Management’s Action Plan: The Neighborhoods Department is committed to ensuring wage rate requirements for contractors and subcontractors are prioritized and internal controls are properly documented. In particular, evidence of approvals needed to ensure compliance with allowable costs, cost princip...
Management’s Action Plan: The Neighborhoods Department is committed to ensuring wage rate requirements for contractors and subcontractors are prioritized and internal controls are properly documented. In particular, evidence of approvals needed to ensure compliance with allowable costs, cost principles and period of performance requirements will be documented for all invoices and payroll allocations. Weekly payroll reports will be reviewed as part of the special tests and provisions needed to comply with wage rate requirements.
A Labor Standards and Construction Manager has been hired to monitor all contracts with labor standard regulations, including wage rate requirements. This individual will be tasked with setting up tracking systems and monitoring compliance of the various City departments, as well as external subrecipients, to ensure all regulations and requirements for labor standards are followed.
Currently, City Departments using federal funds through a MOU with the Neighborhoods Department can access funds and pay vendors without a review by the Housing & Community Development Division’s team. This has led to vendors being paid without submitting the proper wage rate requirement documentation. To mitigate this challenge, the Division has recommended that funds appropriated to other City departments be held by the Housing & Community Development Division, so that verification of wage rate requirements can occur prior to any payment for services.
We will ensure that the written procedures for controls include the title of the positions responsible for each control (preparation, review, reconciliation, etc.) and require that the performance of the controls be documented in a clear, reperformable manner including the name of each responsible individual, the specific control they performed over compliance for the grant and the date(s) the controls were performed.
Contact Names responsible for the plan – Travis Jeffrey
Anticipated completion date of the plan – September 2025