CITY OF ROANOKE MUNICIPAL AUDITING REPORT - Solid Waste Management Early Release Time

 
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CITY OF ROANOKE MUNICIPAL AUDITING REPORT - Solid Waste Management Early Release Time
MUNICIPAL AUDITING REPORT
  CITY OF ROANOKE

  Solid Waste Management
     Early Release Time
           May 13, 2021

      Report Number: 21-009
     Audit Plan Number: 21-307

     Municipal Auditing Department
             Chartered 1974

          www.roanokeva.gov/auditing
            Phone 540.853.5235
TABLE OF CONTENTS

Summary of Complaint ...................................................................................... 1

Investigation Objectives & Conclusions ............................................................ 1

Background ....................................................................................................... 2

Objective 1 – SWM Time Review ...................................................................... 5

Management Comments ................................................................................... 16

Acknowledgments ............................................................................................ 16

Exhibit 1 – Complaint Summary & Disposition

Exhibit 2 – Memorandum from Management Dated April 2, 2021
May 13, 2021                                                                     Report # 21-009

                                 SUMMARY OF COMPLAINT

The complaints allege that Solid Waste Management (SWM) employees routinely complete their
routes early and are paid for hours not worked (i.e., early release time), while also being paid
overtime for all hours worked to clear roads during snow events.

                      INVESTIGATION OBJECTIVES & CONCLUSIONS

1. Are Solid Waste Management employees regularly paid for hours not worked?

   Yes – We identified a notable increase in early release time since early 2020. Early
   Release Time (ERT) increased from an average of 6.82 hours per employee per month in
   2019 to 23.48 hours per employee per month in 2020. ERT continued to trend high in the
   first two (2) months of 2021, averaging 25.47 hours per employee per month.

   Management Comments: The increase in early release time in 2020 was primarily due to
   the COVID-19 Pandemic and the need for employees to leave the Public Works Service
   Center after completing the assigned daily tasks. This action reduced the number of
   employees congregating at the end of the service day. This was in accordance with
   guidelines from the CDC on reducing the number of people congregating.

2. Are early release hours counted toward the 40 hour threshold when computing overtime pay
   for Solid Waste Management employees?

   Yes – Employees can be paid for early release hours and overtime hours in the same work
   week. Early release hours are credited each day and are not netted against extra hours
   worked other days of the work week. Additionally, when solid waste services are
   suspended for snow and Solid Waste employees are needed for snow plow operations, they
   are given early release hours for their full shift and additional pay for the time spent
   operating the snow plows. Snow plows are operated in 12 hour shifts: day shift is paid
   150% of the employee’s hourly rate; night shift is paid at 200% of the normal hourly rate.

   Management Comments: Employees do not earn early release hours. Coding time as
   Early Release is the method by which early release meets the requirements for payroll time
   entry to account for hours within the pay cycle and for tracking early release time. All snow
   operations personnel are paid time and a half during the 12 hour day shift during snow
   operations and double time during the 12 hour night shift. This includes employees from
   Public Works, Parks and Recreation, and General Services. It should be noted that in Public
   Works and the other departments that assist with snow operations, when employees are
   sent home during the day to return to work the night shift, their time for the remainder of the
   work day is not adjusted. That is the operational aspect of snow operations and deployment
   of resources.
                              End of Objectives & Conclusions

                                             Page 1
May 13, 2021                                                                      Report # 21-009

                                         BACKGROUND

The Solid Waste Division currently provides weekly curbside and alley collection of refuse, bulk
and brush, and every other week recycling to City residents and small businesses. Weekly
waste collection services are provided to approximately 42,000 households, and are generally
limited to detached, single-family homes and townhomes living in four units or less.

Approximately 3,500 residents and employers utilize five (5) City-owned sealed compactors
located in the Downtown Business District. Residents and businesses within each compactor
zone are responsible for transporting trash and recyclable material to the compactors. A third
party vendor collects the trash and the City’s Solid Waste Management employees collect the
recycling several times a day including evenings, holidays, and weekends. Overtime is used for
Saturday morning, Saturday night, and Sunday morning solid waste collection.

