OIG No. 21-17: Roll-Off Permit Process Review
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September 2, 2021
TO: Honorable Mayor and Members of the City Commission
FROM: Joseph Centorino, Inspector General
PROJECT: Roll-Off Permit Process Review
OIG No. 21-17
PERIOD: January 1, 2017 through July 31, 2020
Executive Summary
This review was initiated to analyze the Roll-off permit process to identify possible improvements
and increase compliance.
The systemic deficiencies identified in this report have made the City increasingly reliant on
conducting roll-off fee audits to uncover these deficiencies. To date, contractors have cooperated,
and recent audit assessments have been substantial.
As a result of unreported gross receipts identified through this process, recent assessments
(including interest and penalties) have been levied in the amount of $114,086.84 to Great Waste
& Recycling LLC, and $2,130.99 to Bicon Inc. d/b/a S&S National Waste. Both companies agreed
with the assessments and remitted all monies due.
These listed assessment amounts do not include other fees identified by OIG audit staff that are
owed by these contractors for delinquent business tax receipts, outstanding Code Compliance
violations, prior audit assessments, additional roll-off permit fees due related to months not in the
designated audit period, etc. Furthermore, the OIG Sanitation Tax Auditor is presently working
on several other roll-off fee revenue audits that are expected to have significant assessments.
The OIG has also become aware of the existence of several previously unknown contractors
performing roll-off services within Miami Beach. They were only noticed due to the
implementation of several recommendations listed in this report, and through the OIG Sanitation
Tax Auditor’s May and June 2021 site visits to Miami Beach properties that were issued Building
permits. These contractors’ noncompliance has provided an unfair advantage to these
companies over the other registered firms, as they are less regulated and can offer lower prices
and/or realize higher profit margins, due to their avoidance of required business tax receipts and
monthly roll-off permit fees.
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The implementation of the recommendations listed in this report will help lessen this advantage
by identifying non-complying contractors more quickly and subjecting them sooner to the City
Code’s enforcement provisions, as well as insuring that the City receives the appropriate fees and
roll-off revenues to which it is entitled.
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TO: Honorable Mayor and Members of the City Commission
FROM: Joseph Centorino, Inspector General
DATE: September 2, 2021
PROJECT: Roll-Off Permit Process Review
OIG No. 21-17
PERIOD: January 1, 2017 through July 31, 2020
This review was initiated to analyze the Roll-off permit process to identify possible improvements
and increase compliance. The Office of the Inspector General (OIG) Sanitation Tax Auditor soon
realized that this process was closely intertwined with portions of the Building Department’s
permitting process as well as to the Finance Department’s Business Tax Receipts and Accounts
Receivable processes. Therefore, the scope of the review was expanded to include an overview
of those pertinent areas, where applicable.
Authorized Roll-Off Companies and Monthly Reporting Process Summary
A roll-off is defined as a container with a minimum capacity of ten cubic yards designed to be
transported by a motorized vehicle. These containers are used by contractors for the collection
and disposal of construction and demolition debris and/or large quantities of trash and/or bulky
waste, but not garbage or commercial refuse. Bulky waste represents large items of household
refuse, such as appliances, furniture, accumulations from major tree cutbacks, large crates and
like articles, while commercial refuse is all solid waste produced by commercial establishments.
The City’s licensing and permitting system, EnerGov, listed six roll-off contractors on January 20,
2021 with their 2020/21 fiscal year business tax receipts (BTRs) in “active” status and another
seven contractors in “pending” status. “Pending” status means that the BTR is not yet valid or
active and is missing needed documentation and/or payment in full. The number of roll-off
contractors frequently changes, either upward as new contractors abide by the City’s guidelines
and obtain their BTRs, or downward as contractors merge or stop conducting business in Miami
Beach and do not renew their BTRs. For comparative purposes only, there were 194 roll-off
contractors registered with Miami-Dade County.
