Audit 406113

REPORTING – COMPLIANCE AND CONTROLS REPEAT FINDING: NO FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT; PASSED THROUGH FLORIDA DEPARTMENT OF COMMERCE PROGRAM: COMMUNITY DEVELOPMENT BLOCK GRANTS, ALN 14.228 GRANT NUMBERS: H2494, H2384, M0043, M0024, M0150, M0154, MT151 FINDING TYPE: SIGNIFICANT DEFICIENCY CRITERIA: Under 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)), OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326; the County’s contractor is required to submit a copy of the payroll and a statement of compliance (certified payrolls) weekly for each week in which any contract work is performed. The grant agreements outline the reports required to be submitted and their due dates. Additionally, 2 CFR 200.303(a) of the Uniform Guidance requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. CONDITION: 18 of 135 total reports required under the grants were tested for compliance with this requirement. This was not a statistically valid sample. The auditor noted the following which affected 7 of the reports tested: - For 5 reports, there was no evidence of a second review - For 1 monthly progress report, the report was submitted later than the due date - For 1 quarterly progress report, the funds used through the report date were not included at the correct amount and there were other mathematical errors - For 2 reports, the client could not show when the reports were submitted to the grantor CAUSE: Management has not established procedures for reviewing all program reports and/or the reviews failed to identify reporting errors and ensure reports were submitted timely. EFFECT: Certain reports were not submitted timely or may not have been submitted to the grantor, and certain reports were inaccurate. QUESTIONED COSTS: None. The finding is over the reporting compliance requirement. Amounts expended and received from federal awards were not affected. RECOMMENDATION: We recommend procedures be established for review of all program reports prior to submission to the grantors and that the review be documented; procedures be established to ensure reports are submitted timely; and a reconciliations of reported amounts to the accounting records be performed. VIEW OF RESPONSIBLE OFFICIALS: See Management’s Response and Corrective Action Plan beginning on page 122.

SPECIAL TESTS AND PROVISIONS, WAGE RATE REQUIREMENTS – COMPLIANCE AND CONTROLS REPEAT FINDING: NO FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT; PASSED THROUGH FLORIDA DEPARTMENT OF COMMERCE PROGRAM: COMMUNITY DEVELOPMENT BLOCK GRANTS, ALN 14.228 GRANT NUMBERS: H2494, H2384, M0043, M0024, M0150, M0154, MT151 FINDING TYPE: SIGNIFICANT DEFICIENCY CRITERIA: 2 CFR 200.303(a) of the Uniform Guidance requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. CONDITION: The County relies on third-party consultants to obtain and review construction contractors’ weekly certified payrolls, and the consultants report the information to the County. In some cases, the County does not review the certified payrolls until the end of the construction contract. Additionally, the auditor tested 2 of 3 grants that had construction performed during the fiscal year for compliance with this requirement and for 1 grant tested, the County could not provide evidence that the consultant verified that the certified payrolls were submitted. The sample was not statistically valid. CAUSE: Management has not established procedures for regular monitoring of consultants’ performance related to obtaining and reviewing evidence of certified payrolls. EFFECT: Certified payrolls for a construction contract subject to wage rate requirements under the Davis-Bacon Act were not reviewed by the County during the fiscal year. QUESTIONED COSTS: None. The auditor is not aware of any amounts paid in violation of Federal statutes as a result of this finding. RECOMMENDATION: We recommend procedures be established for the County to obtain and review of certified payrolls for the construction projects on a more frequent basis to ensure compliance with the wage rate requirements. VIEW OF RESPONSIBLE OFFICIALS: See Management’s Response and Corrective Action Plan beginning on page 122.