DATE: February 20, 2025
TO: Oakland Residents, Interim Mayor Jenkins, Members of the City Council, City Attorney Richardson, and City Administrator Johnson
FROM: City Auditor Michael C. Houston, MPP, CIA
SUBJECT: SUBSTANTIATED WHISTLEBLOWER ALLEGATION: The City of Oakland Uses Unauthorized Formulas for Calculating Overtime that Differ from FLSA Guidelines
Background
Compensation to City of Oakland employees is defined by the City of Oakland’s Charter, Municipal Code, City ordinances, and memoranda of understanding (MOUs) between the City of Oakland (City) and the various employee units that represent City employees. T he City is also subject to the Fair Labor Standards Act (FLSA), a federal law that establishes requirements for minimum wage, overtime pay, recordkeeping, and youth employment standards. FLSA mandates additional compensation for employees who work beyond standard hours and has established formulas for calculating overtime compensation.1 The Finance Department’s Payroll Division is responsible for overseeing payroll processing. This includes ensuring that the compensation of City employees aligns with the agreements, rules, and regulations mentioned above.
Below are the elements of employee pay that are influenced by these agreements, rules, and regulations:
Base Rate of Pay The pay employees receive for work before any additional compensation, bonuses, or incentives are added. Base Rate of Pay is the amount of money employees earn for their compulsory job duties, typically expressed as an hourly rate for hourly employees or an annual salary for salaried employees.
Premium Pay The additional pay provided to employees for working certain types of hours or under certain types of conditions. Premium Pay includes pay authorized for overtime, night, Sunday, or holiday work; or for standby duty, administratively uncontrollable overtime work, or availability duty, and various other types of pay.
Regular Rate of Pay The wage or salary employees typically earn for performing job duties during standard work hours. For employees who have fixed wages, Regular Rate of Pay equals Base Rate of Pay. However, employees with additional compensation elements like shift differential, standby, special assignment, and various other types of pay, the Regular Rate of Pay includes all compensation.
1 Some employees are exempt from FLSA’s overtime provisions.
INVESTIGATION
REPORT
2 FLSA Overtime Pay The additional hours worked by nonexempt employees beyond the standard 40-hour work week. The FLSA requires that nonexempt employees must be compensated for overtime hours at a higher rate than their Regular Rate of Pay.
FLSA Overtime Premium Pay The FLSA Overtime Premium P ay is the difference between FLSA Overtime Pay and Overtime Pay calculated with Base Rate of Pay.
Investigation History and Allegation
In July 2023, the City Auditor’s Office received an anonymous whistleblower complaint alleging that the City paid employees in the Department of Transportation and Public Works Department more in FLSA Overtime Premium Pay than those employees should have been paid.
The results of the City Auditor’s Office preliminary review warranted an investigation.2 Investigation Objectives
The objective of the investigation was to substantiate or refute the allegation by answering the following question:
• Did the City pay employees in the Department of Transportation and Public Works Department more in FLSA Overtime Premium Pay than they should have been paid, and if so, why and by how much? To meet this objective, we designed and completed an independent investigation. This report summarizes the investigation process and results.
Investigation Results
Our investigation substantiated the whistleblower allegation. Specifically, the investigation found:
• The City of Oakland uses formulas for calculating overtime that differ from FLSA guidelines, resulting in payments that exceed FLSA requirements. See “Overtime Methodologies” section (page 4), and Appendix A which describes our review and analysis of payroll data from the City’s financial management system and FLSA pay guidelines.
o The investigation confirmed the formulas have been coded into the City’s payroll system since at least 2018. The City was unable to explain the use of the formulas and when they took effect. o Between January 2018 and May 2024, the City overpaid 158 Department of Transportation and 368 Public Works Department employees $1,667,65 0 in FLSA Overtime Premium Pay.