City Code Section 90-192 provides that franchise waste and roll-off contractors are required to
obtain annual BTRs or may be subject to enforcement procedures and penalties. Meanwhile, the
City of Miami Beach’s website states, “The Code Compliance Department is dedicated to
protecting the public health, safety, and welfare, improving the quality of life for our City’s
residents, business owners and visitors through education and the consistent and equitable
application of the City’s Code of Laws and Ordinances.” It is the responsibility of the Finance
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Department’s Licensing Section to notify the Code Compliance Department that these seven roll-
off contractors still have their BTRs in “pending” status to help obtain compliance, or that they are
subject to the stated enforcement procedures and penalties.
Authorized roll-off contractors are required to abide by provisions outlined in the City Code, which
include the remittance of roll-off permit fees, calculated by multiplying the City Commission
approved rate by the contractor’s total applicable Miami Beach gross receipts. City Code Section
90-221 defines gross receipts as the entire amount of fees collected by the contractor (whether
wholly or partially collected) for solid waste collection and disposal within the City, excluding any
taxes, and gross receipts from servicing roll-off and portable containers. Any unpaid fees that are
not timely received are subject to penalties of 10% per month up to a maximum of 50%, plus
interest of 1% per month.
City Code Section 90-278(4) requires that monthly reports, accompanied by payment of any owed
fees, are to be submitted to the City’s Finance Department by all authorized contractors at the
end of the month after the month in which the gross receipts were generated. For example, the
report and any associated roll-off fees owed for January 2021 are due by February 28, 2021.
When the roll-off contractor has annual gross receipts reported to the City over $200,000.00, it is
required to deliver to the City’s Finance Department a statement of annual gross receipts
generated from accounts in the City for the preceding fiscal year, certified by an independent
Certified Public Accountant. These statements of annual gross receipts are to be furnished within
60 days following the close of the roll-off contractor’s fiscal year pursuant to City Code Section
90-278(4).
Roll-Off Permit Process Overview
A. Roll-Off Permit Process
According to a January 14, 2021 email received from the Sanitation Division, the roll-off
permit process for the hauler permits can be summarized as follows:
1. Applicant (Licensee) submits the request via email to
“sanitationrequests@miamibeachfl.gov”.
2. Sanitation Office Staff reviews to make sure application is complete.
3. Sanitation staff enters the application in EnerGov.
a. On the inspection screen it is placed in pending status (Code Compliance
assigns & schedules their own inspections)
4. If Code Compliance approves it, Sanitation then issues the permit to the hauler.
5. If Code Compliance denies a permit, necessary corrections must be made before
reinspection.
OIG’s review determined that Roll-off permits do not contain a stated expiration date and remain
open indefinitely, unlike Building Permits which are closed when the project’s CO or CC is issued.
Application Review EnerGov Code
Inspection Approval
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Another interesting point is that, unlike a Building Permit, there is no charge for a customer
(typically either the property owner or the hired building contractor) to obtain a Roll-off permit,
which may diminish its value and apparent importance to the customer. Furthermore, the Code
Compliance Department issues violations containing a $100 fee to any identified customers using
a roll-off that did not previously obtain a Roll-off permit for that location.
Testing Performed and Results Obtained
OIG staff met with members of the Miami-Dade County Solid Waste Department, who closely
monitor the direct correlation between Building and Roll-off permits. They claimed that this
leading indicator helps them ensure that Roll-off permits are issued when needed, and that the
roll-off contractors include these locations in their monthly filings and remittances.
OIG’s testing determined that the data entered in the City’s EnerGov system, the City’s licensing
and permits system, pertaining to Building and Roll-off permits are not linked and are typically
entered separately by different personnel. This practice increases the risk that required Building
and/or Roll-off permits may not be obtained by contractors, thereby resulting in less regulation
and lost revenues to the City. It also places more emphasis on ensuring that Finance Department
Licensing Section personnel timely notify the Code Compliance Department to issue violations
for noncompliance.
The Building Department Deputy Director stated in an August 13, 2020 phone conversation with
the OIG Sanitation Tax Auditor, that the following eight Building permits have a direct relationship
with roll-off services (i.e., tied to a construction site): (1) building commercial, (2) building
condominium, (3) building residential, (4) building special events, (5) pool commercial, (6) pool
residential, (7) roofing commercial and (8) roofing residential. Since Building permits issued for
each of these eight categories most likely require the usage of a roll-off container to dispose of
the debris, Roll-off permits should be simultaneously issued in many instances for these projects.
