WILLIAMSON HOUSING AUTHORITYLocal Government

2022-001 ALN 14.850 ? Public & Indian Housing ? Special Tests & Provisions ? Wage Rate Requirements Criteria: The wage rate requirements (also known as the Davis-Bacon Act) apply to construction activities over $2,000 within public housing. As part of these requirements, non-federal entities are required to include in any applicable contracts, a provision that the contractor or subcontractor shall comply with the wage rate requirements and the Department of Labor (DOL) regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction). The requirements include a provision requiring contractors and subcontractors submit to the non-federal entity weekly, for each week where any contract work has been performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR part 215, Appendix A, Contract Provisions); 2 CFR part 176, subpart C; and 2 CFR section 200.326). Condition: For the fiscal year ended September 30, 2022, we tested wage rate requirements within the Authority?s Public and Indian Housing Program and were unable to obtain the necessary documentation for the one and only ongoing contract where wage rate requirements were required. Cause: Internal controls over wage rate requirements compliance are weak. No procedure exists for Public and Indian Housing Program projects to follow up on stipulations within the contract requiring contractors to submit weekly wage reports, nor does a procedure exist whereby the Authority interviews contracted employees to ensure they are being paid fairly. Effect or Potential Effect: Contractors and subcontractors who are providing construction-related services to the Authority could be paying their employees below the local prevailing wages and fringe benefits paid on projects of a similar character, as defined by the Department of Labor. Questioned Costs: N/A Context: As a result of only one Public and Indian Housing Program contract being required to comply with wage rate requirements during the year-end September 30, 2022, 100% of the population had control deficiencies and a compliance exception, and no additional opportunities for sampling were available. Auditor?s Recommendation: We recommend that the Authority implement procedures to follow up on the obligations of contractors to produce weekly wage reports and compare them with prevailing wage rates. Also, make physical inspections and interview employees to ascertain that the information is accurate. Grantee Response: Management acknowledges the finding and will follow the auditor?s recommendation.