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HomeMy WebLinkAbout2005-2006 Single AuditCity of Evanston, Illinois Single Audit Act Supplementary Financial and Compliance Report Year Ended February 28, 2006 MILLER COOPER & Co., LTD. CONTENTS Page Independent Auditors' Report on Internal Control over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance with Government Auditing Standards 3-4 Independent Auditors' Report on Compliance with Requirements Applicable to Each Major Program and Internal Control over Compliance in Accordance with OMB Circular A-133 and on the Schedule of Expenditures of Federal Awards 5-7 Schedule of Expenditures of Federal Awards 8 - 11 Notes to Schedule of Expenditures of Federal Awards 12 - 13 Schedule of Insurance in Force 14 Schedule of Findings and Questioned Costs 15 - 17 Sunvnary Schedule of Prior Audit Findings 18 - 19 Corrective Action Plan 20 MILLER COOPER & Co., LTD. MILLER C(OPER & Co., Ltd ACCOUNTANTS AND CONSULTANTS INDEPENDENT AUDITORS' REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN ACCORDANCE WITH GO VERNMENT A UDITING STANDARDS The Honorable Lorraine H. Morton, Mayor, and Members of the City Council City of Evanston, Illinois We have audited the financial statements of the governmental activities, the business -type activities, each major fund, and aggregate remaining fund information of the City of Evanston, Illinois, as of and for the year ended February 28, 2006, which collectively comprise the City's basic financial statements, and have issued our report thereon dated August 4, 2006. We conducted our audit in accordance with auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States. Internal Control Over Financial Reporting In planning and performing our audit, we considered the City of Evanston, Illinois', internal control over financial reporting in order to determine our auditing procedures for the purpose of expressing our opinions on the financial statements and not to provide an opinion on the internal control over financial reporting. Our consideration of the internal control over financial reporting would not necessarily disclose all matters in the internal control over financial reporting that might be material weaknesses. A material weakness is a reportable condition in which the design or operation of one or more of the internal control components does not reduce to a relatively low level the risk that misstatements caused by error or fraud in amounts that would be material in relation to the financial statements being audited may occur and not be detected within a timely period by employees in the normal course of performing their assigned functions. We noted no matters involving the internal control over financial reporting and its operation that we consider to be material weaknesses. However, we noted certain matters involving the internal control over financial reporting that we have reported to management of the City of Evanston, Illinois, in a separate letter dated August 4, 2006. (Continued) -3- 650 DUNDEE ROAD, SurrE 250 • NORTHBROOK, IL 60062-2767 PHONE 847.205.5000 • FAX 847.205.1400 - e-mail mccltd@millercooper.com The Honorable Lorraine H. Morton, Mayor, and Members of the City Council City of Evanston, Illinois (Continued) Compliance and Other Matters As part of obtaining reasonable assurance about whether the City of Evanston, Illinois', financial statements are free of material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the determination of financial statement amounts. However, providing an opinion on compliance with those provisions was not an objective of our audit and, accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards. This report is intended solely for the information and use of the Mayor, City Council, management, federal awarding agencies, and pass -through entities and is not intended to be and should not be used by anyone other than those specified parties. MILLER, COOPER & CO., LTD. Certified Public Accountants Northbrook, Illinois August 4, 2006 -4- MILLER COOPER & Co., LTD. MILLER CQDPER & Co., Ltd ACCOUNTANTS AND CONSULTANTS INDEPENDENT AUDITORS' REPORT ON COMPLIANCE WITH REQUIREMENTS APPLICABLE TO EACH MAJOR PROGRAM AND INTERNAL CONTROL OVER COMPLIANCE IN ACCORDANCE WITH OMB CIRCULAR A-133 AND ON THE SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS The Honorable Lorraine H. Morton, Mayor, and Members of the City Council City of Evanston, Illinois Compliance We have audited the compliance of the City of Evanston, Illinois, with the types of compliance requirements