Finding 1205185 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-31
Audit: 396839
Organization: City of Richardson (TX)
Auditor: CROWE LLP

AI Summary

  • Core Issue: The City failed to obtain certified payrolls from contractors on time, risking non-compliance with federal wage rate requirements.
  • Impacted Requirements: Compliance with prevailing wage rates as mandated by the Department of Labor for federally funded construction contracts.
  • Recommended Follow-Up: Implement internal controls to monitor and track certified payroll submissions to ensure timely compliance with wage rate requirements.

Finding Text

Finding 2025-001: Special Tests – Wage Rate Requirements – Significant Deficiency Program: Highway Planning and Construction Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Pass-through entity: Texas Department of Transportation Award No.: CSJ0918-24-268 Award Year: Fiscal year 2024-2025 Category of Finding: Special Tests – Wage Rate Requirements Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3147). Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (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). Condition: In two out of seven selections tested for required certified payrolls for contractor or subcontractor work performed during the fiscal year ended September 30, 2025, the certified payrolls were not obtained by the City until subsequent to audit fieldwork. In addition, the City did not have internal controls in place to identify that these certified payrolls were not being obtained. Cause: Policies and procedures were not in place to ensure that certified payrolls are obtained from contractors during the year. Effect: Certified payrolls were not obtained or reviewed in a timely manner for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Questioned Costs: None. Context: There were two contracts included for projects under this program. Certified payrolls were not obtained from one of the contractors until subsequent to audit fieldwork. Identification of a repeat finding: Not a repeat finding. Recommendation: The City should design and implement internal controls to ensure compliance with the program’s wage rates requirements. These controls should include monitoring construction contracts, tracking weekly certified payrolls or notification of no work performed and reviewing to ensure that the payrolls are properly certified for all contractor and subcontractor work performed. Management Response: See Corrective Action Plan.

Corrective Action Plan

February 27, 2026 Re: Corrective Action Plan in response to Federal Single Audit Introduction On February 27, 2026, Crowe LLP issued the Independent Auditor’s Report as required and in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Controller General. The Corrective Action Plan, submitted by the City of Richardson more specifically, responds to the Report and outlines the City’s corrective action plans to address the finding. We again thank Crowe LLP for their hard work in this matter. This single audit has and will continue to serve as a roadmap for future financial operations. Finding 2025-001: Special Tests – Wage Rate Requirements – Significant Deficiency In two out of seven selections tested for required certified payrolls for contactor or subcontractor work performed during the fiscal year end September 30, 2025, the certified payrolls were not obtained by the City until subsequent to audit fieldwork. In addition, the City did not have internal controls in place to identify that these certified payrolls were not being obtained. Response: The City acknowledges that the required supporting documentation was not available at the time compliance testwork was completed by Crowe LLP. The City recognizes its responsibility to obtain and review certified payroll records from contractors and subcontractors for all laborers working on City grant funded projects to ensure wages and fringe benefits are paid in compliance with the Davis-Bacon Act. Corrective Action Plan: The City has an established Grants Management Policy and quarterly reporting from departments stating compliance with grant requirements. To strengthen compliance and address the documentation deficiency identified in the audit finding, the City will conduct mandatory training sessions with designated grant personnel in each department to reinforce policy requirements, required documentation standards, and applicable federal and state regulations, including certified payroll monitoring requirements where applicable. Training will be completed by June 30, 2026, and will be provided annually thereafter.The City will implement a grant review process that includes a master checklist to assist departments in verifying compliance prior to processing payments. The checklist will include verification that required supporting documentation, including certified payroll records when applicable, has been received, reviewed, and approved. Implementation of this checklist will occur by March 31, 2026. A centralized electronic repository will be established to allow Finance access to grant agreements, supporting documentation and relate records maintained by City departments. This control will be implemented by March 31, 2026. Additional internal controls will be incorporated into the financial software system to ensure that all required supporting documentation is attached and reviewed prior to payment approval. This control will be implemented by March 31, 2026. The City will conduct periodic internal compliance review testing of grants, including verification of required labor compliance documentation where applicable, to confirm ongoing adherence to federal and state regulations. Pre-award and post-award meetings will be held between Finance and the respective grant departments to establish reporting parameters, documentation requirements, monitoring responsibilities and compliance expectations prior to project implementation. When bids are solicited that include grant funding, the City will continue to communicate to all prospective bidders that compliance with all applicable federal and state laws and regulations, including labor standard requirements when applicable, is a condition of award. Bid documents will include a sample copy of the U.S. Department of Labor Davis-Bacon and Related Acts Weekly Certified Payroll form. Contact Person Responsible/Anticipated Completion Date: The Finance Director is responsible for oversight of this corrective action plan, with day-to-day management and implementation delegated to the Assistant Director of Finance. Implementation of these corrective actions is scheduled to begin immediately, with full completion anticipated by June 30, 2026. Once implemented, the procedures will be monitored on an ongoing basis to ensure continued compliance and to prevent recurrence of the finding.

Categories

Subrecipient Monitoring Special Tests & Provisions Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.205 HIGHWAY PLANNING AND CONSTRUCTION $290,319
20.939 SAFE STREETS AND ROADS FOR ALL $99,911
97.067 HOMELAND SECURITY GRANT PROGRAM $80,726
16.034 CORONAVIRUS EMERGENCY SUPPLEMENTAL FUNDING PROGRAM $75,456
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $70,675
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $21,797
16.922 EQUITABLE SHARING PROGRAM $17,507
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $9,367