Compliance Monitoring Criteria – The City entered into an agreement with East Central Intergovernmental Association (ECIA) to administer the Lead-Based Paint Hazard Control in Privately-Owned Housing grant (LBA). The agreement requires ECIA identify applicable federal and state laws and regulations and assist in complying with federal and state requirements. The agreement also requires ECIA monitor and evaluate the project progress to facilitate compliance with applicable federal and state laws and regulations. Condition – As the primary recipient of the LBA grant, the City is responsible to ensure compliance with the requirements of the Uniform Guidance. ECIA monitored the LBA grant to ensure compliance with the requirements of the Uniform Guidance. However, the City did not review and retain documentation by ECIA to ensure the City complied with the requirements of the Uniform Guidance. Cause – Although the City contracted with ECIA to administer the grant, the City is the grant recipient and, accordingly, is responsible for ensuring compliance. The City was unaware it retained this responsibility. Effect – The City is not properly monitoring ECIA to ensure compliance with the requirements of the Uniform Guidance. Noncompliance with the requirements of the Uniform Guidance could result in the loss and refunding of grant funds. Recommendation – The City should maintain and review documentation to ensure applicable compliance requirements have been met. The review should be evidenced by the initials or signature of the reviewer and the date of the review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. In addition to those supporting documents, the City is already requesting ECIA’s yearly audit report, but will implement a procedure to sign off that it was reviewed. Conclusion – Response accepted.
Federal Funding Accountability and Transparency Act Reports Criteria – The Federal Funding Accountability and Transparency Act (Pub. L.No. 109-282), as amended by Section 6202 of the Government Funding Transparency Act of 2008 (Pub. L. No. 110-252), requires prime awardees to submit reports regarding their first-tier subawards to the Federal funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports are due for all applicable subrecipient grants by the end of the month subsequent to the month the grants were awarded. Condition – The City did not report subaward information for one subrecipient as required by the Federal Funding Accountability and Transparency Act. Cause – Although the City contracted with ECIA to administer the grant, the City remained the grant recipient and, accordingly, retained responsibility for ensuring compliance was met. The City was unaware it retained this responsibility. Effect – The City is not reporting the required subaward information to ensure compliance with the requirements of the Uniform Guidance. Recommendation – The City should establish policies and procedures to ensure reports are submitted in accordance with the Federal Funding Accountability and Transparency Act. Response and Corrective Action Planned – The City is now aware that as the grant recipient, we are responsible for the reporting, and will begin reporting to be in compliance with the requirements of the Uniform Guidance. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Compliance Monitoring Criteria – The City entered into an agreement with East Central Intergovernmental Association (ECIA) to administer the Lead-Based Paint Hazard Control in Privately-Owned Housing grant (LBA). The agreement requires ECIA identify applicable federal and state laws and regulations and assist in complying with federal and state requirements. The agreement also requires ECIA monitor and evaluate the project progress to facilitate compliance with applicable federal and state laws and regulations. Condition – As the primary recipient of the LBA grant, the City is responsible to ensure compliance with the requirements of the Uniform Guidance. ECIA monitored the LBA grant to ensure compliance with the requirements of the Uniform Guidance. However, the City did not review and retain documentation by ECIA to ensure the City complied with the requirements of the Uniform Guidance. Cause – Although the City contracted with ECIA to administer the grant, the City is the grant recipient and, accordingly, is responsible for ensuring compliance. The City was unaware it retained this responsibility. Effect – The City is not properly monitoring ECIA to ensure compliance with the requirements of the Uniform Guidance. Noncompliance with the requirements of the Uniform Guidance could result in the loss and refunding of grant funds. Recommendation – The City should maintain and review documentation to ensure applicable compliance requirements have been met. The review should be evidenced by the initials or signature of the reviewer and the date of the review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. In addition to those supporting documents, the City is already requesting ECIA’s yearly audit report, but will implement a procedure to sign off that it was reviewed. Conclusion – Response accepted.
Federal Funding Accountability and Transparency Act Reports Criteria – The Federal Funding Accountability and Transparency Act (Pub. L.No. 109-282), as amended by Section 6202 of the Government Funding Transparency Act of 2008 (Pub. L. No. 110-252), requires prime awardees to submit reports regarding their first-tier subawards to the Federal funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports are due for all applicable subrecipient grants by the end of the month subsequent to the month the grants were awarded. Condition – The City did not report subaward information for one subrecipient as required by the Federal Funding Accountability and Transparency Act. Cause – Although the City contracted with ECIA to administer the grant, the City remained the grant recipient and, accordingly, retained responsibility for ensuring compliance was met. The City was unaware it retained this responsibility. Effect – The City is not reporting the required subaward information to ensure compliance with the requirements of the Uniform Guidance. Recommendation – The City should establish policies and procedures to ensure reports are submitted in accordance with the Federal Funding Accountability and Transparency Act. Response and Corrective Action Planned – The City is now aware that as the grant recipient, we are responsible for the reporting, and will begin reporting to be in compliance with the requirements of the Uniform Guidance. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.
Special Test – Wage Rate Requirements Criteria – 29 CFR part 5, “Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assistance Construction”, requires contractors to submit a copy of the payroll and statement of compliance (certified payrolls) weekly. Payrolls should be reviewed by the City to ensure compliance with the wage rate requirements. Condition – Two of three projects’ certified payrolls tested had no evidence of review by the grant administrator. Cause – Procedures have not been designed and implemented to ensure all certified payrolls are reviewed. Effect – The City is not always reviewing certified payrolls to ensure compliance with Federal regulations pertaining to wage rate requirements. Recommendation – The City should implement procedures to ensure certified payrolls are reviewed. The reviews should be documented by the initials or signature of the reviewer and the date of review. Response and Corrective Action Planned – The City will begin to request that ALL supporting documents of an ECIA claim accompanies the claim. This will include (but is not limited to) the certified payrolls, the contractor invoices, time analysis worksheets for ECIA personnel being charged to the grant and reporting from ECIA’s tracking systems. Conclusion – Response accepted.