Appendices B and C show a detailed breakdown of the FLSA Overtime Premium Pay by department, division, and year. They also show the number of employees who received FLSA 2 The Office performed a preliminary review of the whistleblower complaint to confirm understanding of the reported allegations, and determine if all the following four investigation criteria were met: 1) the alleged incident(s) involved Cit y of Oakland property, infrastructure, employees, officials, or otherwise falls within the City’s jurisdiction; 2) if true, the concern meets the definition of “fraud,” “waste,” or “abuse;” 3) the alleged incident(s) occurred within 12 months of being reported; and 4) the alleged incident(s) are not known to be the subject of current litigation. 3 Overtime Premium Pay each year since 2018. Appendix D provides a summary table that shows the average, median, and maximum excess payment s per pay period for the combined paychecks of the Department of Transportation and Public Works Department. Appendices E and F provide a detailed breakdown of FLSA Overtime Premium Pay by department, union representation, job classification, and year.
o The focus of our investigation was the affected employees in the Department of Transportation and the Public Works Department. We did not review employees in other City departments who might be affected.
• The City did not authorize the use of the formulas that differ from FLSA guidelines, meaning employees are not authorized to receive the resulting excess pay. o Employers like the City of Oakland may compensate employees over and beyond what FLSA requires. Nonetheless, we conclude that the City has been paying and continues to pay employees in the Department of Transportation and Public Works Department more than those employees were/are authorized to be paid based on our review of the City of Oakland’s Charter, Municipal Code, ordinances, and memoranda of understanding (MOUs) between the City and the various employee units that represent City employees.
o
Paying employees more than what they are authorized to be paid belies a transparent compensation system. Furthermore, paying City employees more than what they are authorized to be paid may constitute a costly and unauthorized gift of public funds to individual employees from the City and Oakland taxpayers.
Recommendations
Given the investigation results noted in this report, we recommend the City Administration:
1. Conduct a Citywide review of overtime formulas for sworn and non-sworn employees to identify the extent of unauthorized payments.
2. Identify and pursue the adoption and implementation of authoritative overtime formulas that align with and do not exceed FLSA guidelines. For public accountability and transparency, the methodology of the formulas should be documented and publicly available.
3. Consult with the City Attorney’s Office to identify how to address past payments.
4. Address the recommendations in this report at a public meeting in the near term.
4 Overtime Methodologies
To demonstrate how the City’s formulas for calculating FLSA Overtime Premium Pay differed from FLSA guidelines, and led to the City paying employees more than was authorized, this section and Appendix A highlight an actual Public Works employee’s compensation for a single two -week pay period in 2023. This featured employee – who had an annual salary of $127,691.20 – was paid a total of $24,190.74 for the two -week pay period. Under FLSA guidelines, the employee should have been paid $10,054 FLSA Overtime Pay ($5,718 for the first week and $4,336 for the second week). However, the employee was paid $5,649.19 more than what was required by FLSA.
Exhibit 1: Actual Compensation Data of an Actual Public Works Employee for One Week in 2023 Annual Salary $127,691.20
Hourly Pay (based on 2,080 work week) $61.39
Premium Pay $1,841.77
Regular Hours Worked 40
Overtime Hours Worked 56.25
Source: Summary based on the Auditor’s review and analysis City payroll records.
The City of Oakland Uses Formulas for Calculating FLSA Overtime Premium Pay that D iffer from FLSA Guidelines, Resulting in Payments that Exceed FLSA Requirements
The City’s calculations of the following pay elements differ from FLSA’s Guidelines:
1. Regular Rate of Pay
2. FLSA Overtime Pay
The formulas used to calculate these pay elements individually contribute to excess payments, and the interaction resulted in excess FLSA Overtime Premium Pay, as described and detailed in the following subsections.
Regular Rate of Pay
The Regular Rate of Pay is meant to reflect the average hourly earnings for all hours worked in a work week including overtime hours. Under FLSA guidelines, Regular Rate of Pay is calculated by dividing Total Compensation – including compensation elements like shift differential, standby, bilingual, acting, special assignment, and various other types of pay (except for statutory exclusions) – by Total Hours Worked. By contrast, we found that the City divides Premium Pay by 40 hours and adds the Base Rate of Pay. In the case of the actual Public Works employee whose actual payroll records we are using throughout this report, the FLSA formula resulted in $80.53, as opposed to the City’s formula which resulted in a Regular Rate of Pay that was $107.44 per hour. This is a difference of $26.91, or 33 percent (See Appendix A).
