Finding Text
Finding 2025-007: Significant Deficiency – Special Tests and Provisions Program: Climate Pollution Reduction Grants Assistance Listing Number: 66.046 Federal Agency: U.S. Environmental Protection Agency Federal Award Identification Number: 03D30125 Federal Award Year: June 30, 2025 Criteria: The Uniform Guidance requires that entities obtain certified payroll records for each week in which work was performed under a contract funded by an award that contains Wage Rate Requirements and review those records for compliance with the applicable wage rate requirements. Condition: The Club notified the contractor of the wage rate requirements but did not obtain or review certified payroll records for each week in which work was performed under the contract. Questioned Costs: None noted. Context: Two contracts under the grant were subject to wage rate requirements. The sample is not considered statistically valid. Effect: The Club did not perform adequate monitoring of contractors to ensure compliance with applicable wage rate requirements, which increases the risk of noncompliance with grant requirements. Cause: Club personnel were advised by the Environmental Protection Agency (EPA) that certified payroll records would only need to be made available if the grant was under EPA audit, so certified payroll records were not obtained and reviewed each week in which work was performed under the contract. Recommendation: It is recommended that the Club implement policies and procedures to ensure that weekly certified payrolls are obtained from contractors subject to wage rate requirements and those payroll records are reviewed for compliance with the applicable wage rate requirements. Management’s Response: The Club Finance Director will work with the current contractor and set up a schedule for payroll review based on their payroll schedule.