Meeting of the Board of Regents | December 2007
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THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234 |
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Subcommittee on Audits
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Theresa E. Savo
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Board of Regents Oversight – Financial Accountability
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November 16, 2007
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Goal 5
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Executive Summary
Issues for Discussion
Three items are presented for discussion with the Members of the Subcommittee on Audits including:
- Audit of the Financial Statements of New York State including the State Education Department
- Proposed Process for Providing Information to the Regents Subcommittee on Audits
- Completed Audits
Reason(s) for Consideration
Update on Activities
Proposed Handling
Discussion and Guidance
Procedural History
The information is provided to assist the Subcommittee in carrying out its oversight responsibilities related to audits of financial and reporting practices; performance audits or reviews; ethical conduct issues arising from audits; internal controls; and compliance with laws, regulations, and policies.
Background Information
1. Audit of the Financial Statements of New York State including the State Education Department – The Department’s revenues and expenses are not audited separately, but are included in the audit of New York State. The independent auditors provided an unqualified opinion on the 2006-2007 financial statements for New York State. This means the financial statements present fairly, in all material respects, the financial position of New York State. The report can be used to assist the Board of Regents in helping fulfill its oversight responsibilities for the Department’s financial and reporting practices.
2. Proposed Process for Providing Information to the Regents Subcommittee on Audits – The Members of the Subcommittee have requested a more efficient method of communicating the results of audits in order to carry out their responsibility. Department staff will discuss such an approach.
3. Completed Audits
Reports are provided as follows:
Office of Audit Services (OAS)
Orleans-Niagara BOCES Pre-Kindergarten Special Education Programs
New York City Department of Education Special Education Preschool Audit of Special Kids Intervention Program, Inc. (SKIP)
VESID Rochester District Office
Office of the State Comptroller
Averill Park Central School District
Avon Central School District
Bainbridge-Guilford Central School District
Ballston Spa Central School District
Bronxville Union Free School District
Cleveland Hill Union Free School District
Clymer Central School District
Edwards-Knox Central School District
Elmsford Union Free School District
Gilbertsville-Mount Upton Central School District
Haldane Central School District
Hampton Bays Union Free School District
Holland Patent Central School District
LaFayette Central School District
Lewiston-Porter Central School District
Massena Central School District
Mexico Academy and Central School District
Minerva Central School District
Northeastern Clinton Central School District
Onondaga-Cortland-Madison BOCES Regional Information Center (RIC)
Peekskill City School District
Pine Plains Central School District
Putnam Central School District
Quogue Union Free School District
Randolph Academy Union Free School District
St. Johnsville Central School District
Schodack Central School District
Sewanhaka Central High School District
Sherburne-Earlville Central School District
Sherrill City School District
Tonawanda City School District
Victor Central School District
Waterville Central School District
Wellsville Central School District
Westminster Community Charter School
Wheelerville Union Free School District
Yorktown Central School District
Recommendation
For items one (Audit of the Financial Statements of New York State) and two (Proposed Process for Providing Information to the Regents Subcommittee), the advice and guidance of the Members of the Subcommittee is sought. For item three (Completed Audits), no further action is recommended.
Timetable for Implementation
N/A
The following materials are attached:
- Roadmap
- Minutes of the October Meeting (Attachment I)
- Summary of Findings (Attachment II)
- Audit Report Abstracts (Attachment III)
REGENTS SUBCOMMITTEE ON AUDITS
MEETING ROADMAP
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Opening Remarks |
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Chair |
2 |
Review Agenda/Minutes (Attachment I) |
Approval |
Conway |
5 |
Follow-up on Previous Meetings |
Information |
Conway |
5 |
Audit of the Financial Statements of New York State |
Information |
KPMG Staff |
20 |
Proposed Process for Providing Information to the Regents Subcommittee on Audits |
Information/ Acceptance |
Conway |
15 |
Audit Report Abstracts (Attachment III) |
Questions Addressed |
SED and OSC Staff |
10 |
Next Session |
Preview |
Staff |
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Your Subcommittee on Audits held its scheduled meeting on October 22, 2007.
Subcommittee Members in Attendance:
Regent Geraldine D. Chapey, Chair
Regent Arnold Gardner
Regent Joseph Bowman Jr.
