OIG No. 25-01 Insurance Compliance Controls in BTR Renewals"I B
»70RG
Joseph M.Centorino,Inspector General
TO:Honorable Mayor and Members of the City Commission
FROM:Joseph M.Centorino,Inspector General
DATE:February 5,2025
PROJECT:Insurance Compliance Controls in BTR Renewals
OIG No.25-01
The City of Miami Beach Office of the Inspector General (OIG),in conjunction with the Finance
Department and the Risk Management Division,seeks to establish a procedure which ensures
that the Risk Management Division thoroughly reviews all contractors requiring insurance for
compliance before approving the renewal of a Business Tax Receipt (BTR).
INSURANCE REQUIREMENT FOR A ROLL-OFF COMPANY
Section90-196 (a):Each private waste contractor must maintain throughout the entire effective
period and/or term of its business tax receipt and/or franchise agreement,whichever term is
longer,the following required insurance coverage:
(1)Commercial general liability,in the amount of$1,000,000.00 per occurrence for bodily injury
and property damage.This policy must include coverage for contractual liability and specifically
re-state the indemnity agreement set forth in section 90-195.The city must be named as an
additional insured on this policy.
(2)Automobile liability,in the amount of $1,000,000,00 per occurrence for bodily injury and
property damage,covering all vehicles owned,leased,or used by the contractor within the limits
of the city.The city must be named as an additional insured on this policy.
(3)Workers'compensation and employer's liability,as required by state law.
During a sanitation fee Roll-Off audit,OIG auditors detected that several Roll-Off companies held
active Business Tax Receipts (BTRs),but were not meeting the insurance requirements specified
in City Code Section 90-196.In response,the OIG promptly contacted Risk Management,
Customer Service Directors,the Assistant City Manager,and the Chief Financial Officer to review
and clarify the BTR application and renewal process.
Manny Marquez,Assistant Finance Director,confirmed that there is an established process to
review the insurance requirements during the initial application for a BTR.However,the renewal
process does not currently include a step for Risk Management to verify that contractors maintain
a policy that meets the City's minimum insurance requirements before the BTR is renewed.
Initially,this issue was thought to be limited to the Sanitation Department.However,it was later
identified as a citywide problem affecting not only Roll-Off companies but also other types of
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contractors.For example,in 2024,Customer Services provided a list indicating 189 cases
involving various businesses,including charter boats,bicycle rentals and repairs,motor scooter
rentals,tour operators,transportation services,valet parking,and others,where contractors did
not have a direct agreement with the City.
OIG auditors contacted the Information Technology Department,specifically an Energov
specialist,to inquire whether the system could allow contractors to upload their Certificates of
Insurance (COis)during the renewal process.The specialist confirmed that this feature is
available.
RECOMMENDATIONS:
1.The Office of Inspector General (OIG)recommends establishing a procedure to place a
hold on all BTR renewals requiring insurance verification unless proper insurance
coverage is confirmed.
2.Customer Services in the Finance Department should notify applicable businesses to
provide a COi during the renewal process.
3.Risk Management should promptly download the COi,review it for compliance with
requirements,and,if compliant,approve and release the hold on the application.
4.Once the hold is released,businesses should be notified that they have met the insurance
requirements,enabling them to pay and renew their BTRs.
5.The OIG also recommends that the City Administration ensure that sufficient staff is
available to the Risk Management Department to manage this process effectively.
EFFECT:
Failing to have a procedure that ensures that the Risk Management Division thoroughly reviews
contractor insurance compliance before approving the renewal of a BTR can lead to increased
exposure to liability and financial loss,as uninsured contractors may cause accidents or damage
for which the City of Miami Beach could be held responsible.Additionally,improper insurance
verification oversight compromises the city's ability to safeguard taxpayer funds,maintain
operational integrity,and ensure that contractors meet legal and safety standards.
MANAGEMENT RESPONSE:
As discussed in our meeting with the Inspector General's Office,Risk Management (Risk),and
the Finance Department Business Tax Section,with the assistance of the Information Technology
Department,this July 2025,we will be implementing the following automated process for
businesses deemed needing RM [Risk Management]review and approval of Certificates of
Insurance (COi)on an annual basis:
BTR INSURANCE PROCESS:
1.Plan Module BLPL [Business License Plan]yearly renewal (test configuration)either
before or after BTR renewals
2.Customer would then upload document which triggers a notification to Risk Management
3.Risk Management performs a review of insurance documentation
4.Finance does a generic review following
5.Finance links BLPL to BTR;
6.Finance activates BTR if BLPL is approved,and fees are paid
7.Finance will not release BTR by September 30th if BLPL is not approved
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COi's will be verified by Risk before any BTR requiring insurance is issued
If this process cannot be implemented by July 2025,we suggest an annual process for FY 25/26
that is similar to "Parking Impact Fees,"in which Planning and Zoning (P&Z)sends Finance a list
of all BTRs that cannot be renewed because of outstanding Impact Fees owed to the City.This
has worked well with P&Z.We just implemented a similar procedure with Code Compliance
(Code)and the Marine &Waterfront Protection Authority.
The process has been working with P&Z and Code.
OIG ADDITIONAL RECOMMENDATIONS:
After receiving management's response,the OIG auditor contacted an Information Technology
manager to gain a clearer understanding of the Business License Plan (BLPL)process.He
explained that BLPL is a sub-process that creates a workflow for revisions and is integrated into
the BTR module.For a BTR renewal to be approved,Risk Management must first approve the
Certificate of Insurance (COi),followed by manual approval of the BLPL by Customer Services in
the Finance Department.Accordingly,we are making the following additional recommendations:
1.Update the BTR module to include "Certificate of Insurance"in the attachment drop-
down list,allowing applicants to upload their COi for review by Risk management.
2.Develop a procedure to train applicants on the new process,ensuring they understand
how to upload the COi into the system.This training should be completed before the
new process is implemented.
3.Grant Risk Management access to the BLPL module and provide appropriate training
on how to review and approve the BLPL.This training should be completed before the
new process is implemented.
cc:Eric Carpenter,City Manager
Jason Greene,Chief Financial Officer
Mark Taxis,Assistant City Manager
Manny Marquez,Assistant Director,Finance Department
Marc Chevalier,Senior Risk Officer,Human Resources,Risk Management
Ricardo Dopico,City Attorney
Hernan Cardena,Director,Code Compliance
OFFICE OF THE INSPECTOR GENERAL,City of Miami Beach1130WashingtonAvenue,6th Floor,Miami Beach,FL 33139Tel:305.673.7020 •Hotline:786.897.1111Email:CityofMiamiBeachOIG@miamibeachfl.govWebsite:www.mbinspectorgeneral.com
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