The OIG Sanitation Tax Auditor requested and received a Building Permits Report generated by
the City’s Information Technology Department containing all the corresponding Building permits
issued for the 55-month period of January 1, 2016 through July 31, 2020. Similarly, a Roll-Off
Permits Report for the same period was also generated and provided, so that data from the two
reports could be compared. Hence, it was noted that the Building Permits Report contained 8,618
transactions while the Roll-off Permits Report contained only 1,372 transactions. As each
transaction is identified by address in the City’s EnerGov system, it was calculated that the
Building Permits Report contained a total of 1,349 addresses and the Roll-Off Permits Report
contained 746 addresses. The difference between the number of transactions and addresses is
attributable to the fact that more than one Building and/or Roll-off permit may be issued to each
address.
A further analysis of the two reports found that 361 addresses were listed on both reports,
representing 26.76% of the Building Permits Report’s addresses (361/1,349). Consequently, it
was concluded that the remaining 988 (1,349 – 361) addresses or 73.24% did not have a Roll-off
permit issued. These 988 addresses were related to 4,738 Building permit transactions, and its
corresponding distribution among the eight categories is shown in Table 1 below.
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Table 1
From the 746 addresses included in the Roll-Off Permits Report, 385 (51.61%) did not have a
corresponding Building permit issued (see Table 2 below). This high percentage is troubling
because the Building Department’s permitting process regulates construction to ensure that it is
performed in accordance with Florida Building Code standards.
Table 2
The 361 addresses issued both Building and Roll-off permits were related to 3,880 Building
Department transactions (see Table 3 below) in support of the Deputy Building Director’s
assertion that there is a direct relationship between the identified eight Building permits and roll-
off services (i.e., tied to a construction site). Therefore, OIG’s analysis supports the assertion that
0
500
1,000
1,500
2,000
2,500
3,000 2,747
207
1,236
33 22 155 155 183
Building Permits Without Roll Off Permits
0
500
1000
1500
Total Both Permits No Roll Off No Building
1,349
361
988
746
361 385
# of Addresses with Building and Roll-Off Permits
Building Roll Off
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these eight Building permits are frequently a good leading indicator of roll-off activity within the
City and can be used proactively to help detect unreported roll-off activity.
Table 3
Furthermore, it was determined that at least seven roll-off permits were issued to companies
and/or general contractors without a valid BTR authorizing the performance of roll-off activities
within the City’s boundaries (see Table 4 below). It was subsequently concluded after meeting
with Sanitation Division personnel, that the “Applicant” and “Contractor” names were entered into
the incorrect fields and that the associated contractors were compliant. Although the OIG realizes
that input errors may occur, it is important that they are minimized to facilitate effective data
analytics.
Table 4
PERMIT
NUMBER
ISSUED
DATE PERMIT MAIN ADDRESS COMPANY/CONTRACTOR NAME
PWD0117-0544 1/6/2017
800 77TH ST MIAMI BEACH FL -
331412209 CARIVON CONSTRUCTION CO
PWD1116-0455 11/10/2016
204 W DILIDO DR MIAMI BEACH
FL -331391168 CHANIN CONSTRUCTION
PWD1218-1793 12/17/2018
100 S POINTE DR MIAMI BEACH
FL -331390000
Continuum on South Beach Master
Association, Inc.
PWD0518-1455 5/23/2018
3175 PRAIRIE AVE MIAMI BEACH
FL -331403426 JOSE F PRIETO
PWD0119-1804 1/7/2019
4300 ALTON RD MIAMI BEACH FL
-331402800 KIM THAYER
PWD0616-0099 6/14/2016
2201 COLLINS AVE MIAMI BEACH
FL -331391717 MEGATREND INC- CGC1513585
PWD0616-0100 6/16/2016
3747 PRAIRIE AVE MIAMI BEACH
FL -331403436
RAMMAR CONSTRUCTION
COMPANY CGC031506
A Roll-Off Violations Report by case number was received from the City’s Information Technology
Department containing 86 violations issued by the Code Compliance Department during the 55-
0
500
1,000
1,500
2,000
2,500 2,003
222
974
46 69 256 168 142
# of PermitsBuilding Permit
Number of Building Permits found on the 361
Roll-Off Addresses Matched
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month period of January 1, 2016 through July 31, 2020. Of these, 81 violations were related to
overflowing roll-off containers, while the remaining five were for not obtaining the required permits
(see Table 5 below).