described in the U.S. Office of Management and Budget (OMB) Circular A-133, Compliance Supplement, that are applicable to each of its major federal programs for the year ended February 28, 2006. The City of Evanston, Illinois', major federal programs are identified in the summary of auditors' results section of the accompanying schedule of findings and questioned costs. Compliance with the requirements of laws, regulations, contracts, and grants applicable to each of its major federal programs is the responsibility of the City of Evanston, Illinois', management. Our responsibility is to express an opinion on the City of Evanston, Illinois', compliance based on our audit. We conducted our audit of compliance in accordance with auditing standards generally accepted in the United States of America; the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States; and OMB Circular A-133, Audits of States, Local Governments, and Non -Profit Organizations. Those standards and OMB Circular A-133 require that we plan and perform the audit to obtain reasonable assurance about whether noncompliance with the types of compliance requirements referred to above that could have a direct and material effect on a major federal program occurred. An audit includes examining, on a test basis, evidence about the City of Evanston, Illinois', compliance with those requirements and performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion. Our audit does not provide a legal determination on the City of Evanston, Illinois', compliance with those requirements. (Continued) -5- 650 DUNDEE ROAD, SUITE 250 • NORTHBROOK, IL 60062-2767 PHONE 847.205.5000 • FAX 847.205.1400 • e-mail mccltd@millercooper.com i 1 k- The Honorable Lorraine H. Morton, Mayor, and Members of the City Council e City of Evanston, Illinois (Continued) Compliance (Continued) As described in item 06-1 in the accompanying schedule of findings and questioned costs, the City of Evanston, Illinois, did not comply with requirements regarding all the compliance requirements that are applicable to the Community Development Block Grant Program. Compliance with such requirements is necessary, in our opinion, for the City of Evanston, Illinois, to comply with requirements applicable to that program. in our opinion, except for the noncompliance described in the preceding paragraph, the City of Evanston, Illinois, complied, in all material respects, with the requirements referred to above that are applicable to each of its major federal programs for the year ended February 28, 2006. Internal Control Over Comnliance The management of the City of Evanston, Illinois, is responsible for establishing and maintaining effective internal control over compliance with requirements of laws, regulations, contracts, and grants applicable to federal programs. In planning and performing our audit, we considered the City of Evanston, Illinois', internal control over compliance with requirements that could have a direct and material effect on a major federal program in order to determine our auditing procedures for the purpose of expressing our opinion on compliance and to test and report on internal control over compliance in accordance with OMB Circular A-133. Our consideration of the internal control over compliance would not necessarily disclose all matters in the internal control that might be material weaknesses. A material weakness is a reportable condition in which the design or operation of one or more of the internal control components does not reduce to a relatively low level the risk that noncompliance with the applicable requirements of laws, regulations, contracts, and grants caused by error or fraud that would be material in relation to a major federal program being audited may occur and not be detected within a timely period by employees in the normal course of performing their assigned functions. We noted no matters involving the internal control over compliance and its operation that we consider to be material weaknesses. (Continued) -6- MILLER COOPER & Co., LTD. The Honorable Lorraine H. Morton, Mayor, and Members of the City Council City of'Evanston, Illinois Schedule of Expenditure_ s of Federal Awards (Continued) We have audited the financial statements of the governmental activities, the business -type activities, each major fund, and aggregate remaining fund information of the City of Evanston, Illinois, as of and for the year ended February 28, 2006, and have issued our report thereon dated August 4, 2006. Our audit was performed for the purpose of forming