Finding 620144 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-11-20

AI Summary

  • Core Issue: The Authority failed to conduct required employee interviews and provide necessary documentation (HUD-11) for compliance with the Davis-Bacon Act.
  • Impacted Requirements: Lack of internal controls means potential non-compliance with wage rate requirements, risking underpayment of workers on projects.
  • Recommended Follow-Up: Implement procedures for employee interviews and maintain documentation in contract files to ensure accurate reporting of payroll.

Finding Text

2022-001 CFDA #14.872 ? Public Housing Capital Funds Program ? Wage Rate Requirements Condition and Criteria: The Authority was not able to provide necessary documentation that includes Record of Employee Interviews form HUD-11 as required by the Department of Labor?s Davis-Bacon Act. The Davis-Bacon Act requires a contractor whose contract is over $2,000 to provide weekly certified payrolls to prove that they are paying prevailing wage rates. The Authority is required to perform contractor employee interviews and document on form HUD-11. Amount of Questioned Costs: None. Context: It was determined that the internal controls over Davis-Bacon wage rate requirements were likely to be ineffective due to the fact that the Authority explained that they did not perform contractor employee interviews for the D.W. Builders contract that was selected for audit testing. The Authority was unable to provide the documentation of form HUD-11. Cause: A procedure does not exist whereby the Authority interviews contracted employees to ensure they are being paid fairly per Davis-Bacon wage rate requirements. Effect: The Authority does not have proper controls in place to ensure compliance with the Department of Labor?s Davis-Bacon Act. As a result, contractors could be underpaying works while working on Authority projects. Auditor?s Recommendation: We recommend that the Authority implement procedures to interview employees to ascertain that information is accurate reported on the weekly certified payroll reports is accurate and to document this information on form HUD-11. We also recommend that the Authority maintain this documentation in the contract file. Grantee Response: Management acknowledges the finding and will follow the auditor?s recommendation.

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

  • 43702 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.872 Public Housing Capital Fund $712,304
14.850 Public and Indian Housing $489,803