The City also collects leaves during four (4) weeks each year beginning in November. Brush
collection continues during these weeks, as normal.

Solid Waste Management assists elderly and handicapped residents who are unable to move
their trash receptacles to the curb or alley. Assistance is also provided to residents who have
topographical issues that create an undue hardship. There are currently just over 1,000
addresses designated as physically or topographically challenged.

Per management, there are established routes each day. Each scheduled collection day is
different with respect to the number of automated routes and semi-automated routes. As
automated and semi-automated routes are completed, resources are assigned to help on other
routes, if needed. Front-line collection staff return to the Public Works Service Center after
completing their assigned collection work for the day. After returning to the Public Works
Service Center, crews complete post trip work that includes disinfecting vehicles and cleaning
residual trash that accumulates in certain compartments of the body of their vehicles.

Solid Waste Management operates on a modified task system. Given that collection is divided
into four geographic areas with each having a designated collection day, there is no additional
work until the next collection day. There are a number of factors which impact the amount of
time required to complete daily collection activities. The factors include the size of each route,
the number of cans set out, the volume of bulk and brush items, the availability of equipment
(equipment downtime), the time of year (seasonality), and the level of paid leave being taken.

Solid Waste Management Staffing

City budgets for fiscal years 2012 through 2021 report that Solid Waste Management has
budgeted 57 positions annually for the last nine years. The adopted budget offers for FY21
included the following allocation of full time equivalent employees for solid waste services:

                                              Page 2
May 13, 2021                                                                                       Report # 21-009

            Service                    Supv   Driver   Worker  Manager AdmAsst AcctTech
    Brush                                 .20     4.00    0.00
    Bulk                                  .30     4.50    2.90
    Cent Business Dist                    .20     1.00    0.00
    Physically Challenged                 .20     1.50    1.00
    Recycle                               .50     5.50    5.10     .50     .50      .50
    Trash Collection                     1.00    14.50    4.00     .50     .50      .50
            Totals:                     2.40*    31.00   13.00    1.00    1.00     1.00

* Other services were allocated the remaining portion of the third supervisor position; they were:

-     Inspectors (4 FTE)
-     Container Distribution (1 FTE)
-     Call Center (2 FTE)

Solid Waste Management’s budget proposals for fiscal 2022 included 57 positions as of April 8,
2021.

The City’s financial system reports the following expenditures for Solid Waste Management:

                                            Solid Waste Expenditures
                                               Sanitation & Waste
    7,000,000

    6,000,000

    5,000,000                                                                 3,230,334
                                                    2,851,580
                        2,584,758
    4,000,000
                                                                                                    2,052,472
    3,000,000

    2,000,000
                        2,872,681                   2,927,452                 2,962,997
    1,000,000                                                                                       2,166,282

           ‐
                            FY17‐18                  FY18‐19                   FY19‐20              FY20‐21*

                Personnel         Operating Exp        Internal Services (Risk Management)   Other Operating Exp

          * As reported thru March 31, 2021 (75% of fiscal year 2021)

                                                            Page 3
May 13, 2021                                                                     Report # 21-009

Solid Waste Management
operates all field staff on four (4)                Solid Waste Overtime Wages
10 hour days, covering 122             $140,000                  $124,495
planned routes Monday through          $120,000
                                                     $93,443                $96,448
Thursday. When the City closes         $100,000
for holidays falling on Mondays,        $80,000
                                                                                         $55,087
employees are paid 10 hours for         $60,000
the holiday and collections are         $40,000
shifted to Tuesday through              $20,000
Friday. The following Monday,                $‐
                                                     FY17‐18      FY18‐19   FY19‐20     FY20‐21*
Solid Waste reverts back to the
regular schedule. Based on the City’s defined work week running Tuesday through Monday,
this results in five (5) 10 hour work days falling within the work week and solid waste employees
earning overtime on the final day (Monday). Unplanned overtime can occur when bulk and
brush volumes increase following floods and other natural disasters, due to equipment failure,
and when supporting special events.

Management noted that Solid Waste Management employees receiving early release time are
full-time, FLSA non-exempt employees, and that management does not have the ability to
adjust their salaries for early release.