FLSA Overtime Pay
Under FLSA Guidelines, FLSA Overtime Pay is calculated by multiplying the Base Rate of Pay by the number of overtime hours worked, and adding the Regular Rate of Pay multiplied by the number of overtime hours worked multiplied by half. By contrast, we foun d that the City’s calculation relies solely on the Regular Rate of Pay – which as stated above is inflated, and omits the Base Rate of Pay. Specifically, the City calculates FLSA Overtime Pay by multiplying the inflated Regular Rate of Pay by the number of overtime hours worked and then multiplying the result 5 by one and a half. In the case of the actual Public Works employee whose actual payroll records we are using throughout this report, the FLSA formula resulted in an FLSA Overtime Pay of $5,718. 10, as opposed to the City’s formula which resulted in a FLSA Overtime Pay o f $9,064.94. This is a difference of $3,346.84, or 59 percent (See Appendix A).
FLSA Overtime Premium Pay
FLSA Overtime Premium Pay is the difference between FLSA Overtime Pay and overtime pay calculated using the Base Rate of Pay. This premium applies to City employees because the City’s payroll system calculates overtime based on base rates, requiring the City to pay an additional overtime premium.
In the case of the Public Works employee featured in Exhibits 1, this FLSA Overtime Premium Pay calculation resulted in a payment of $3,885. 16 for the one- week pay period, as opposed to the $538.32 required by FLSA. This is a difference of $3,346.84, or 622 percent (See Appendix A). 6 Appendix A
The Cumulative Effects of the City’s Formulas for Regular Rate of Pay, FLSA Overtime Pay, and FLSA Overtime Premium Pay, and the Resulting Inflated FLSA Overtime Premium Pay. As a reminder, here is the actual compensation data of an Actual Public Works employee:
Annual Salary $127,691.20
Hourly Pay (based on 2,080 work week) $61.39
Premium Pay $1,841.77
Regular Hours Worked 40
Overtime Hours Worked 56.25
FLSA Guidelines City of Oakland's Method Base Rate of Pay (hourly) $61.39 $61.39 Yearly Annual Salary / Total Annual Hours Worked Premium Pay $1,841.77 $1,841.77 Premium Pay
Base Rate * 40 Hours $2,455.60 $2,455.60 Base Rate * 40 Hours Base Rate * OT Hours $3,453.19 $3,453.19 Base Rate * OT Hours Total Compensation $7,750.56 $7,750.56 Total Compensation Regular Rate of Pay (hourly)
Total Compensation / Total Hours Worked $80.53 $107.43 (Premium Pay/40) + Base Rate Difference $26.91 City's Regular Rate of Pay is 33% higher than what is required.
FLSA Overtime Pay
(Base Rate * OT Hours) * 1.0 $3,453.19 $6,042.94 (City's Regular Rate * OT Hours) * 1.0 (Regular Rate * OT Hours) * 0.5 $2,264.91 $3,022.00 (City's Regular Rate * OT Hours) * 0.5 (Base Rate * OT Hours) + (Regular Rate * OT
Hours) * 0.5 $5,718.10 $9,064.94 (City's Regular Rate * OT Hours) * 1.5 Difference $3,346.84 City's FLSA Overtime Pay is 59% higher than what is required’
FLSA Overtime Premium Pay
Overtime Pay calculated with Base Rate $5,179.78 $5,179.78 Overtime Pay Calculated with Base Rate (FLSA Overtime Pay) - (Overtime Pay calculated
with Base Rate) $538.32 $3,885.16 (FLSA Overtime Pay) - (Overtime Pay Calculated with Base Rate)
Difference $3,346.84 City overpaid the employee by 622% Source: Auditor formulas and calculations, based on the Auditor’s review and analysis of FLSA requirements and City payroll records.
