Finding Text
Finding No. 2025-002: Inadequate Controls Related to Wage Rate Requirements, Significant Deficiency Federal award agency: US Department of Transportation Federal Transit Administration Program name and ALN: Highway Planning and Construction (Federal-Aid Highway Program) 20.205 Federal award identification number: X21FBP0120-C12 Federal award year: 2025 Criteria: The Wage Rate Requirements aka Davis-Bacon Act requires that all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2k 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. For each week in which work was performed under the contract or subcontract, the grantee shall obtain certified payrolls from the contractor or subcontractor. Condition: Of the five contracts included within major program 20.205 in the current year, two were subject to the wage rate requirement. These two contracts accounted for $1.9M of the $4M total program expenditures. In total there were 13 weeks of payroll included within the two contracts, of which three were selected for testing. Cause: The internal control failure occurred due to the timing of the invoices in relation to year end close procedures. The Treasurer indicated that the payment was accelerated to capture both the expense and cash outlay within the same fiscal year overlooking the need to confirm the receipt of the certified payrolls. Effect or potential effect: The identified control deficiency could result in non-compliance. Requiring the receipt of certified payrolls prior to invoice payment gives the Authority leverage and motivates the contractor or subcontractor to meet the requirements of the agreement in order to receive payment, further it ensure that the Authority remains in compliance with federal requirements. Questioned costs: None noted. Context: 3 control exceptions out of 3 selections. Recommendation: To mitigate this risk, it is recommended that the Authority review and evaluate its internal control processes and procedures related to the Davis Bacon Wage Act to ensure that the information is complete and accurate. Views of responsible official: The Authority agrees with the above finding and its response is included in the corrective action plan.