Finding 1240182 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-10-08
Audit: 414768
Organization: City of Toledo (OH)

AI Summary

  • Core Issue: The City lacks a proper system to monitor and track certified payroll reports for contractors working on projects with prevailing wage requirements.
  • Impacted Requirements: Federal and state laws mandate that certified payroll reports be submitted weekly; failure to comply affects the City's adherence to wage rate regulations.
  • Recommended Follow-Up: Implement a formal tracking system and internal controls to ensure timely submission and review of certified payroll reports for all relevant contracts.

Finding Text

Finding 2025-003 – Significant Deficiency/Wage Rate Requirements CDBG – Entitlement Grants Cluster – ALN 14.218 U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Criteria: Federal and state prevailing wage requirements require contractors and subcontractors working on applicable projects to submit certified payroll reports on a weekly basis. As the awarding entity, the City is responsible for monitoring compliance and maintaining documentation demonstrating that required certified payroll reports have been received and reviewed. Condition: During testing, we noted that the City did not have an adequate process in place to monitor contracts and projects subject to prevailing wage requirements. Specifically, the City did not maintain a comprehensive method for tracking applicable contracts and ensuring that weekly certified payroll reports were submitted timely by prime contractors and subcontractors for review. Context: The City did not receive two of the six required certified payroll reports tested. Cause: The City has not established formal procedures or internal controls to identify all prevailing wage projects and monitor the timely receipt and review of required certified payroll reports. Effect: The City was not in compliance with wage rate requirements in 2025. Recommendation: We recommend the City establish and implement a formal tracking system and related internal controls for all contracts and projects subject to prevailing wage requirements, including CDBG-funded projects. The system should identify all applicable prime contractors and subcontractors and ensure that weekly certified payroll reports are submitted and reviewed timely in accordance with prevailing wage requirements. Views of Responsible Officials: Management concurs. See corrective action plan.

Corrective Action Plan

The City will establish and implement a formal tracking system and related internal controls for all contracts and projects subject to prevailing wage requirements, including CDBG-funded projects. The system should identify all applicable prime contractors and subcontractors and ensure that weekly certified payroll reports are submitted and reviewed timely in accordance with prevailing wage requirements.

Categories

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1240179 2025-002
    Material Weakness Repeat
  • 1240180 2025-003
    Material Weakness Repeat
  • 1240181 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $7.59M
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $6.23M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $5.11M
14.900 LEAD-BASED PAINT HAZARD CONTROL IN PRIVATELY-OWNED HOUSING $1.74M
14.251 Economic Development Initiative, Community Project Funding $1.27M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $1.25M
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $1.22M
20.287 Surface Transportation Block Grant Program $1.16M
66.001 AIR POLLUTION CONTROL PROGRAM SUPPORT $1.12M
11.463 HABITAT CONSERVATION $957,388
97.047 Wright Avenue FEMA BRIC Grant $773,014
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $701,160
66.469 GREAT LAKES PROGRAM $516,397
66.460 NONPOINT SOURCE IMPLEMENTATION GRANTS $274,711
97.067 HOMELAND SECURITY GRANT PROGRAM $109,543
66.818 BROWNFIELDS ASSESSMENT AND CLEANUP COOPERATIVE AGREEMENTS $88,547
16.045 Community-Based Violence Intervention and Prevention Initiative $71,829
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $54,772
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $47,268
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $44,047
16.742 PAUL COVERDELL FORENSIC SCIENCES IMPROVEMENT GRANT PROGRAM $34,327
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $16,346
14.023 Community Development Block Grant - PRO Housing Competition $8,582
16.609 PROJECT SAFE NEIGHBORHOODS $7,537
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $6,369
16.839 Stop School Violence $459
66.468 CAPITALIZATION GRANTS FOR DRINKING WATER STATE REVOLVING FUNDS $18