Dear Mr. Waguespack:
The Department is in receipt of your single audit finding entitled "Inadequate Controls over and Noncompliance with Wage Rate Requirements". I appreciate the opportunity to respond to the finding and also to have my response letter included as an attachment in the final report....
Dear Mr. Waguespack:
The Department is in receipt of your single audit finding entitled "Inadequate Controls over and Noncompliance with Wage Rate Requirements". I appreciate the opportunity to respond to the finding and also to have my response letter included as an attachment in the final report.
The Department concurs with the finding.
We plan to implement all corrective actions by April 30, 2024. Ms. Paula Roddy, Compliance Programs Director, will be responsible for ensuring implementation for all Compliance related matters. Mr. M. Todd Donmyer, Assistant Secretary of Operations, will be responsible for ensuring implementation for all Operations related matters. The following are our corrective action plans for each of the issues noted:
• To address the exceptions identified with DOTD's compliance with the Copeland Act ensuring that contractor's estimates are only approved after all required payrolls for the service period are submitted, we offer the following control enhancements:
o Compliance Programs will update the Labor Compliance Manual to add the Estimate Approval Process with specific instructions for the following Construction phases of a project:
• Assembly Period 1st estimate
• Zero Dollar estimate
• Project estimate (payroll coverage needed to approve)
• 30-day estimate
• 30 plus day estimate
• Closeout estimate
o Responsible Compliance Programs employee and backup will be trained on Manual updates
o Compliance Programs will discuss these requirements at any Project Engineer and District Administrator meetings section personnel attend, as well as at the annual shade tree meetings, when possible.
• To address the exceptions identified with compliance with DOTD's policy for site interviews for Davis-Bacon eligible projects, we offer the following control enhancements:
o The Office of Operations will develop a District by District process to schedule, coordinate, and follow-up with their respective Project Engineers to ensure site interviews are performed, signed, and scanned into the system of record. Additionally, part of this process will be to develop an internal audit process to ensure the controls implemented are working effectively.
o Compliance Programs will work with the Enterprise Support Services to develop a report identifying all Davis-Bacon eligible projects. This list will be communicated on an ongoing basis to the responsible District personnel and will be used by the Labor Compliance Manager to perform spot audits for compliance. Any areas of deficiency should be addressed or exceptions documented accordingly.
o Compliance Programs will discuss these requirements at any Project Engineer and District Administrator meetings section personnel attend, as well as at the annual shade tree meeting when possible.
Thank you for the opportunity to respond to this audit finding and to have this Management Response Letter included in the final audit report. Please feel free to contact me at (225) 379-1200 or Don Johnson, Undersecretary, at (225) 379-1010, should you have any questions.