                                      End of Background

                                             Page 4
May 13, 2021                                                                    Report # 21-009

                               Objective 1: SWM Time Review

OBJECTIVES:

Are Solid Waste Management employees regularly paid for hours not worked?

Yes

Are early release hours counted toward the 40 hour threshold when computing overtime pay for
Solid Waste Management employees?

Yes

SCOPE:

We reviewed time and attendance data in the NovaTime system, and corresponding payroll
data in the Lawson system from January 1, 2019 through March 8, 2021, for Solid Waste
Management employees.

We interviewed the person who enters early release time and other edits into the NovaTime
system for the Solid Waste Management division. There were no written policies or procedures
addressing the use of early release time or other aspects of managing day-to-day staffing levels
within the parameters of management’s daily staffing needs chart (See Exhibit 2 for Chart).

                                            Page 5
May 13, 2021                                                                                                         Report # 21-009

RESULTS:

Early Release Time (ERT)

The raw data in the NovaTime system indicates a considerable increase in early release time
began in March 2020:

                                      SWM Early Release Hours ‐ 2019
 500
 450          462                                                                            438
                                                                                                      432
 400
                          371                                              367
 350                                                                                                                    344
                                                         298                        322
 300                                                                                                           298
                                                                  275
 250
 200
                                      178
 150                                           143
 100
  50
   0
            Jan      Feb        Mar          Apr     May        Jun     July     Aug      Sept      Oct     Nov      Dec
           2019     2019        2019        2019     2019      2019     2019     2019     2019     2019     2019     2019

                                       SWM Early Release Hours ‐ 2020
 7,000

 6,000                                                                                                                      5,570
                                                     5,741              5,384
                                                                                 5,421             5,084
 5,000                                                        5,017                                                  4,837
                                                                                          4,468             4,790
 4,000

 3,000

 2,000

 1,000                                   1,243
                    357
       ‐                         13
              Jan      Feb        Mar          Apr     May        Jun     July     Aug      Sept      Oct     Nov      Dec
             2020     2020        2020        2020     2020      2020     2020     2020     2020     2020     2020     2020

Upon closer review of the data, we discovered that edits of clock in times using the ERT reason
code erroneously marked actual hours worked as being early release time. We also noted
instances in which employees clocked in and out using the ERT code.

                                                                      Page 6
May 13, 2021                                                                    Report # 21-009

We removed the following early release hours from the NovaTime data to more accurately
reflect actual ERT:

2020 Invalid Entries

      Hours recorded for seven (7) employees on four (4) dates in January 2020 as 100%
       ERT hours

      Hours recorded as ERT starting at 6:23 AM paired with a clock out time between 1:01 to
       6:08 PM

      All ERT hours recorded from 9/29/20 – 10/2/20 and from 10/5/20 – 10/6/20 when
       employees were not allowed to enter the building to clock in/out due to COVID-19 cases.
       The Administrative Assistant manually entered 10 hours each day for each employee, all
       coded as early release time

      Hours recorded as ERT for the two (2) Customer Service Specialists throughout the
       year; incorrectly coded as early release

      Hours marked as ERT in NovaTime which were paid as Leave or Holiday Taken time for
       eight (8) different employees on various dates throughout the year

      Hours marked as ERT for six (6) employees who reported to work for one (1) to three (3)
       hours before clocking out for the day due to illness or other events for which they
       reported paid leave.

2021 Invalid Entries

      Hours recorded as ERT which were actually Temporary Employee pay or COVID pay for
       two (2) different employees on 1/6/21 and 2/23/21

      Hours recorded as ERT starting at 6:00 AM paired with clock out times between 2:55 to
       5:02 PM

      Hours recorded as ERT for the 8 hour / day Customer Service Specialist

The following chart shows the magnitude of our adjustments to the NovaTime data to more
correctly report ERT:

                                           Page 7
May 13, 2021                                                                                                           Report # 21-009

                                 Early Release Hours ‐ Raw vs Adjusted Data
                                       January 1, 2019 ‐March 8, 2021
 55,000
                                                                47,923
 45,000

 35,000

 25,000

 15,000                                                                       13,245

