Finding Text
Assistance Listing, Federal Agency, and Program Name - ALN 14.218, U.S. Department of Housing and Urban Development, CDBG Entitlement Grants Cluster - Community Development Block Grant Federal Award Identification Number and Year - B-20-MC-26-0033, B-21-MC-26-0033, B-22-MC-26-0033, B-23-MC-26-0033, B-24-MC-26-0033 Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - 29 CFR 5.5.ii.A requires that certified payrolls be submitted weekly to the Township for each week in which work is performed and for these records to be maintained for at least three years. Condition - We noted no indication that certified payrolls were obtained and reviewed by Township officials prior to payment being made to a contractor for construction work performed in one instance. Questioned Costs - N/A Identification of How Questioned Costs Were Computed - N/A Context - There were several weeks during the year where contractors were being paid, but there was no documentation as to why there were no certified payrolls for those weeks. Cause and Effect - Lack of controls to ensure certified payrolls are received weekly for all applicable invoices prior to payment could result in questioned costs if such invoices include labor related costs. Recommendation - We recommend the Township implement controls to ensure that certified payroll is received weekly for all construction invoices prior to payment. This control should include a process to document procedures performed during weeks when certified payroll is not necessary. Views of Responsible Officials and Planned Corrective Actions - While controls are in place to ensure payments to vendors are not made without completed review of certified payrolls, staff acknowledges records kept did not provide adequate backup to verify these controls. Going forward, staff will not only be sure to keep copies of certified payrolls with related invoices, they will also maintain records that confirm invoices without certified payrolls did not include labor that is subject to Davis Bacon wage requirements. These records will likely come in the form of detailed invoice cost breakdowns (showing absence of labor costs) or correspondence affirming no labor costs were included in the invoice.