Finding Text
SPECIAL TESTS AND PROVISIONS, WAGE RATE REQUIREMENTS – COMPLIANCE AND CONTROLS REPEAT FINDING: NO FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT; PASSED THROUGH FLORIDA DEPARTMENT OF COMMERCE PROGRAM: COMMUNITY DEVELOPMENT BLOCK GRANTS, ALN 14.228 GRANT NUMBERS: H2494, H2384, M0043, M0024, M0150, M0154, MT151 FINDING TYPE: SIGNIFICANT DEFICIENCY CRITERIA: 2 CFR 200.303(a) of the Uniform Guidance requires non-federal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. CONDITION: The County relies on third-party consultants to obtain and review construction contractors’ weekly certified payrolls, and the consultants report the information to the County. In some cases, the County does not review the certified payrolls until the end of the construction contract. Additionally, the auditor tested 2 of 3 grants that had construction performed during the fiscal year for compliance with this requirement and for 1 grant tested, the County could not provide evidence that the consultant verified that the certified payrolls were submitted. The sample was not statistically valid. CAUSE: Management has not established procedures for regular monitoring of consultants’ performance related to obtaining and reviewing evidence of certified payrolls. EFFECT: Certified payrolls for a construction contract subject to wage rate requirements under the Davis-Bacon Act were not reviewed by the County during the fiscal year. QUESTIONED COSTS: None. The auditor is not aware of any amounts paid in violation of Federal statutes as a result of this finding. RECOMMENDATION: We recommend procedures be established for the County to obtain and review of certified payrolls for the construction projects on a more frequent basis to ensure compliance with the wage rate requirements. VIEW OF RESPONSIBLE OFFICIALS: See Management’s Response and Corrective Action Plan beginning on page 122.