Table 5
Period Overflowing
Containers
Violations
No Roll-Off Permit
Violations
Total Roll-Off
Violations
Roll-Off Fines
Issued
01/01/16 – 12/31/16 10 0 10 $900
01/01/17 – 12/31/17 21 1 22 $4,400
01/01/18 – 12/31/18 12 0 12 $2,550
01/01/19 – 12/31/19 32 4 36 $14,850
01/01/20 – 07/31/20 6 0 6 $1,700
Total 81 5 86 $24,400
In addition, three of the five addresses issued violations for not obtaining the required Roll-off
permits by the Code Compliance Department (see Table 6 below), were also found to have not
obtained Building permits.
Table 6
DATE CODE CASE MAIN
ADDRESS
CODE CASE
NUMBER COMPANY NAME
12/5/2019 5765 LA GORCE DR
MIAMI BEACH FL - SV2019-12395 5765 La Gorce Drive, LLC- C/o HINSHAW &
CULBERTSON LLP
3/2/2019 1220 9 ST MIAMI BEACH
FL -331395560 SV2019-07982 TIMS LAND ACQUISITION CORP % TIMOTHY
WILCOX
11/28/2017 1211 Euclid SV2017-04348 J & M Scaffolds of Florida, Inc. c/o Guerra, Rene L.
Roll-off contractors are required to remit a percentage of their total monthly gross receipts to the
Finance Department in accordance with the City Code. The City Commission sets the applicable
percentage rate, which was 18% through September 2019 before being increased to 20% for the
remainder of the audit period. These contractors’ payments are to be supported by the Roll-Off
Fee Returns, showing the calculations in arriving at the payment amounts, as well as providing a
detailed listing of the Miami Beach locations serviced.
Finance Department staff’s primary emphasis is on checking the accuracy of the Roll-Off Fee
Return’s calculations and depositing the payments received. It has been found in prior audits of
these roll-off contractors, that a detailed listing of Miami Beach locations serviced may be missing.
This omission complicates the auditing process as the missing information must be requested
from the roll-off contractor during the audit field work phase, since it is essential in verifying the
accuracy of the roll-off contractor’s filings and must be reconciled with the customer data in all
positive confirmation letters returned to the OIG.
OIG staff used the following methodology to estimate that the City’s Sanitation Division did not
collect a total of $163,256.00 in roll-off fees (excluding interest and penalties) during the January
1, 2016 through July 31, 2020 reviewed period, that it may have been entitled to receive.
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• Recent audits of two roll-off companies, Bicon Inc. d/b/a S&S National Waste and Ojito
Waste Systems Inc., determined that their average monthly invoice was $481.42 and
$567.33, respectively.
• Similarly, each company’s average monthly billing frequency by location was calculated
to be 3.39 and 1.95 times per month.
• Given these results, a conservative approach was used whereby it was assumed that the
average monthly invoice equaled $450.00 and that the average monthly billing frequency
by location is two.
• As previously stated, OIG staff determined that there was a total of 988 addresses that
did not obtain a Roll-off permit. For simplicity, it was assumed that the identified
deficiencies occurred evenly throughout the period or 17.96 times per month (988
addresses/55 months = 17.96).
After applying the City Commission approved roll-off fee percentage rates in effect at the time,
OIG staff estimated that the City’s Sanitation Division did not receive revenues of $163,256.00
owed during the 55-month period reviewed or approximately $2,968.00 per month (excluding
interest and penalties).
In addition to roll-off violations, the Code Compliance Department also issues other Sanitation
violations including illegal dumping, illegal disposal, garbage service, bio-hazardous, creation of
a health hazard or nuisance, etc. It was determined that a total of 9,858 Sanitation violations by
case number (including roll-off violations) were issued between January 1, 2017 through July 31,
2020 as shown below in Table 7:
Table 7
Period * # of Sanitation Violations by case
number Sanitation Fines Levied
01/01/17 – 12/31/17 3,039 $342,600
01/01/18 – 12/31/18 2,710 $292,562
01/01/19 – 12/31/19 3,371 $260,500
01/01/20 – 07/31/20 738 $96,500
Total 9,858 $992,162
* Because OIG staff could not easily obtain the 2016 calendar year labor costs, which would have required
access to the City’s prior Eden system’s data, it was excluded from analysis.
