It's great when a
public agency receives federal funding for a project that they might
otherwise not be able to fund. However, federal money comes with
procurement and contracting requirements.
Consequences of Non-Compliance: Failure to comply with federal grant requirements may result in:
- Audit findings from the federal agency providing the funding
- Audit findings from a state auditor
- Having to pay grant money back to the federal government
Audit Findings for School District: In Washington State, the Othello School District No. 147 recently received an audit finding
from the State Auditor's Office for failing to comply with various
federal procurement requirements. The District spent $174,417 in
construction costs with funding from the American Recovery and
Reinvestment Act (ARRA). The audit found that the District did not
comply with the following:
- Davis-Bacon Prevailing Wage Requirements: The District did not inform the contractor that federal prevailing wages applied on the project, and did not collect weekly certified payrolls from the contractor and all subcontractors, as required.
- Suspension and Debarment: The District did not verify that the contractor was not suspended or debarred from doing business on federally funded projects as required. Agencies receiving federal funding should check www.epls.gov for any contract of $25,000 or more, and print out documentation for the file demonstrating that the contractor (or consultant or vendor) is not on the suspension/debarment list.
- Buy American: On ARRA funded projects, iron, steel, and construction materials must be manufactured in the United States. "The District did not ensure the Buy American requirement was included in its construction contract with the contractor, and it did not monitor compliance."
Mike Purdy's Public Contracting Blog© 2012 by Michael E. Purdy Associates, LLChttp://PublicContracting.blogspot.com
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