Finding 963060 (2023-002)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-27

AI Summary

  • Core Issue: The Airports lack internal controls to monitor compliance with wage rate requirements, specifically regarding weekly certified payrolls from contractors.
  • Impacted Requirements: Compliance with 29 CFR Sections 5.5 and 5.6, which mandate that contractors submit certified payrolls weekly.
  • Recommended Follow-up: Implement and formalize internal controls to regularly review third-party consultant submissions and ensure compliance with wage rate requirements.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - 20.106 Federal Aviation Administration - Airport Improvement Program Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - 29 CFR Sections 5.5 and 5.6 establish certain requirements for wage rate requirements. This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). The Airports are responsible for monitoring compliance by any third-party contractor to ensure compliance requirements are being met. Condition - During the audit, it was determined that there is no control function in place by the Airports staff to ensure that wage rate compliance with weekly certified payrolls is occurring. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The Airports have hired a third-party consultant to perform compliance work regarding obtaining weekly certified payrolls from contractors, and subcontractors as required under the wage rate requirements. The third party has access to upload the certified payrolls to a shared folder with the Airports. The Airports do not have internal controls to monitor or review the work of the third-party consultant. Without this review, the Airports may not be able to detect if a noncompliance by the contractors or subcontractors has occurred. During our testing, we did not note any noncompliance matters related to the wages that were paid for a sample of expenditures that were tested. Cause and Effect - Due to the Airports' lack of monitoring or review of the certified payrolls obtained by the third-party consultant, they did not maintain the proper internal controls to ensure compliance with the wage rate requirement. Recommendation - Internal controls should be implemented and formalized to ensure proper monitoring and reviews of the information provided by the third party are occurring in regards to wage rate requirements. Views of Responsible Officials and Corrective Action Plan - Certified payroll registers that are uploaded in the Airports' web-based databases will be checked monthly by HDOT staff to detect and correct matters related to wage rate requirements. Noncompliance notices will be issued to the third-party consultants when missing information or errors are identified.

Categories

Subrecipient Monitoring Matching / Level of Effort / Earmarking Material Weakness

Other Findings in this Audit

  • 386618 2023-002
    Material Weakness
  • 386619 2023-002
    Material Weakness
  • 963061 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
20.106 Airport Improvement Program $74.13M
20.106 Covid-19 - Airport Improvement Program $46.89M