                         3,927      3,927                                                                 5,461
  5,000                                                                                                                2,705

  (5,000)                    2019                                       2020                                    2021 *

                                                       Raw Data        Adjusted Data

The revised 2020 monthly fluctuations are illustrated on the following chart:

                                               2020 Early Release Time
 2,000
 1,800
                                                   1,719                        1,717
 1,600
                                                                      1,462                                                    1,497
 1,400
                                                       1,396                              1,231
 1,200                                                                                                       1,077
 1,000                                                                                                                 947
                                                                                                  1,108
   800                                   787
   600
   400
                   293
   200
      ‐                     13
             Jan      Feb         Mar        Apr      May       Jun      July      Aug       Sept      Oct      Nov      Dec
            2020     2020         2020      2020      2020     2020      2020      2020      2020     2020      2020     2020

ERT increased from an average of 6.82 hours per employee per month in 2019 to 23.48 hours
per employee per month in 2020. ERT continued to trend high in the first two (2) months of
2021, averaging 25.47 hours per employee per month.

                                                                 Page 8
May 13, 2021                                                                        Report # 21-009

The majority of Solid Waste Management employees (46 of 51) were credited more than 300
early release hours in 2020; four (4) were credited more than 400 hours for the year. In 2019,
no employee was credited more than 113 hours of early release time for the year.

Based on the average ($30,919) and median salary ($31,251) of the 53 employees who were
paid ERT in calendar 2020, we estimate ERT costs were between $196,888 and $199,000. The
increase in ERT cost from CY19 to CY20 was approximately $138,000.

Analysis of ERT hours by job title shows the largest accumulation of hours by SWM Equipment
Operators:

                                Early Release Time by Job Title
                                         1/1/19 - 3/8/21
                                    659.50
                                             280.25

                                               5,166.75            Collection Inspector
                                                                   Container Distributor
                                                                   Sanitation Worker

                    13,672.50                                      SWM Equipment Operator

** Hours for the 2 Customer Service Specialists were not included in the above chart, as they
were minimal  98 hours for both employees combined during the period.

We noted the following new hire and termination activity in the Solid Waste division:

                                  New Hires     Terminations
                       2019          15              18
                       2020          7               3
                       2021          1               1

The last equipment operator was hired 3/24/20; no additional employees have been hired since
February 9, 2021.

                                                 Page 9
May 13, 2021                                                                   Report # 21-009

Correlation Between Paid Leave and Early Release Time

Management indicated the use of employee paid leave hours substantially dropped during
2020. Our analysis of paid leave data shows the two months with the largest declines (April and
July) experienced the highest ERT hours:

                                    LEAVE HOURS (ALL TYPES)
                2019        2020       Change       %          2021       Change         %
  January       1907.00     1745.75     (161.25)   ‐8.46%      1979.25        72.25      3.79%
  February      1682.25     1407.00     (275.25)  ‐16.36%      1501.50     (180.75)    ‐10.74%
  March         1257.25     1047.50     (209.75)  ‐16.68%            ‐            ‐          ‐
  April         1852.25      609.00 (1,243.25)    ‐67.12%            ‐            ‐          ‐
  May           1838.00     1007.25     (830.75)  ‐45.20%            ‐            ‐          ‐
  June          1397.00      882.75     (514.25)  ‐36.81%            ‐            ‐          ‐
  July          1791.00      958.75     (832.25)  ‐46.47%            ‐            ‐          ‐
  August        1579.75     1075.25     (504.50)  ‐31.94%            ‐            ‐          ‐
  September     1677.75     1561.25     (116.50)   ‐6.94%            ‐            ‐          ‐
  October        917.50     1569.50       652.00   71.06%            ‐            ‐          ‐
  November      1254.25     1518.25       264.00   21.05%            ‐            ‐          ‐
  December      1722.00     1388.75     (333.25)  ‐19.35%            ‐            ‐          ‐
                                      (4,105.00)                           (108.50)