Other Members of the Board of Regents in Attendance:
Regent Roger B. Tilles
Discussion Items
- Regent Chapey opened the meeting acknowledging the importance of the audit function in determining how money is spent and the effectiveness of the spending. She mentioned two pieces of legislation with a bearing on the importance of audits.
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- The Sarbanes-Oxley legislation is now five years old and has created major changes nationally.
- The 2005 legislation, the School Accountability Act, calling for Office of the State Comptroller (OSC) audits of all school districts, BOCES, charter schools, and other educational institutions.
- The members were provided with the Annual Report on the Activities of the Regents Subcommittee on Audits for the period from September 2006 through July 2007. During that period, the Subcommittee received 211 audit reports consisting primarily of school districts, as well as BOCES and State Education Department programs. Other accomplishments of the Subcommittee included:
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- The initiation of a process of meetings among representatives from the Office of Audit Services, the Office of Counsel, the Office of Operations and Management Services and the Office of Education-P-16 to review audit reports to be presented and highlight issues and objectives, as well as to initiate out-reach to school districts and other auditees to address their audit issues.
- The issuance of a revised Statement on the Governance Role of a Trustee or Board Member.
- The members also discussed a revised approach to providing the Subcommittee members with the information they need to carry out their oversight responsibility. An alternative for sharing relevant information will be presented at the December meeting.
- The Subcommittee was presented with the Office of Audit Services Annual Report of Activities for the first year of its two-year audit plan. Staff highlighted some of the accomplishments of the Office including:
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- Nine audits issued.
- Review of school districts and BOCES financial statements.
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- 728 financial statements reviewed
- 23 letters sent to districts in fiscal stress
- Corrective action plans reviewed for Federal Single Audit findings.
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- 245 management decisions issued
- Review of 895 corrective action plans required by Section 170.12 of the Regulations.
- Review of private college and university independent financial statements for degree granting 2- and 4-year institutions.
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- 162 college and university analysis completed
- 41 memos sent to the Office of Higher Education
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- 81 proprietary school analysis completed
- 81 memos sent to the Bureau of Proprietary School Supervision
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- Fraud, Waste and Abuse hotline.
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- 190 resolved cases
- Violent and Disruptive Incident Reporting (VADIR).
- Forty-nine audits were presented this month:
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- Office of the State Comptroller - 39 audits
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- Central Square Central School District
- Clifton-Fine Central School District
- Explore Charter School
- Frewsburg Central School District
- Gates Chili Central School District
- George Junior Republic Union Free School District
- Greenwich Central School District
- Hannibal Central School District
- Harpursville Central School District
- Harrisville Central School District
- Hermon-DeKalb Central School District
- Hopevale Union Free School District – 2 reports
- Ilion Central School District
- Jamesville-DeWitt Central School District
- Jefferson Central School District
- Jericho Union Free School District
- Keene Central School District
- Leake & Watts Services, Inc.
- Mamaroneck Union Free School District
- Mayfield Central School District
- Middletown – Enlarged City School District
- Mohawk Central School District
- Morrisville-Eaton Central School District
- Nyack Union Free School District
- Onondaga Central School District
- Poughkeepsie City School District
- Ramapo Central School District
- Ravena-Coeymans-Selkirk Central School District
- Red Hook Central School District
- Saranac Central School District
- Schalmont Central School District
- Sisulu-Walker Charter School of Harlem
- South Glens Falls Central School District
- Stamford Central School District
- Trumansburg Central School District
- VADIR (Reporting of Violent and Disruptive Incidents by Public Schools)
- Waterford-Halfmoon Union Free School District
- Worcester Central School District
- Office of Audit Services - 8 audits
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- Clinical Associates of the Finger Lakes
- New York State Museum Institute
- Our Preschool Learning Adapted to Communication and Education (OUR P.L.A.C.E. School)
- The Early Advantage for Children with Handicaps, Inc. (TEACH)
- VESID Syracuse District Office
- New York State Association of Retarded Citizens, Inc., Yates County Chapter – 3 reports
- New York City Department of Education - 1 audit
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- FY05 & FY06 Internal Audits of Schools of the Department of Education of the City of New York
- City of New York Office of the Comptroller - 1 audit
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- Audit Report on the Department of Education’s Reporting of Violent, Disruptive, and Other Incidents at New York City Public High Schools
Follow-up Items
- Develop policy driven process to deliver audit results to Regents in a more useful format.