7 Appendix B
Seven-year summary of excess FLSA Overtime Premium Pay for Public Works Department by Division between January 2018 through May 2024
Department of Public Works
Years (Payment Date)
2018 2019 2020 2021 2022 2023 2024* Total
Sewer System Maintenance $59,545 $76,633 $85,717 $101,396 $107,978 $110,783 $76,060 $618,114 Tree Services $18,906 $51,387 $28,064 $41,823 $37,866 $42,964 $8,509 $229,521 Illegal Dumping $13,756 $18,741 $19,359 $35,129 $44,498 $70,341 $20,970 $222,794 Equipment Services Administration $6,368 $11,185 $13,733 $25,881 $30,533 $29,013 $12,382 $129,094 Street Cleaning $17,981 $7,386 $3,140 $7,818 $4,520 $24,140 $11,887 $76,871 Graffiti Abatement & Rapid Response $8,864 $5,649 $2,106 $3,439 $5,507 $8,285 $11,971 $45,821 Storm Drain Maintenance $5,318 $7,057 $3,254 $4,977 $2,778 $7,329 $1,692 $32,405 Landscape Maintenance $1,700 $1,408 $2,630 $3,904 $1,744 $5,639 $1,578 $18,604 Facilities: Maintenance $273 $511 $549 $386 $1,137 $1,847 $195 $4,898 Facilities: Electrical/ Project $24 $321 $1,215 $1,057 $987 $966 $201 $4,770 Facilities: Roving Custodial - OPR $358 $183 $266 $452 $2,683 $232 $4,173 Facilities: Hall of Justice Complex $209 $135 $664 $823 $663 $733 $12 $3,240 Facilities: Civic Center Complex $279 $133 $1,036 $29 $1,144 $38 $2,660 Facilities: Plant Operations $5 $446 $66 $62 $296 $245 $32 $1,151 Litter Enforcement $2 $14 $38 $174 $345 $29 $603
Facilities: Structural $214 $54 $141 $14 $3 $426
Facilities: Administration $35 $11 $18 $65
Buildings Structural $49 $49
Buildings Electrical & Painting $45 $45
Construction Management and
Material Testing $1 $7 $18 $7 $32
Sanitary Sewer Design $12 $1 $5 $18
Facilities: Custodial - OPL $4 $4
Director and Human Resources Unit
Total $133,259 $181,589 $160,980 $228,049 $239,207 $306,476 $145,798 $1,395,359 Source: Auditor analysis of data from Oracle, the City’s financial management system. *Data included through May 2024
8 Seven-year summary of the number of Public Works Department employees who received FLSA Overtime P remium Pay between January 2018 through May 20241
Years 2018 2019 2020 2021 2022 2023 2024*
Employee Count 180 212 182 194 193 214 166
Source: Auditor analysis of data from Oracle, the City’s financial management system. *Data included through May 2024
1 The majority of employees have received the FLSA Overtime Premium Pay in each year since 2018. This results in overlapping counts, where individual employees may be recorded in multiple years. Consequently, the cumulative total of employees receiving the premium across all years may exceed the annual counts when aggregated. 9 Appendix C
Seven-year summary of excess FLSA Overtime Premium Pay for the Department of Transportation by Division between January 2018 through May 2024
Department of Transportation Years (Payment Date)
2018 2019 2020 2021 2022 2023 2024* Total
Great Streets Maintenance Asphalt $16,490 $2,365 $6,609 $11,733 $9,458 $29,452 $11,333 $87,441 Complete Streets Maintenance $4,324 $4,069 $8,729 $12,994 $25,802 $15,558 $7,558 $79,035 Great Streets Maintenance Concrete and Guardrails $7,083 $3,100 $2,725 $2,213 $2,367 $21,267 $6,883 $45,638 Major Corridor Multimodal Operations $745 $3,102 $3,376 $3,743 $4,018 $2,384 $680 $18,048 Parking Enforcement $139 $766 $636 $2,573 $1,155 $8,636 $3,244 $17,150 Parking Meter Repair $5,078 $761 $209 $264 $181 $6,493 Street Lighting Maintenance $322 $1,765 $1,663 $1,823 $1,074 $562 $670 $7,880 Great Streets Maintenance Admin $5 $6,937 $49 $6,991 ROW Management $134 $322 $207 $544 $319 $91 $34 $1,652
Parking Management Admin $236 $506 $742
Survey $509 $509
Traffic Capital Projects $346 $99 $46 $492
Complete Streets Planning & Project Development $67 $44 $1 $113 Complete Streets Pavement & Sidewalk Management $26 $33 $37 $97 Street Lighting Engineering $10 $10
Complete Streets Design
Total $35,175 $23,522 $24,756 $35,982 $44,453 $77,989 $30,414 $272,291 Source: Auditor analysis of data from Oracle, the City’s financial management system. *Data included through May 2024
Seven-year summary of the number of Department of Transportation employees who received FLSA Overtime Premium Pay between January 2018 through May 20242
Years 2018 2019 2020 2021 2022 2023 2024*
Employee Count 70 85 70 68 67 76 57
Source: Auditor analysis of data from Oracle, the City’s financial management system. *Data included through May 2024
2 The majority of employees have received the FLSA Overtime Premium Pay in each year since 2018. This results in overlapping counts, where individual employees may be recorded in multiple years. Consequently, the cumulative total of employees receiving the premium across all years may exceed the annual counts when aggregated. 10 Appendix D
Summary table showing the average, median, and maximum overpayment per pay period for the combined paychecks of the Departmen t of Transportation and Public Works.