                                 EARLY RELEASE TIME HOURS
                 2019       2020    Change        %       2021            Change        %
  January        461.75      293.25    (168.50)     ‐36.49%   1,129.00      667.25     144.50%
  February       370.75       12.75    (358.00)     ‐96.56%   1,136.25      765.50     206.47%
  March          178.25      787.25      609.00     341.65%          ‐             ‐         ‐
  April          143.25    1,718.50    1,575.25    1099.65%          ‐             ‐         ‐
  May            297.50    1,396.00    1,098.50     369.24%          ‐             ‐         ‐
  June           274.75    1,461.75    1,187.00     432.03%          ‐             ‐         ‐
  July           366.75    1,716.75    1,350.00     368.10%          ‐             ‐         ‐
  August         322.25    1,231.25      909.00     282.08%          ‐             ‐         ‐
  September      438.00    1,107.75      669.75     152.91%          ‐             ‐         ‐
  October        431.75    1,076.50      644.75     149.33%          ‐             ‐         ‐
  November       297.75      946.75      649.00     217.97%          ‐             ‐         ‐
  December       344.00    1,496.50    1,152.50     335.03%          ‐             ‐         ‐
                                       9,318.25                           1,432.75

                                           Page 10
May 13, 2021                                                                     Report # 21-009

The following graph shows the direct correlation between leave time and early release time
each month during the review period:

                                   Leave Hours vs ERT Hours
                   ‐   200   400     600     800     1,000   1,200   1,400   1,600   1,800   2,000

   January 2019

  February 2019

    March 2019

      April 2019

      May 2019

      June 2019

       July 2019

    August 2019

 September 2019

   October 2019

 November 2019

 December 2019

   January 2020

  February 2020

    March 2020

      April 2020

      May 2020

      June 2020

       July 2020

    August 2020

 September 2020

   October 2020

 November 2020

 December 2020

   January 2021

  February 2021

                                       Leave Hours   ERT Hours

                                           Page 11
May 13, 2021                                                                    Report # 21-009

Sick and Extended Illness leave accounts for a substantial proportion of overall leave that was
used by employees beginning in September 2020. Per Management, Solid Waste began
experiencing an increase in employees that were COVID positive and / or had to be quarantined
due to exposure to someone who was COVID positive:

                    2019       2020      Change          %        2021     Change       %
     January        341.25     260.00     (81.25)      ‐23.81%    768.75    427.50   125.27%
     February       292.50     342.75       50.25       17.18%    701.75    409.25   139.91%
     March          185.50     282.00       96.50       52.02%         ‐         ‐         ‐
     April          480.50     207.00    (273.50)      ‐56.92%         ‐         ‐         ‐
     May            147.00     120.00     (27.00)      ‐18.37%         ‐         ‐         ‐
     June           196.50     175.25     (21.25)      ‐10.81%         ‐         ‐         ‐
     July           534.25     244.50    (289.75)      ‐54.23%         ‐         ‐         ‐
     August         757.00     319.75    (437.25)      ‐57.76%         ‐         ‐         ‐
     September      570.50     679.00      108.50       19.02%         ‐         ‐         ‐
     October        241.50     968.00      726.50      300.83%         ‐         ‐         ‐
     November       107.50     402.75      295.25      274.65%         ‐         ‐         ‐
     December       564.25     630.75       66.50       11.79%         ‐         ‐         ‐

                         Sick and Extended Illness Leave by Month
                                     1/1/19 ‐ 2/28/21
        1200
        1000
         800
         600
         400
         200
           0

                                          2019      2020   2021

                                           Page 12
May 13, 2021                                                                    Report # 21-009

Absent without pay (AWOP) and Disciplinary Hours in 2019 were notably higher than in 2020:

                  2019        2020      Change            %      2021     Change        %
  January          117.00      92.50      (24.50)      ‐20.94%   131.50      14.50    12.39%
  February         462.50      17.75     (444.75)      ‐96.16%    10.00   (452.50)   ‐97.84%
  March            474.00      10.00     (464.00)      ‐97.89%        ‐          ‐         ‐
  April            523.00      20.00     (503.00)      ‐96.18%        ‐          ‐         ‐
  May              376.00      23.25     (352.75)      ‐93.82%        ‐          ‐         ‐
  June             360.00      49.25     (310.75)      ‐86.32%        ‐          ‐         ‐
  July              60.25      70.00         9.75       16.18%        ‐          ‐         ‐
  August           191.00      67.25     (123.75)      ‐64.79%        ‐          ‐         ‐
  September         78.00      91.75        13.75       17.63%        ‐          ‐         ‐
  October          100.00      10.00      (90.00)      ‐90.00%        ‐          ‐         ‐
  November          10.00      12.25         2.25       22.50%        ‐          ‐         ‐
  December          95.50       2.25      (93.25)      ‐97.64%        ‐          ‐         ‐