- Follow-up with Office of State Assessment on method to identify schools submitting altered grades.
Audit |
Procurement |
Capital Assets |
Claims Processing |
Payroll |
Cash |
Financial Reporting |
Information Technology |
Extra Classroom Activity Fund |
Budgeting |
Conflict of Interest |
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Orleans Niagara BOCES |
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Special Kids Intervention Program, Inc. (SKIP) |
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VESID Rochester District Office |
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Averill Park Central School District |
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Avon Central School District |
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Bainbridge-Guilford Central School District |
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Ballston Spa Central School District |
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Bronxville Union Free School District |
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Cleveland Hill Union Free School District |
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Clymer Central School District |
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Edwards-Knox Central School District |
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Elmsford Union Free School District |
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Gilbertsville-Mount Upton Central School District |
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Haldane Central School District |
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Hampton Bays Union Free School District |
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Holland Patent Central School District |
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Lafayette Central School District |
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Lewiston-Porter Central School District |
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Massena Central School District |
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Mexico Academy and Central School District |
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Minerva Central School District |
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Northeastern Clinton Central School District |
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Onondaga-Cortland-Madison BOCES |
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Peekskill City School District |
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Pine Plains Central School District |
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Putnam Central School District |
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Quogue Union Free School District |
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Randolph Academy Union Free School District |
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St. Johnsville Central School District |
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Schodack Central School District |
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Sewanhaka Central High School District |
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Sherburne-Earlville Central School District |
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Sherrill City School District |
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Tonawanda City School District |
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Victor Central School District |
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Waterville Central School District |
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Wellsville Central School District |
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Westminster Community Charter School |
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Wheelerville Union Free School District |
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Yorktown Central School District |
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Summary of Current and Prior Audit Findings
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May 2007 |
June 2007 |
July 2007 |
October 2007 |
December 2007 |
Total |
Procurement |
9 |
11 |
12 |
20 |
12 |
64 |
Capital Assets |
10 |
1 |
2 |
4 |
0 |
17 |
Claims Processing |
13 |
3 |
12 |
17 |
16 |
61 |
Payroll |
12 |
3 |
11 |
20 |
17 |
63 |
Cash |
6 |
2 |
8 |
15 |
14 |
45 |
Financial Reporting |
12 |
3 |
2 |
16 |
6 |
39 |
Information Technology |
10 |
10 |
9 |
14 |
15 |
58 |
Capital Construction |
2 |
1 |
1 |
0 |
0 |
4 |
Extra Classroom Activity Fund |
1 |
1 |
0 |
1 |
1 |
4 |
Segregation of Duties |
0 |
0 |
3 |
0 |
15 |
18 |
Budgeting |
2 |
3 |
0 |
1 |
1 |
7 |
Conflict of Interest |
0 |
0 |
0 |
4 |
3 |
7 |
Other |
0 |
2 |
0 |
0 |
0 |
2 |
Total |
77 |
40 |
60 |
112 |
100 |
389 |
Definitions of Categories
Procurement – includes findings related to lack of a contract, failure to competitively bid, failure to use purchase orders, lack of segregation of duties, no approval of the purchase and a lack of documentation.
Capital Assets – includes failure to have a manager responsible, lack of policy, and inappropriate disposal.
Claims Processing – includes claims being paid without adequate documentation, failure to audit the claim, an untrained claims auditor, and a claims auditor that lacks independence.
Payroll – includes a lack of segregation of duties in the payroll process, no policy and procedures and inappropriate payments to district administrators including leave accruals and health benefits.
Cash – includes poor control of cash and failure to prepare bank reconciliations.
Financial Reporting – includes inaccurate accounting statements, such as, an overstated fund balance, fund balance exceeding the legal limit, and general fund transfers without voter approval.
Information Technology – includes lack of a disaster recovery plan, failure to back up information, inappropriate or undocumented user rights, inappropriate or missing password protection, and no policy and procedures.
Capital Construction – includes a lack of detailed accounting records related to a capital project, undocumented expenses, inappropriate and unapproved change orders.