an opinion on the basic financial statements taken as a whole. The accompanying schedule of expenditures of federal awards is presented for purposes of additional analysis as required by OMB Circular A-133 and is not a required part of the basic financial statements. Such information has been subjected to the auditing procedures applied in the audit of the basic financial statements and, in our opinion, is fairly stated, in all material respects, in relation to the basic financial statements taken as a whole. This report is intended solely for the information and use of the Mayor, City Council, management, federal awarding agencies, and pass -through entities and is not intended to be and should not be used by anyone other than those specified parties. MILLER, COOPER & CO., LTD. Certified Public Accountants Northbrook, Illinois August 4, 2006 -7- MILLER COOPER & Co., LTD. 7 City of Evanston, Illinois SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS For the vear ended February 28. 2006 Federal Grantor/ Federal Pass -Through Entity Pass -Through Grantor/ CFDA Identifying Federal Program Title i Number Number Expenditures Direct Programs - Grants DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT COMMUNITY PLANNING AND DEVELOPMENT Community Development Block Grant Entitlement year 22 14,218 B98-MC-17-0012 $ 12,859 Entitlement year 24 14.218 BOO-MC-17-0012 2,729 Entitlement year 27 14.218 BO1-MC-17-0013 30,849 Entitlement year 28 14.218 B02-MC-17-00I2 65,921 Entitlement year 29 14.218 B02-MC-17-0012 287,578 Entitlement year 30 14.218 B02-MC-17-0012 140,487 Entitlement year 31 14.218 B03-MC-17-0012 2,282,929 Total Community Development Block Grant 2,823,352 Emergency Shelter Block Grant 14.231 S03-MC-17-0012 1.517 14.231 SO4-MC-)7-0012 348 14.231 S05-MC-17-0012 93,506 Total Emergency Shelter Block Grant 95.371 Home Investment Partnership * HOME Program 14.239 S95-MC-170218 842 HOME Program 14.239 S97-MC-170218 5.000 HOME Program 14.239 S98-MC-170218 28.146 HOME Program 14.239 M02-MC-170218 406.384 HOME Program 14.239 M03-MC-170218 321.462 HOME Program 14.239 M04-MC-170218 46.323 Total HOME Program 808,157 Total Department of Housing and Urban Development 3,726,880 Denotes a Major Program (Continued) The accompanying notes are an integral part of this schedule. -8- MILLER COOPER & CO., LTD. City of Evanston, Illinois SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) For the vear ended February 28, 2006 Federal Grantor/ Federal Pass -Through Entity Pass -Through Grantor/ CFDA Identifying Federal Program Title Number Number Expenditures DEPARTMENT OF JUSTICE OFFICE OF COMMUNITY ORIENTED POLICING SERVICES Title V Delinquency Prevention 16.548 - $ 15,000 Law Enforcement Block Grant 16.592 2001-LB-BX-3274 3,478 Law Enforcement Block Grant 16.592 2002-LB-BX 20.152 Law Enforcement Block Grant 16.592 2003-LB-BX 12,000 Justice Assistant Grant 16.592 2205-DI-BX-1256 55,906 Total Department of Justice 106,536 Pass -Through Programs - Grants and Loans ENVIRONMENTAL PROTECTION AGENCY OFFICE OF WATER * Passed through the Illinois Environmental Protection Agency Water Pollution Control Revolving Loan 66.458 L17I452 10B 4,400,827 Water Pollution Control Revolving Loan 66,458 L170895 10A 1,047,170 Water Pollution Control Revolving Loan 66,458 L170894 9A 73,927 Total Environmental Protection Agency 5,521,924 FEDERAL EMERGENCY MANAGEMENT AGENCY STATE AND LOCAL PROGRAMS AND SUPPORT Passed through the Illinois Emergency Services and Disaster Agency Community Emergency Response Team 97.054 - 19,677 Emergency Management Assistance Program 83.517 497-58830-440 24,726 Total Federal Emergency Management Agency 44,403 DEPARTMENT OF AGRICULTURE Summer Lunch Program 10.559 14-016-51 OP-00 70,329 * Denotes a Major Program (Continued) The accompanying notes are an integral part of this schedule. -9- MILLER COOPER & CO., LTD. City of Evanston, Illinois SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) For the year ended February 28.2006 Federal Grantor/ Federal Pass -Through Entity Pass -Through Grantor/ CFDA Identifying Federal Program Title Number Number Expenditures DEPARTMENT OF HEALTH AND HUMAN SERVICES PUBLIC HEALTH SERVICE - I OFFICE OF HUMAN DEVELOPMENT SERVICES Passed through Suburban Area Agency on Aging Ombudsman (Older Americans Act Title III B) Special Programs for the Aging 93.633 OFFICE OF MENTAL HEALTH SERVICES Evanston Project - SEED * 98.230 Passed Through State of Illinois Department of Human Services Family Planning 93.217 Family Planning 93.667 Family Planning 93.994 Family Planning 93.217 