                             AWOP and Disciplinary Hours
                                 1/1/19 ‐ 2/28/21
     600

     500

     400

     300

     200

     100

      0

                                       2019     2020    2021

We confirmed that employees used 4,105 hours less leave time in CY20 compared to CY19, a
nearly 22% reduction. SWM has no formal workforce management plan that addresses daily
staffing requirements, leave management, and utilization of early release hours to address
unusual fluctuations in service demands.

MANAGEMENT COMMENTS: Early release time is reported up the chain of command to the
Director of General Services and Deputy City Manager. Prior to the COVID-19 Pandemic, front-
line collection staff would be released as a group after all scheduled routes had been completed

                                              Page 13
May 13, 2021                                                                               Report # 21-009

for the day. This practice was changed during the Pandemic, with front-line collection staff
released on an individual basis after completing assigned work for the day. This change in
practice mitigates the total number of people congregating in the Public Works Assembly Room
waiting to be released as a group. Mitigating the number of people who congregate in a given
area has been identified as a best practice during the COVID-19 Pandemic. This change in
practice, coupled with the reduced leave taken by employees due to travel restrictions during
the Pandemic, are largely responsible for the increases experienced in early release time during
2020 and 2021.

Overtime and Early Release Time

As reported in the NovaTime system, adjusted for ERT coding errors:

                                         OT vs ERT Hours
                                         1/1/19 ‐ 2/28/21
 14,000                                                   13,245

 12,000
 10,000
  8,000
  6,000          5,052
                            3,927
  4,000                                         3,244
                                                                                       2,265
                                                                               1,453
  2,000
     ‐
                     2019                             2020                         2021*

                                           OT Hrs     ERT Hours

                                         OT Hours
                2019           2020      Change            %        2021         Change           %
January        1,057.50         718.00     (339.50)       ‐32.10%    548.50       (509.00)       ‐48.13%
February         477.00         513.00       36.00          7.55%    904.25        427.25         89.57%
March            218.50         139.75      (78.75)       ‐36.04%          ‐             ‐             ‐
April            283.50          72.00     (211.50)       ‐74.60%          ‐             ‐             ‐
May              180.75          71.00     (109.75)       ‐60.72%          ‐             ‐             ‐
June             421.25         391.25      (30.00)        ‐7.12%          ‐             ‐             ‐
July             512.25          78.00     (434.25)       ‐84.77%          ‐             ‐             ‐
August           239.25         129.25     (110.00)       ‐45.98%          ‐             ‐             ‐
September        502.00         463.00      (39.00)        ‐7.77%          ‐             ‐             ‐
October          344.00          89.50     (254.50)       ‐73.98%          ‐             ‐             ‐
November         206.50         300.75       94.25         45.64%          ‐             ‐             ‐
December         609.00         278.50     (330.50)       ‐54.27%          ‐             ‐             ‐
                                         (1,807.50)

                                                Page 14
May 13, 2021                                                                       Report # 21-009

Employees can be credited early release hours and overtime hours in the same work week.
The City’s defined work week for wage and hour calculations runs Tuesday through Monday.
Solid Waste Management typically works 10 hour days, Monday through Thursday, with Fridays
off. When a holiday falls on Monday, solid waste employees work Tuesday through Friday of
that week, then resume Monday routes the following week. This results in five (5) work days
falling within the wage and hour work week. By entering early release time daily to bring
employees up to 10 hours, the system treats any hours clocked the following Monday as
overtime. As a result, the City pays more overtime than required by city policy and federal
regulations.

