Noncompliant Certified Payrolls - HPC - MDT - The Montana Department of Transportation partially concurs that there are late certified payrolls. To verify whether a certified payroll is warranted, contractor records—such as payroll cycle dates and corresponding Daily Work Report entries—must be revi...
Noncompliant Certified Payrolls - HPC - MDT - The Montana Department of Transportation partially concurs that there are late certified payrolls. To verify whether a certified payroll is warranted, contractor records—such as payroll cycle dates and corresponding Daily Work Report entries—must be reviewed. Comparing datasets can help identify items needing further examination, but an analytical review alone cannot determine whether a certified payroll is late. Each contractor follows its own payroll cycle, and federal requirements must be applied to the circumstances of each contractor. This concern was raised multiple times, and while some issues were addressed, the additional review needed to confirm the accuracy of the identified noncompliance remains unresolved. In communication with the department, the auditor stated that “we will never arrive at an exact number we can all agree on due to gaps in Daily Work Report data and an uncertain measurement metric.” This acknowledgment calls into question the reliability of the projected late payment rate and indicates the need for additional procedures to validate the assumptions and methodology used in the analytical review. The department manually recalculated the contractor identified as having the highest number of late submissions. This review resulted in a rate 47.53 percent lower than the auditor’s calculation; however, the auditor did not revise the analysis. This recalculation reflects only one contractor, and reviewing the remaining contractors would likely further reduce the overall percentage. The department will continue strengthening internal controls on overdue payrolls. The original payroll withholding specification lacked a standard calculation method, which led to inconsistent practices among project managers. The Contract Administration Section developed a standardized deduction table based on the awarded contract amount to ensure consistent application statewide. Specification language was also revised for clarity. Additionally, the Contract Administration Section developed a monthly overdue payroll report that will be sent to project managers around the fifteenth of each month. This report will help identify and address overdue payrolls before the monthly estimate cycle ends. The department will continue monitoring overdue payrolls, ensuring proper withholding on estimates, and providing guidance and additional training to project staff. A guide has also been provided to help staff document communication with contractors and apply correct withholding. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Dustin Rouse, Chief Engineer, Montana Department of Transportation Target Implementation Date - 12/31/2026