Family Planning 93.667 Total Family Planning Total Public Health Service - I HEALTH CARE FINANCING ADMINISTRATION PUBLIC HEALTH SERVICE -11 Passed through State of Illinois Department of Human Services Teen Pregnancy Prevention 93.994 Teen Pregnancy Prevention 93.994 Total Teen Pregnancy Prevention * Denotes a Major Program The accompanying notes are an integral part of this schedule. -10- MILLER COOPER & Co., LTD. A13-119 $ 43,109 1 U79 SM53999-03 337,255 61 I G6095350 27,000 611 G6095 3 50 9,800 611G6095350 3,700 511G5095350 3,900 5 ] 1 G5095350 10,900 55,300 435,664 611 G6095230 23,400 5 ].1 G5095230 19,000 42,400 (Continued) City of Evanston, Illinois SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS (Continued) For the near ended February 28. 2006 Federal Grantor/ Pass -Through Grantor/ Program Title Federal Pass -Through Entity CFDA Identifying Federal Number Number Expenditures DEPARTMENT OF HEALTH AND HUMAN SERVICES (Continued) PUBLIC HEALTH SERVICE -II (Continued) Passed through State of Illinois Department of Public Health Oral Health Grant 93.994 33480526 Family Case Management Administration Reimbursement 93.778 - Total Public Health Service - I1 Total Department of Health and Human Services DEPARTMENT OF HOMELAND SECURITY 2,367 68,231 112,998 548,662 Assistance to Firefighters Grant Program * 97.044 EMW-2003-FG-04561 210,000 Total Federal Financial Assistance S 10,228,734 * Denotes a Major Program (Concluded) The accompanying notes are an integral part of this schedule. -11- MILLER COOPER & Co., LTD. City of Evanston, Illinois NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Year ended February 28. 2006 NOTE A - SCOPE OF REVIEW The City of Evanston, Illinois, (City) is a governmental entity established under Illinois State Statutes. The City has had a single audit performed for its fiscal year ended February 28, 2006, pursuant to the Single Audit Act of 1984, as amended. The Environmental Protection Agency has been designated as the City's oversight agency for this single audit. Programs Subject To Single Audit All federal financial awards have been included in the Schedule of Expenditures of Federal Awards. The City also receives grant awards solely funded by the state of Illinois or private sources. These funds are not included in the Schedule of Expenditures of Federal Awards. Pursuant to the Single Audit Act, a major federal program is one whereby the total expenditures are equal to the larger of (a) $300,000 or (b) 3% of the City's total federal program expenditures (less loans received). All programs for the City with expenditures greater than $300,000 were considered Type A programs. Total federal program expenditures (less loan received of $5,521,924) $ 4,706,810 3% of total federal program expenditures 141,204 Greater of above or $300,000 300,000 NOTE B - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Basis of Presentation The accompanying Schedule of Expenditures of Federal Awards has been prepared using the modified accrual basis of accounting. Revenue is recognized either when received or once reimbursable expenditures have been incurred. Expenditures are recognized when incurred. -12- MILLER COOPER & Co., LTD. City of Evanston, Illinois NOTES TO SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Year ended February 28. 2006 NOTE C - COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) ENTITLEMENT YEAR 30 'The CDBG Entitlement Year 31 receipts include $366,149 of program income generated through collection of prior years' loans. The balance of receipts are from letter of credit drawdowns. The CDBG expenditures for the year include expenditure of this program income. Program income is not included in the award amount. NOTE D - FEDERALLY PURCHASED COMMODITIES The City receives federally purchased vaccine passed through the Illinois Department of Public Health. The approximate cost of the vaccine provided to eligible patients is included in the Schedule of Expenditures of Federal Awards. For the state of Illinois fiscal year ended June 30, 2006, the Department advises that the cost of vaccine shipped to the City was $16,592. The vaccine was provided to eligible patients in the City's public health clinic. NOTE E - LOANS RECEIVABLE OUTSTANDING The City had the following loan receivable balances outstanding at February 28, 2006, Program Federal CFDA Number Amount Home Program 14.239 S 3.201.381 Community Development Block Grant 14.218 $ 1.473.105 -13- MILLER COOPER & Co., LTD. CITY OF EVANSTON, ILLINOIS Schedule of Insurance in Force March 1, 2006 