The Sanitation Division contributed the following revenues to the Code Compliance Department
to help offset the associated estimated labor costs (see Table 8):
Table 8
Sanitation Funds (Calendar Year) * 2017 2018 2019 2020 Total
Code Compliance - Salaries, health
costs & fringe benefits $110,890 $246,568 $245,584 $106,409 $709,451
Code Compliance employees totally
or partially paid by Sanitation 3 4 4 2
* Payroll data was queried for all salaries paid between 1/1/2017 through 7/31/2020 to Code Compliance
Department employees in which Organizational Code 43500310 (Sanitation Personal S Public W) was used.
Fringe benefits were also determined and added accordingly.
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The estimated Sanitation Division’s payroll contributions of $709,451 are less than the $992,162
in fines levied by the Code Compliance Department (if all or most of the fines levied are paid).
However, improvements should be considered in enforcement as only five violations were issued
for failure to obtain roll-off permits during the tested period when it appears that as many as 993
(998 – 5) other addresses may have needed to be similarly cited.
OIG staff also reviewed the last five Citizen and Business Surveys related to garbage/trash
collection and cleanliness of streets performance measures where it was found that there is an
overall decrease in residential and business owners’ satisfaction since 2009 (OIG’s established
baseline), despite an uptick in satisfaction for three out of four measurements between 2016 and
2019 (see Tables 9 and 10 below).
Table 9
Table 10
83%81%79%
66%
75%
75%
71%72%
71%
66%
55%
60%
65%
70%
75%
80%
85%
2009 2012 2014 2016 2019Satisfaction %Years
Garbage/Trash Collection
Residential Business
71%
69%
61%
51%
58%
75%74%
68%
61%
69%
45%
50%
55%
60%
65%
70%
75%
80%
2009 2012 2014 2016 2019Satisfaction %Axis Title
Cleanliness of Streets
Business Neighborhoods
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Increased enforcement efforts of Sanitation related issues by the Finance and Building
Departments and its timely reporting to the Code Compliance Department would most likely result
in additional roll-off violations being issued, and improved ratings in the City of Miami Beach
Citizen and Business surveys. (https://www.miamibeachfl.gov/city-hall/city-manager/mission-
vision-and-values/strategic-planning/community-survey/).
Additional Observations
1. OIG staff encountered unexpected differences in comparing the permit addresses listed
in the different reports due to inconsistencies in entering the data, which complicated the
reconciliation process. The areas of the permits highlighted in Table 11 below show
examples of the lack of data entry standardization:
Table 11
PERMIT
NUMBER PERMIT TYPE PERMIT
WORKCLASS PERMIT MAIN ADDRESS
PWD0320-2374 Roll-Off Private 100 21 ST MIAMI BEACH FL -331391701
BC1703525 Building -
Commercial
Alteration (w/o
Phased) 100 21ST ST MIAMI BEACH FL -331391701
BCR2000272 Building –
Condominium Online Flooring 100 LINCOLN RD Miami Beach FL 33139
PWD0516-0048 Roll-Off Private 100 LINCOLN RD MIAMI BEACH FL -331392013
BC1705997 Building -
Commercial
Alteration (w/o
Phased) 100 S POINTE DR MIAMI BEACH FL -331390000
PWD1218-1793 Roll-Off Private 100 S POINTE DR MIAMI BEACH FL -331397364
PWD0319-1920 Roll-Off Private 100 INTE DR MIAMI BEACH FL -331390000
2. Roll-off contractors are currently submitting monthly reports and the corresponding roll-off
permit fees at their own discretion. Consequently, the contractors may not file during
several month(s) and the City does not know if it is because no roll-off services were
performed on Miami Beach during that period or if it was an oversight, intentional or
otherwise.