Per Pay Period
Year Average Maximum Median
2018 $6,844 $15,175 $7,323
2019 $7,646 $16,580 $7,016
2020 $6,061 $11,576 $6,022
2021 $10,155 $16,170 $11,003
2022 $10,910 $17,034 $12,102
2023 $14,787 $22,550 $15,954
2024* $17,621 $23,595 $17,851
Source: Auditor analysis of data from Oracle, the City’s financial management system. *Data included through May 2024
11 Appendix E
Seven-year summary of excess FLSA Overtime P remium Pay for the Public Works Department by Union Representation and Job Classification between January 2018 through May 2024
Union
Rep.
Years (Payment Date)
Job Classification 2018 2019 2020 2021 2022 2023 2024* Total IE1
Electrician $24 $47 $101 $87 $35 $23 $317
SB1
Auto Equipment Mechanic $246 $380 $1,781 $13 $3,068 $2,267 $86 $7,839 Carpenter $124 $3 $4 $3 $134
Construction & Maintenance
Mechanic $270 $460 $465 $161 $535 $459 $46 $2,396
Electro-Mechanical Machinist $213 $735 $278 $136 $21 $1,383 Equipment Body Repair Worker $172 $139 $543 $27 $132 $1,013 Heavy Equipment Mechanic $4,990 $7,725 $7,962 $23,123 $25,918 $24,737 $12,127 $106,582 Heavy Equipment Operator $1,564 $957 $1,229 $2,515 $2,468 $4,130 $682 $13,545 Maintenance Mechanic $112 $73 $46 $15 $14 $11 $271
Painter $5,068 $3,018 $25 $96 $68 $40 $5,075 $13,389
Plumber $63 $13 $98 $31 $43 $15 $27 $290
Stationary Engineer $11 $50 $31 $83 $8 $16 $199
SC1
Auto Equipment Service Worker $301 $210 $37 $53 $96 $698 Construction Inspector (Field) $12 $1 $5 $18
Custodian $358 $183 $232 $456 $320 $190 $1,739
Custodian, PPT
Environmental Enforcement
Officer $92 $22 $132 $279 $304 $13 $842
Equipment Parts Technician $408 $964 $995 $1,307 $648 $1,147 $5,469 Gardener Crew Leader $250 $454 $77 $604 $257 $820 $103 $2,564 Gardener II $151 $390 $625 $449 $169 $628 $630 $3,043
Heavy Equipment Service
Worker $172 $830 $160 $617 $344 $308 $15 $2,446
Irrigation Repair Specialist $12 $3 $1 $672 $688
Park Attendant, PPT $3 $268 $271
Park Equipment Operator $2 $104 $47 $128 $1,169 $9 $1,459
Public Works Maintenance
Worker $8,563 $12,255 $9,406 $16,755 $19,476 $26,285 $11,005 $103,745 Sewer Maintenance Leader $21,843 $38,750 $32,946 $32,648 $35,662 $38,729 $23,625 $224,202 12 Source: Auditor analysis of data from Oracle, the City’s financial management system. *Data included through May 2024
Union
Rep.