Policy Policy Name of Company Number Dates FM Global FC359 3/01/06 - 3/01/07 Hartford Insurance Co. 83MSRZ3857 3/01/06 - 3/01/07 Safety National Casualty Corp. SP8724-IL 3/01/06 - 3/01/07 Western World Insurance NPP970824 3/01/06 - 3/01/07 Illinois National Insurance Co. 76062798 3/01/06 - 3/01/07 Lexington Insurance Co. 006260954 3/01/06 - 3/01/07 Type of Coverage Details All -Risk Property Actual cash value per Statement (includes business of Values each loss/each location interruption, loss of rents, and fine arts) in excess of $75,000 deductible Fine Arts - Noyes, Levy Per Statement of Values in excess Center, and of $250 deductible limits of Fleetwood/Jourdain different levels at each property Theaters Excess Worker's Specific excess coverage in excess Compensation of $50,000 per occurrence Ambulance/Paramedic $1,000,000 per occurrence; Liability $1,000,000 aggregate Excess Liability $10,000,000 coverage in excess of $2,000,000 per occurrence (first $2,000,000 is City's portion) Crime Policy Theft of cash in excess of $25,000 deductible, to I im it of $2,000,000 -14- City of Evanston, Illinois SCHEDULE OF FINDINGS AND QUESTIONED COSTS For the year ended February 28. 2006 I. SUMMARY OF -INDEPENDENT AUDITORS' RESULTS Financial Statements Type of auditors' report issued: Unqualified opinion on the basic financial statements of the City of Evanston. Illinois. None Internal control over financial reporting: Yes Reported Material weaknesses identified? X Reportable conditions identified that are not considered to be material weaknesses? X Noncompliance material to financial statements noted? X Federal Awards Internal control over major programs: Material weaknesses identified? X Reportable conditions identified that are not considered to be material weaknesses? x Type of auditors' report issued on compliance for major programs: Qualified Any audit findings disclosed that are required to be reported in accordance with section 510(a) of Circular A-133? X (Continued) on MILLER COOPER & CO., LTD. City of Evanston, Illinois SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) For the year ended February 28. 2006 1. SUMMARY OF INDEPENDENT AUDITORS' RESULTS (Continued) Identification of major programs: CFDA Number Name of Federal Program or Cluster 14.218 Connnunity Development Block Grants (CDBG) 14.239 Horne Investment Partnership (HOME) 66.458 Water Pollution Control Revolving Loan (EPA) 98.230 Evanston project - SEED 97.044 Assistance to Firefighters Grant Dollar threshold used to distinguish between type A and type B programs Auditee qualified as low -risk auditee? 11. FINANCIAL STATEMENT FINDINGS A. Reportable Conditions in Internal Control B. Compliance Findings m MILLER COOPER & Co., LTD. $ 300,000 No None Reported None Reported (Continued) City of Evanston, Illinois SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) For the vear ended Februarv_2_8. 2006 Ill. FINDINGS AND QUESTIONED COSTS FOR FEDERAL AWARDS Questioned Finding CFDA # Program Costs 06-1 14.218 Cormnunity Development Block Grant None Findinv-/Noncomp liance Wages should be monitored to insure that the provisions of the Davis -Bacon Act are met. The City could not locate support for two of the thirteen disbursements tested to show that Davis -Bacon Act monitoring took place and that the wage requirements were met. Subsequent testing determined that prevailing wage rates were met or exceeded in all instances tested. Support for the monitoring should be maintained for at least three years. The City should develop standard procedures for record retention that include the amount of time to keep the files (a minimum of three years) and what information should be maintained in those files. -17- i MILLER COOPER & Co., LTD. City of Evanston, Illinois SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS For the year ended February 28.2006 Identifyine Number: 05-1 Audit Findine: Wages should be monitored to insure that the provisions of the Davis -Bacon Act are met. The City could not locate support for two of the seven disbursements tested to show that Davis -Bacon Act monitoring took place and that the wage requirements were met. Subsequent testing determined that prevailing wage rates were met or exceeded in all instances tested. Support for the monitoring should be maintained for at least three years. The City should develop standard procedures for record retention that include the amount of time to keep the files (a minimum of three years) and what information should be maintained in those files. Corrective Action Taken: The City