We also looked at a sample of 14 employees who were credited with early release time and
overtime in the same pay period when a holiday was not involved. As we noted previously,
early release time is credited daily to bring employees up to 10 hours. If an employee works
more than 10 hours on a given day, no adjustment is made to reduce ERT on other days. As a
result, the City essentially pays overtime on a daily basis rather than the normal weekly basis
applied to other city employees. However, this infrequently occurs given the excess capacity in
solid waste operations.

When Solid Waste employees are needed for snow plow operations, they are given credit for
working their full shift when solid waste services are suspended. Snow plows are operated in
12 hour shifts: day shift is paid 150% of the employee’s hourly rate; night shift is paid at 200% of
the normal hourly rate.

City Management provided a response to the allegations in advance of our investigation, which
we have included as Exhibit 2. Our office will perform a follow up audit at the appropriate time,
once management’s planned actions are completed.

                                       End of Objective 1

                                             Page 15
May 13, 2021                                                                    Report # 21-009

                                 MANAGEMENT COMMENTS

City Management/Administration provided a response to the allegations, via memorandum
dated April 2, 2021 (attached), in advance of the investigation. Early release has been an
operational practice of the Solid Waste Management Division, in various forms, for at least 40
years. Prior to the COVID-19 Pandemic, front-line collection staff would be released as a group
after all scheduled routes had been completed for the day. This practice was changed during
the Pandemic, with front-line collection staff released on an individual basis after completing
assigned work for the day. This change in practice mitigated the total number of people
congregating in the Public Works Assembly Room waiting to be released as a group. Mitigating
the number of people who congregate in a given area was a best practice during the COVID-19
Pandemic. This, along with a decline in paid leave usage during the COVID-19 Pandemic,
resulted in an increase in early release time. Solid Waste Management will develop procedures
for the coding of early release time. Solid Waste Management recently solicited proposals for
a route optimization study. This study will develop recommendations on collection routes and
facilitate the development of a revised staffing model, including establishing standards of cover
to provide a staffing buffer for paid leave and other factors. As front-line collection positions
turnover, vacancies are not being filled.

                                   ACKNOWLEDGEMENTS

We would like to thank the Solid Waste Management Division, specifically, James Hurt, Solid
Waste Management Administrative Assistant II, for his cooperation and assistance throughout
the Investigation. We would also like to thank Jody Lawson, Payroll and Systems Supervisor,
and Suzanne Barnett, Payroll Accountant, for their assistance with the NovaTime data.

  Drew Harmon, CPA, CIA                 Cari Spichek, CIA
  Municipal Auditor                     Senior Auditor

                                            Page 16
EXHIBIT 1 – Complaint Summary & Disposition

 Complaint                        Disposition         Notes
 Solid Waste employees            Substantiated       Once routes are completed each day, the majority
 regularly finish routes early,                       of Solid Waste Management employees are
 and therefore routinely work                         released with clock-out time through 5:00 PM
 30 hours a week but are                              credited as early release time (ERT). Time
 being paid for 40 hours.                             records show an increase in ERT for Solid Waste
                                                      Management employees from an average of 6.82
                                                      hours per employee per month in 2019 to 23.48
                                                      hours per employee per month in 2020. ERT
                                                      continued to trend high in the first two (2) months
                                                      of 2021, averaging 25.47 hours per employee per
                                                      month.
 Solid Waste employees were       Substantiated       Employees can earn early release hours and
 paid overtime when it                                overtime hours in the same work week. When
 snowed but did not work                              Solid Waste employees are needed for snow plow
 more than 40 hours per                               operations, they are given credit for working their
 week.                                                full shift when solid waste services are suspended.
                                                      Snow plows are operated in 12 hour shifts: day
                                                      shift is paid 150% of the employee’s hourly rate;
                                                      night shift is paid at 200% of the normal hourly
                                                      rate.

Definitions:

 Unsubstantiated     -   Allegations not supported by the evidence
 Substantiated       -   Allegations supported by the evidence
 Inconclusive        -   Evidence inadequate to make a determination
 Not Evaluated       -   Allegation presents no risk to the city and was not investigated
 Referred            -   Allegation was referred to another department or agency for investigation
EXHIBIT 2 - Management Response
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