3. Any roll-off contractor with annual gross receipts reported to the City over $200,000.00 is
required to deliver to the City’s Finance Department a statement of annual gross receipts
generated from accounts in the City for the preceding fiscal year, certified by an
independent Certified Public Accountant. These statements of annual gross receipts are
to be furnished within 60 days following the close of the roll-off contractor’s fiscal year
pursuant to City Code Section 90-278(4). Although these statements are a valuable
control document when the OIG Sanitation Tax Auditor is performing his analysis, they
may not be obtained by contractors or furnished to the Finance Department, where their
submittal is typically not monitored. Lastly, the City Code is relatively silent on the
enforceability of this provision and how to address non-compliance by contractors.
4. The Sanitation Department Business Manager told the OIG Sanitation Tax Auditor that a
customer’s Roll-off permit application should be reviewed within twenty-four hours. It was
noted that a roll-off contractor, G7 Holdings, Inc., submitted twenty-one (21) Roll-off permit
applications online through the Miami Beach Citizen Self Service (CSS) portal on May 22,
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2021. However, the Sanitation Division had not processed these permit requests as of
June 4, 2021. When questioned, Sanitation Division personnel verbally stated that they
were unaware of the need to monitor the CSS regarding Roll-off permit application
requests. The status of one of these permits is shown below in Table 12 concerning 15 E
San Marino Dr, Miami Beach, FL, 33139-1101.
Table 12
Recommendations
• Contractors should be charged for obtaining Roll-off permits to at least cover the
associated direct costs. In addition, Roll-off permits should contain a stated expiration
date and not remain open indefinitely until the project’s Certificate of Occupancy (CO) or
Certificate of Completion (CC) is issued.
• Information Technology Department staff should develop a monthly report that
automatically compares the Building Permits Report with the Roll-Off Permits Report data
so that any identified differences can be promptly investigated by the OIG Sanitation Tax
Auditor and/or other designated City staff.
• Building and Roll-off permits should not be issued to companies or individuals without a
valid “active” City of Miami Beach BTR.
• The City Code should be revised to require roll-off contractors to timely submit returns
every month, even if they did not operate within Miami Beach during that period. If they
do not comply, they should be notified electronically, and penalties should be levied where
appropriate. This practice should help improve compliance by preventing inadvertent filing
omissions.
• Designated City staff should more actively monitor the need for applicable roll-off
contractors to timely submit statements of annual gross receipts pursuant to City Code
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Section 90-278(4). Furthermore, the City Code should be amended to establish penalties,
etc. for non-compliance.
• The Building Department’s online permit application should include two questions to
determine if a roll-off will be used on the project and the name of the roll-off contractor
selected. This information will be confirmed by the OIG Sanitation Tax Auditor and then
used to verify that they are included in the appropriate roll-off contractor’s monthly
reporting and remittances.
• Standardization should be implemented across City departments on how addresses and
contractors’ names are to be entered into the EnerGov system to prevent duplication and
decentralization of data. This identified deficiency would most likely also apply to all other
City used software.
• The Information Technology Department should work with City staff to automate the
monthly filings of the Sanitation franchise waste and roll-off contractors and require the
submittal of both the Roll-Off Fee Return and the detailed listing of Miami Beach addresses
serviced. In the interim, the Finance Department should ensure that the proper supporting
documentation is present and then follow up with the contractors on any missing
information.
• Finance Department’s Licensing Section provides the Code Business Tax Receipt Report
to the Code Compliance Department, which is a useful tool to determine the status of a
customer’s business tax receipt. However, the report does not provide specific leads or
generate a proactive list of business tax receipts for issuance of violations. Although it is
a good source of data, it should generate a list of companies that are operating without a
business tax receipt. For example, it could be programmed to indicate which contractors’
business tax receipts have remained in pending status for longer than a designated period
(1 month, 3 months, etc.) and should be investigated to determine whether a violation is
warranted. The Code Business Tax Receipt Report also does not address those
occasions where companies have never registered with the City of Miami Beach or that
are filing monthly roll-off fee returns in the Munis system without a business tax receipt.
• Designated Sanitation Division personnel should routinely review the CSS to determine if
any Roll-off permit applications were received. If so, they should be reviewed timely with
the results communicated to the customer in accordance with the documented criteria
established by division management.