Years (Payment Date)
Job Classification 2018 2019 2020 2021 2022 2023 2024* Total Sewer Maintenance Worker $20,267 $35,428 $27,634 $22,769 $29,148 $22,218 $15,390 $172,854
Street Maintenance Leader $12,416 $13,392 $14,887 $22,717 $26,511 $42,015 $8,600 $140,538 Street Sweeper Operator $6,432 $7,000 $2,482 $7,013 $3,912 $8,987 $4,754 $40,581 Tree High Climber $5,209 $15,392 $3,562 $2,593 $26,757 Tree Trimmer $9,353 $19,858 $16,329 $26,101 $26,557 $26,320 $5,995 $130,512 Tree Worker $41 $3,755 $346 $4,141
SI1
Food Program Driver, PT $160 $8 $168
Lifeguard, PT $41 $16 $57
Recreation Attendant I, PT $7 $7
Recreation Attendant II, PT $5 $5
TF1
Engineer, Assistant I (Office) $4 $4
Engineer, Assistant II (Office) $1 $2 $7 $4 $15
Engineer, Civil (Office) $10 $2 $12
UH1
Arboricultural Inspector $2,559 $7,363 $5,285 $9,346 $6,816 $7,797 $660 $39,826
Construction & Maintenance
Supv I $13 $326 $1,203 $1,158 $1,465 $1,002 $326 $5,492
Construction Inspector,
Supervisor II $1 $1
Custodial Services Supervisor I $3,664 $58 $3,723
Custodian Supervisor $62 $62
Equipment Services
Superintendent $320 $15 $299 $135 $768
Equipment Supervisor $23 $541 $520 $415 $34 $26 $1,558 Heavy Equipment Supervisor $56 $178 $637 $102 $185 $112 $19 $1,289 Park Supervisor I $42 $42 $614 $263 $746 $316 $2,023
Park Supervisor II $269 $395 $1,257 $2,541 $922 $1,603 $520 $7,508 Public Works Supervisor I $21,626 $3,210 $12,085 $30,973 $40,426 $57,673 $36,852 $202,846 Public Works Supervisor II $7,671 $1,376 $12,979 $17,179 $7,573 $20,665 $16,606 $84,049 Stationary Engineer, Chief $204 $810 $825 $1,893 $905 $2,084 $18 $6,739 Tree Supervisor I $1,515 $3,535 $251 $1,850 $7,151
Tree Supervisor II $1,267 $5,240 $2,637 $3,784 $4,452 $3,243 $1,508 $22,131 Total $133,259 $181,589 $160,980 $228,049 $239,207 $306,476 $145,798 $1,395,359 13 Appendix F
Seven-year summary of FLSA Overtime Premium Pay for the Department of Transportation by Union Representation and Job Classification between January 2018 through May 2024
Union Rep.
Years (Payment Date)
Job Classification 2018 2019 2020 2021 2022 2023 2024* Total IE1
Electrician $966 $4,961 $5,057 $5,556 $5,038 $2,639 $1,178 $25,396 Electrician Helper $1 $4 $16 $10 $19 $4 $10 $64
Electrician Leader $222 $6 $35 $303 $68 $634
SB1
Concrete Finisher $336 $7 $1,148 $1,817 $3,308
Heavy Equipment Operator $334 $1,624 $1,286 $911 $193 $528 $237 $5,114 Parking Meter Repair Worker $2,508 $711 $180 $68 $3,467 Traffic Painter $1,101 $1,016 $2,800 $7,398 $7,001 $1,676 $20,992 SC1
Construction Inspector (Field) $96 $256 $207 $539 $270 $88 $34 $1,491 Construction Inspector, Sr (Field) $38 $66 $104
Parking Control Technician $29 $860 $1,097 $2,573 $781 $7,677 $2,879 $15,896 Parking Control Technician, PPT $8 $8 $298 $315
Public Works Maintenance Worker $10,100 $8,868 $7,988 $7,746 $6,985 $21,653 $7,987 $71,327 Sign Maintenance Worker $751 $143 $2,529 $634 $156 $4,213 Street Maintenance Leader $4,905 $4,680 $3,055 $1,626 $2,588 $5,212 $6,737 $28,804 Surveying Technician (Field) $35 $35
Surveying Technician, Sr (Field) $495 $495
TF1
Electrical Construction & Maint
Planner $10 $10
Engineer, Assistant II (Office) $31 $49 $80
14 Union Rep.
Years (Payment Date)
Job Classification 2018 2019 2020 2021 2022 2023 2024* Total TW1
Transportation Planner II $2 $1 $4
Transportation Planner III $65 $77 $38 $180
UH1
Chief of Party $263 $263
Construction Inspector Sup (Field) $3 $3
Electrical Supervisor $94 $94
Parking Enforcement Supervisor I $102 $134 $45 $374 $661 $365 $1,681 Public Works Supervisor I $12,886 $184 $489 $8,888 $19,825 $35,391 $10,658 $88,321 Total $35,175 $23,522 $24,756 $35,982 $44,453 $77,989 $30,414 $272,291 Source: Auditor analysis of data from Oracle, the City’s financial management system. *Data included through May 2024
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