had the same finding occur in the previous year and the plan was to apply the Davis -Bacon Act to all types of contracts. However, due to a change in key personnel, there was a deficiency in' the records retention and/or monitoring process (see finding 06-1). The City recognizes the lack of testing and is planning to monitor all of the contracts more closely to assure that the Davis -Bacon Act is applied to all contracts. Identifyina Number: 05-2 Audit Finding-: Records should be maintained that support the determination of eligibility for the Medical Assistance Program based upon eligibility criteria specified in the individual state plan. The City did not maintain a record of the eligible participants provided by the state of Illinois. This lack of records prohibited us from testing the eligibility of the participants in the program. The lack of support makes it possible the ineligible participants were served by the program. The City should develop formal procedures for record retention (a minimum of three years) and what information should be included in the files to support eligibility for the participants. Corrective Action Taken: The City now maintains records. -18- ZIIILLER COOPER & Co., LTD. City of Evanston, Illinois SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS For the vear ended February 28. 2006 Identifying Number: 05-3 Audit Finding: Records should be maintained that support the determination of which participants in the Medical Assistance Program received services. The City did not maintain records supporting who participated in the program. This lack of records prohibited us from testing the case files to determine that they were in compliance with the requirements of the Medical Assistance Program. The lack of support for participation makes it impossible to verify that services were provided to the proper individuals. The City should develop formal procedures for record retention (a minimum of three years) and for what information should be included in the files. Corrective Action Taken: The City now maintains records. Identifying Number: 05-4 Audit Finding_: Records should be developed and maintained that support the expenditures of Medical Assistance Program funds. The City did not develop or maintain records that support expenditures charged to the Medical Assistance Program. The lack of support prohibited us from testing that the expenditures were allowable and in accordance with the pennitted activities. The lack of support makes it possible that nonallowed and/or nonpermitted expenditures were charged to the program. The City should develop minimum standards for support of expenditures charged to a specific program. Corrective Action Taken: The City now maintains records. I Us ]MILLER COOPER & CO., LTD. City of Evanston, Illinois CORRECTIVE ACTION PLAN Year ended February 28, 2006 ldentifvin� Number: 06-1 Audit FindinP,: The City did not apply the Davis -Bacon Act to the two items selected for testing which required the Davis -Bacon Act. Corrective Action Taken: After last year's finding, the City put procedures in place to ensure that the City is in compliance with the Davis -Bacon Act. The contractors for the two items selected for review in this year's audit stated that copies of certified timesheets and worker compensation were provided to the City as required; however, those documents could not be located in the City's files when requested by the auditor. The City believes that the documents were received and reviewed for compliance, but is unable to verify this as the staff person who created and implemented the procedure is no longer employed by the City of Evanston. Duplicate copies of the timesheets were obtained from the contractors for both items in question and were found to be in compliance with the appropriate wage decisions. The City Finance staff has discussed the importance of reviewing timesheets and retaining the required documentation as well as any documents of findings and corrective action required with the new CDBG Grants Administrator. The CDBG Grants Administrator has established written procedures that identify the individual responsible for ensuring tracking that the requirements of the Davis -Bacon Act are satisfied by project and has established a new tracking system to document the process. These procedures will be incorporated in the CDBG Grants Administration Procedure Manual to ensure continuity of Davis -Bacon compliance processes and provide transparency in the event of future staffing changes. -20- E; MILLER COOPER & Co., LTD.