FAC Explorer

Finding 394559 (2023-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-04-24
Audit: 304432
Organization: Collier County (FL)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The County failed to obtain and review certified payrolls as required by the Davis-Bacon Act, leading to noncompliance with federal requirements.
  • Impacted Requirements: Compliance with prevailing wage requirements and effective internal controls under 2 CFR Section 200.303(a) were not met.
  • Recommended Follow-Up: The County should update its policies and procedures to ensure all certified payrolls are verified and maintained throughout the grant period.

Finding Text

Federal Agency: U.S. Department of the Transportation Federal Program Name: National Infrastructure Investments Assistance Listing Number: 20.933 Federal Award Identification Number and Year: 693JJ32040007 - 2020 Award Period: 08/03/2020 – 10/31/2024 Type of Finding: Material Weakness in Internal Control over Compliance; Material Noncompliance (Modified Opinion) Criteria or specific requirement: Under Davis-Bacon Act - 40 U.S.C. §§ 3141, et seq., as applicable under 23 U.S.C. 113, prevailing wage requirements each contractor must submit weekly certified payrolls to the contracting agency or entity certified payrolls providing information for each covered worker. Each certified payroll must be accompanied by a "Statement of Compliance" certifying compliance with applicable requirements. Per 2 CFR Section 200.303(a) the non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County did not obtain, maintain, or review certified payrolls as required for special provisions Davis Bacon Act for all vendors. Questioned costs: None Context: For two out of the eight payrolls selected for testing, the County did not properly obtain and review certified payrolls provided by subcontractor. The certifications were subsequently collected and reviewed when they were selected for audit testing. Cause: The County did not follow its policies, procedures and internal controls related to obtaining and reviewing certified payrolls from vendors. Effect: The County was not in compliance with the special provision compliance requirements of the program. Repeat Finding: No Recommendation: We recommend the County to implement a process and to update its policies and procedures to ensure that all certified payrolls are properly verified and maintained accurately through grant award period and beyond. Views of responsible officials: Management agrees with the finding. See corrective action plan.

Corrective Action Plan

National Infrastructure Investments -Assistance Listing No. 20.933 Recommendation: Implement a process and to update its policies and procedures to ensure that all certified payrolls are properly verified and maintained accurately through the grant award period and beyond. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff will conduct a documented compliance review no less than monthly comparing the certified payroll tracker against supporting documentation including the payrolls collected by the third-party administrator (TPA). Any discrepancies will be conveyed to the TPA and Contractor and monitored until resolved. The Grants Administration Handbook will be updated for procedures for verification of certified payrolls. Name(s) of the contact person(s) responsible for corrective action: Trinity Scott, Transportation Management Services Department Head, 239-252-5873. Planned completion date for corrective action plan: May 30, 2024

Categories

Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 394550 2023-001
    Material Weakness
  • 394551 2023-001
    Material Weakness
  • 394552 2023-001
    Material Weakness
  • 394553 2023-001
    Material Weakness
  • 394554 2023-001
    Material Weakness
  • 394555 2023-001
    Material Weakness
  • 394556 2023-001
    Material Weakness
  • 394557 2023-001
    Material Weakness
  • 394558 2023-001
    Material Weakness
  • 394560 2023-003
    Significant Deficiency
  • 394561 2023-003
    Significant Deficiency
  • 970992 2023-001
    Material Weakness
  • 970993 2023-001
    Material Weakness
  • 970994 2023-001
    Material Weakness
  • 970995 2023-001
    Material Weakness
  • 970996 2023-001
    Material Weakness
  • 970997 2023-001
    Material Weakness
  • 970998 2023-001
    Material Weakness
  • 970999 2023-001
    Material Weakness
  • 971000 2023-001
    Material Weakness
  • 971001 2023-002
    Material Weakness
  • 971002 2023-003
    Significant Deficiency
  • 971003 2023-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $23.79M
21.027 Covid-19-Coronavirus State and Local Fiscal Recovery Funds $23.46M
21.023 Covid-19-Emergency Rental Assistance Program $3.08M
14.218 Community Development Block Grants/entitlement Grants $3.02M
20.507 Federal Transit_formula Grants $2.72M
20.933 National Infrastructure Investments $2.57M
14.218 Covid-19-Community Development Block Grants/entitlement Grants $2.01M
15.226 Payments in Lieu of Taxes $1.61M
20.507 Covid-19-Federal Transit_formula Grants $1.52M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $658,940
20.509 Formula Grants for Rural Areas and Tribal Transit Program $504,624
14.239 Home Investment Partnerships Program $452,471
14.231 Emergency Solutions Grant Program $378,278
20.106 Airport Improvement Program $198,004
16.710 Public Safety Partnership and Community Policing Grants $196,769
16.575 Crime Victim Assistance $187,500
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $181,814
95.001 High Intensity Drug Trafficking Areas Program $146,181
90.404 2018 Hava Election Security Grants $118,610
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $115,421
14.231 Covid-19-Emergency Solutions Grant Program $113,465
93.044 Covid-19-Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $105,972
20.600 State and Community Highway Safety $96,382
97.042 Emergency Management Performance Grants $93,964
94.002 Retired and Senior Volunteer Program $84,624
93.052 National Family Caregiver Support, Title Iii, Part E $78,188
16.738 Edward Byrne Memorial Justice Assistance Grant Program $72,761
87.052 Gulf Coast Ecosystem Restoration Council Oil Spill Impact Program $65,828
93.568 Covid-19-Low-Income Home Energy Assistance $63,812
16.585 Drug Court Discretionary Grant Program $58,500
93.053 Nutrition Services Incentive Program $40,299
93.568 Low-Income Home Energy Assistance $39,868
20.106 Covid-19-Airport Improvement Program $35,228
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $34,541
16.838 Comprehensive Opioid Abuse Site-Based Program $34,174
21.032 Covid-19-Local Assistance and Tribal Consistency Fund $21,934
97.067 Homeland Security Grant Program $21,073
14.239 Covid-19-Home Investment Partnerships Program $15,560
93.630 Developmental Disabilities Basic Support and Advocacy Grants $13,978
97.046 Fire Management Assistance Grant $11,689
93.563 Child Support Enforcement $3,047
20.205 Highway Planning and Construction $88