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Home My WebLink AboutOIG No. 26-05 Sanitation Annual C&D Collection Permit Fee Audit Docusign Envelope ID: CFF558EC-4D27-83C5-83A1-12C9D12E0117 Joseph M. Centorino, Inspector General TO: Honorable Mayor and Members of the City Commission FROM: Joseph M. Centorino, Inspector General DATE: May 29, 2026 PROJECT: Sanitation Annual C&D Collection Permit Fee Audit OIG No.: 26-05 PERIOD: C&D Collection Permit Fees billed from FY 2022 through FY 2025 The Sanitation Tax Auditor in the City of Miami Beach’s Office of the Inspector General (OIG) Audit Division ensures that Construction and Demolition (C&D) haulers comply with City Code regulations. C&D haulers must obtain a C&D collection permit by October 1 of each year, except for those that begin providing services after October 1, in which case they must obtain the permit before beginning operations. This audit covered all C&D Collection Permit Fees billed from FY2022 through FY 2025. BACKGROUND On September 2, 2021, the Inspector General for the City of Miami Beach released a Rolloff Permit Process Review, OIG No. 21-17, to evaluate the permit process, identify potential improvements, and enhance compliance. Among his recommendations, the Inspector General proposed that “Roll-off” (now C&D) contractors be charged permit fees to cover the City’s administrative and processing costs. On December 8, 2021, the Mayor and City Commission approved Ordinance No. 2021-4456, establishing an annual Roll-off permit fee of $1,000 to offset the city’s administrative and processing expenses. The rate specified in Appendix A for this permit is to be adjusted annually to account for changes in the Consumer Price Index for all urban consumers, CPI-U. On July 22, 2022, the Mayor and City Commission passed Ordinance No. 2022-4493, amending Section 90-276(2) to allow for yearly administrative adjustments in fees based on increases in the Consumer Price Index for the Miami-Fort Lauderdale-West Palm Beach area, in accordance with Section 1-15 (B) of the City Code. The rate in Appendix A for this permit must be updated annually by the City Manager, effective October 1st each year. Since the approval of the Annual C&D collection permit, the rate has been subject to CPI increases, and the following rates have been approved by the City Commission: Page 1 of 6 Docusign Envelope ID: CFF558EC-4D27-83C5-83A1-12C9D12E0117 Fiscal Year Schedule of Fees Annual Permit Fee (90-276(2) 2022 $ 1,000.00 2023 $ 1,071.00 2024 $ 1,178.00 2025 $ 1,246.00 2026 $ 1,281.00 OBJECTIVE The objective of this audit was to determine whether the Sanitation Division correctly billed the C&D haulers from FY 2022 through FY 2025. METHODOLOGY x Reviewed applicable sections of the Miami Beach City Code x Interviewed and made inquiries of staff to gain an understanding of the billing process x Performed substantive testing consistent with the audit objectives, including, but not limited to, examination of applicable transactions and records x Drew conclusions based on the results of testing, made corresponding recommendations, and obtained auditee responses and corrective action plans x Performed other audit procedures as deemed necessary FINDINGS, RECOMMENDATIONS, AND MANAGEMENT RESPONSES 1. C&D COLLECTION PERMIT BILLED WITHOUT CPI APPLIED The auditor reviewed all C&D collection permit payments recorded in Munis, the current city’s enterprise resource planning system, to ensure that annual permit fees were billed and paid in accordance with Appendix A (Schedule of Fees). Condition During the audit period, the Public Works Department Sanitation Division billed a total of 76 C&D collection permits. Of these, 58 permits (76%) were incorrectly billed because the annual fee did not reflect the required CPI adjustment as specified by City policy. Exhibit A at the end of the report shows the analysis matrix. Criteria Sec. 90-276 Permit required. (a) Except as provided elsewhere in this chapter, no C&D hauler or other person shall engage in the business of removing or disposing of construction and demolition debris or large quantities of trash from any premises within the city limits, whether or not a C&D container is used, without first securing a C&D collection permit for such activities from the city by: . . . (2) Paying an annual C&D collection permit fee in the amount of $1,000.00 to cover the city's annual administrative and processing costs. The rate in Appendix A pertaining to this subsection will