Status Update
As this review’s fieldwork was being concluded, the OIG held a January 26, 2021 Microsoft Teams
meeting with applicable City staff to discuss the identified findings and the optimal corrective
actions to implement. Over the past several months, the following revisions have already been
implemented:
• With the assistance of the Information Technology and Building Departments, the Building
Department permitting process now contains questions whether a roll-off container will be
used at the job site and which company will be supplying it. The OIG Sanitation Tax
Auditor will utilize this information to verify that the contractor is including that location in
its submitted monthly reports and roll-off permit fee remittances.
• Efforts have been focused on having roll-off contractors obtain all delinquent annual BTRs
and to remit any associated costs. For example, the number with active valid BTRs has
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increased from six in January 2021 to thirteen as of May 27, 2021, and the number in
compliance is expected to further increase.
In addition, recently completed roll-off contractors’ revenue audits have identified significant
unreported and/or delinquently reported gross receipts resulting in assessments (including
interest and penalties) being levied of $114,086.84 to Great Waste & Recycling LLC, and
$2,130.99 to Bicon Inc. d/b/a S&S National Waste, with other significant assessments
forthcoming.
Furthermore, the OIG Sanitation Tax Auditor started conducting field visits to Miami Beach
addresses issued Building permits in May 2021 to determine if roll-offs are also present. In doing
so, he become aware of other non-registered companies that perform roll-off services within the
City and are not reporting monthly gross receipts and remitting roll-off permit fees. Audits of many
of these contractors have been started. Also, the Code Compliance Department was notified and
subsequently issued several warranted violations. A separate report listing the deficiencies noted
from these field visits and their status will be issued.
City Code Section 90-278(8) states, “Identification of equipment. All equipment utilized to collect
and transport solid waste in the city must be conspicuously marked on both sides of the
automotive unit with the name of the hauler, tare weight and cubic yard capacity. Identification
information must also be marked on all trailer and container units. All marking must be in letter
and numerals at least two inches in height.” Upon receipt of the OIG’s initial March 24, 2021
email and after verifying with the City Attorney’s Office, the Code Compliance Department created
a new violation code in the EnerGov system and began issuing applicable citations for any
identified non-conforming roll-off containers.
Summary
The magnitude of these recent assessments and other roll-off fee revenue audits nearing
completion, as well as the number of identified contractors not obtaining valid business tax
receipts and required permits, is alarming. The current process contains few safeguards to
proactively obtain compliance with stated City Code sections other than conducting periodic
audits, which is a lengthy process requiring the contractor to provide the necessary
documentation.
Consequently, the OIG believes in the need to make systemic changes to help identify non-
compliance sooner. We recommend a more proactive approach by the City to strongly consider
adopting the recommendations included throughout this report to help identify noncompliant
contractors more quickly. The better sharing and reconciliation of interdepartmental
communication via software and data, the improved usage of technology through the automation
of contractor’s filing and remittances and the generating of various system reports, the
streamlining of processes and removal of redundancies, are some of the recommended steps to
make the City less dependent on documentation furnished by contractors and to increase
compliance and City revenues.
Meetings were held and correspondence exchanged throughout the audit process with the listed
auditees, to discuss the identified findings and to obtain workable recommendations. The OIG
incorporated any feedback and recommended revisions received into this final report. When the
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auditees were given the final opportunity to include any desired management responses in this
report, none were received. Finally, we would like to personally thank all pertinent Building,
Sanitation, Finance, Code Compliance and Information Technology staff for their cooperation and
assistance.
Approved by:
_____________________________ __________________
Joseph Centorino, Inspector General Date
Reviewed by:
______________________________ __________________
Mark Coolidge, Chief Auditor Date
______________________________ __________________
Norman Blaiotta, Deputy Chief Auditor Date
Completed by:
______________________________ __________________
Juan Ospina, Sanitation Tax Auditor Date
cc: Alina Tejeda Hudak, City Manager
Eric Carpenter, Deputy City Manager
Bradford Kaine, Sanitation Division Director
Ana Salgueiro, Building Department Director
Hernan Cardeno, Code Compliance Department Director
John Woodruff, Chief Financial Officer
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