be administratively adjusted annually by the city manager, effective October 1 of each year, to reflect increases in the Consumer Price Index for the Miami- Page 2 of 6 Docusign Envelope ID: CFF558EC-4D27-83C5-83A1-12C9D12E0117 2. IMPROPER PRORATION OF C&D COLLECTION PERMIT FEES Fort Lauderdale-West Palm Beach, Florida area, pursuant to subsection 1-15(b) of the City Code; and . . . (5) Failure to secure a C&D collection permit by October 1 of each year (except that a C&D hauler that only commences to provide services after October 1 shall be required to secure the C&D collection permit by or before the date it commences to provide services) will result in penalty of $5,000.00. Cause This situation arose from the Sanitation Division's insufficient understanding of the City Code, resulting in annual permit fees not being properly adjusted for inflation as required. Effect The city did not bill and received a total of $10,724.00 in C&D collection permit fees during the audit period. The failure to apply the CPI adjustment diminished the city's anticipated income from permit fees and may affect its ability to cover administrative and processing costs associated with C&D collection permits. Recommendation The OIG recommends that the Sanitation Division collect the unpaid portion of the Construction and Demolition (C&D) collection permit fees. Should any doubt arise concerning this matter, the Sanitation Division may consult with the City’s Legal Department for guidance regarding the collection of the outstanding C&D collection permit fees. Additionally, to prevent future occurrences, the Sanitation Division should receive training on the City Code requirements and the annual administrative adjustment of permit fees in accordance with the Schedule of Fees approved by the City Commission. This training should emphasize the importance of applying Consumer Price Index adjustments as mandated, ensuring accurate billing and compliance moving forward. Sanitation Division Response: During the period from 2022, when the permit was $1,000.00 annually, the previous Division Direction did not advise the office to bill the updated amounts. Upon finding out that the updated amount for 2026 was $1,281.00, we proceeded to send an updated invoice for all the permittees for the year 2026. We will seek the opinion and guidance of the City Attorney’s Office as to how to proceed with the incorrect amounts for the years 2023, 2024 & 2025. Implementation date: September 2026 The auditor reviewed all C&D collection permit payments recorded in Munis, the City’s current enterprise resource planning system, to ensure that annual permit fees were billed and paid in accordance with the City Code. Condition During FY2025, the Public Works Department Sanitation Division improperly prorated the permit bill for three C&D companies that applied for annual permits after October 1, which would last less than a full year. By prorating the permit fees, the Division charged those companies less than the full annual fee. Based on an opinion provided by the City Attorney’s Office, such proration is not provided for in the ordinance and is, therefore, Page 3 of 6 Docusign Envelope ID: CFF558EC-4D27-83C5-83A1-12C9D12E0117 impermissible. This resulted in all three companies being incorrectly billed and the City’s not collecting $1,446.52. Criteria Sec. 90-276 Permit required. (a) Except as provided elsewhere in this chapter, no C&D hauler or other person shall engage in the business of removing or disposing of construction and demolition debris or large quantities of trash from any premises within the city limits, whether or not a C&D container is used, without first securing a C&D collection permit for such activities from the city by: . . . (2) Paying an annual C&D collection permit fee in the amount of $1,000.00 to cover the city's annual administrative and processing costs. The rate in Appendix A pertaining to this subsection will be administratively adjusted annually by the city manager, effective October 1 of each year, to reflect increases in the Consumer Price Index for the Miami- Fort Lauderdale-West Palm Beach, Florida area, pursuant to subsection 1-15(b) of the City Code; and . . . (5) Failure to secure a C&D collection permit by October 1 of each year (except that a C&D hauler that only commences to provide services after October 1 shall be required to secure the C&D collection permit by or before the date it commences to provide services) will result in penalty of $5,000.00. Cause This situation arose from the Sanitation Division's insufficient understanding of the City Code, resulting in annual permit fees not being properly adjusted for inflation as required. Effect Applying proration to the annual C&D collection permit fees resulted in noncompliance with established billing procedures and the improper collection of permit fees, causing an underpayment to the City in the amount of $1,446.52 in C&D collection permit fees during the audit period. Recommendation To address the billing errors identified in this audit, it is recommended that the Sanitation Division provide training to relevant staff on the requirements and procedures outlined in the City Code regarding C&D collection permits. Additionally, the Sanitation Division should establish clear, written guidelines for processing annual permit fees to ensure compliance and prevent future proration errors. Regular internal reviews should also be implemented to monitor adherence to these procedures and ensure that the City collects all appropriate fees. Sanitation Division Response: According to my findings, the previous Division Direction verbally agreed to prorate the fee for some of the haulers. Implementation date: Currently, we do not prorate nor approve any prorations of the yearly fee. Page 4 of 6 GDocuSigned by: ~~ D0FADB7F4F9243L [ DocuSigned by: ~112B55E49B .. __________________ ____________________________ __________________ Docusign Envelope ID: CFF558EC-4D27-83C5-83A1-12C9D12E0117 The final report includes all management responses received pursuant to Section 2-256(h) of The City of Miami Beach Code. Respectfully submitted, 6/1/2026 | 2:12 PM EDT Joseph Centorino, Inspector____________________________ General Date 6/1/2026 | 12:07 PM EDT Norman Blaiotta, Chief Auditor Date cc: Eric Carpenter, City Manager David Martinez, Assistant City Manager John Noris, Public Works Director Alvaro Rueda, Interim Director, Sanitation Division Jason Greene, Chief Financial Officer OFFICE OF THE INSPECTOR GENERAL, City of Miami Beach 1130 Washington Avenue, 6th Floor, Miami Beach, FL 33139 Tel: 305.673.7020 • Fax: 305.587.2401 • Hotline: 786.897.1111 Email: CityofMiamiBeachOIG@miamibeachfl.gov Website: www.mbinspectorgeneral.com Page 5 of 6 Docusign Envelope ID: CFF558EC-4D27-83C5-83A1-12C9D12E0117 Exhibit A Customer ID 2022 2023 Amount to be Paid as per Schedule A in 2023 Differen ce for 2023 2024 Amount to be Paid as per Schedule A in 2024 Difference for 2024 2025 Amount to be Paid as per Schedule A in 2025 Difference for 2025 2026 Amount to be Paid as per Schedule A in 2026 Difference for 2026 Total Underpa yment per Customer ID 17666 $1,000.00 $1,000.00 $1,071.00 $71.00 $416.67 $1,246.00 $829.33 $1,000.00 $1,281.00 $281.00 $1,181.33 2524 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $1,000.00 $1,281.00 $281.00 $776.00 1903 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $1,000.00 $1,281.00 $281.00 $776.00 14600 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $1,000.00 $1,281.00 $281.00 $776.00 9705 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $1,000.00 $1,281.00 $281.00 $776.00 12588 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $1,000.00 $1,281.00 $281.00 $776.00 2700 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $1,000.00 $1,281.00 $281.00 $776.00 21572 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $1,000.00 $1,281.00 $281.00 $776.00 4057 $504.11 $1,246.00 $741.89 $741.89 2939 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $1,000.00 $1,281.00 $281.00 $705.00 4038 $632.70 $1,246.00 $613.30 $613.30 18224 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $495.00 998 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $1,000.00 $1,246.00 $246.00 $495.00 12300 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,281.00 $281.00 $352.00 4151 $1,000.00 $1,281.00 $281.00 $281.00 2960 $1,000.00 $1,281.00 $281.00 $281.00 4162 $1,000.00 $1,281.00 $281.00 $281.00 3326 $1,000.00 $1,281.00 $281.00 $281.00 1747 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $249.00 24575 $1,000.00 $1,000.00 $1,071.00 $71.00 $1,000.00 $1,178.00 $178.00 $249.00 12673 $1,000.00 $1,178.00 $178.00 $178.00 13276 $1,000.00 $1,000.00 $1,071.00 $71.00 $71.00 9712 $1,000.00 $1,000.00 $1,071.00 $71.00 $71.00 3164 $1,000.00 $1,071.00 $71.00 $71.00 2966 $1,000.00 $1,071.00 $71.00 $71.00 7337 $1,000.00 $1,000.00 $1,071.00 $71.00 $71.00 2744 $0.00 21868 $1,000.00 $0.00 27784 $1,000.00 $0.00 2529 $1,000.00 $0.00 Page 6 of 6