Extra Classroom Activity Funds – includes poor accounting over funds and no documentation of expenses.
Conflict of Interest – includes personal conflicts of board members, district officials and district employees where they have an interest in a contract, where they have the power, or may appoint someone who has the power to negotiate, authorize, approve, prepare, make payment or audit bills or claims of the contract.
Budgeting – includes poor revenue projections and use of fund balance.
Segregation of Duties – includes weakness in control caused by individuals having responsibility for incompatible functions.
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Orleans-Niagara (ON) BOCES had overstated reimbursable expenses for the Pre-K Special Education programs in 2000-2001 by $117,054 and understated reimbursable expenses for 2003-2004 by $49,982. There were discrepancies in allocation methodology and documentation of allocations related to rent, operation and maintenance, utility and administration costs.
Student absences were also not adequately documented and some key policies were not adopted to guide ON BOCES operations.
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The report's recommendations focused primarily on strengthening the policies and procedures regarding payroll; cash and disbursements; and financial reporting.
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SKIP did not comply with SED regulations which govern the fiscal operations of schools for children with disabilities. It did not properly allocate expenses and did not maintain necessary documentation to support some of its expenses. SKIP also made several accounting and reporting errors and reported non-reimbursable expenses. It is recommended that an adjustment of $23,801 be made to the total reported costs.
Disallowances included computer leasing expenses, unsupported insurance expenses, car leasing, life insurance policies, directors’ salaries and New York City tax expenses. There was also insufficient documentation involving office supplies, postage expenses, and tax expenses. Some funds were also used for non-school related activities.
FTE attendance was not calculated in accordance with regulations. FTEs were decreased for the full-day two-month program by .166 and the ten-month program by .175 and increased for the half-day ten-month program by 1.38. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding financial reporting and payroll.
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One year after the implementation of improved internal controls, the Rochester District office has eliminated the practice of reissuing a counselor code and reduced the number of authorizations issued following the assigned counselor’s departure from state service. They have also reduced the number of backdated authorizations and the number of authorizations issued after a case was closed.
Weaknesses still exist in documenting compliance with written policies regarding van purchases, rebates, purchasing equipment, self-employment, waivers, and home modification.
There were also discrepancies in the documentation of receipt of rebates, refunds, and returned checks in the consumer’s case file. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding procurement and information technology.
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Computer data was not effectively safeguarded because the proper procedures regarding passwords and access were not established. The business office has control over access to the District's computerized financial system and user rights had not been adequately restricted.
There were inadequate internal controls over reimbursements made to, or on behalf of, certain District officials and employees. Seventy-eight claims were paid to 10 administrators, totaling $18,787 and 6 of the administrators were reimbursed $2,410 for benefits and expenses that were not properly authorized or were lacking adequate documentation. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding information technology and payroll.
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The District’s controls over payroll processing and information technology were not appropriately designed or operating effectively.
There were several internal control weaknesses in the business office because there was inadequate segregation of the payroll clerk’s duties.
There were also internal control weaknesses in the computerized financial system. Several users of accounting software have access rights that exceeded requirements of their duties. The treasurer’s electronic signature was not password protected and was widely available to staff. |
The report's recommendations focused primarily on strengthening policies and procedures regarding information technology and payroll processing.
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The treasurer creates the employee records, inputs payroll data, and prepares employees’ paychecks, which does not allow for the proper segregation of duties.
Additionally, the board did not adequately safeguard the District’s computerized data and assets due to lack of policies and procedures related to access controls, physical security, and disaster recovery.
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The report's recommendations focused primarily on strengthening policies and procedures regarding payroll and information technology.
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The District has developed a comprehensive set of procedures establishing an adequate internal control structure over payroll processing. Time sheets, employee records, leave time records, and payroll registers were all examined, and there were no significant deficiencies. Overall, the system was well designed and operating efficiently. |
There were no recommendations.
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The District’s internal control system for cash receipts and disbursements appeared to be appropriately designed and operating effectively. Based on the review, policies and procedures have been adequately implemented, duties are properly segregated, and all received cash is recorded and deposited in a timely manner.
Additionally, the District's controls over purchasing were appropriately designed and operating effectively. Vendors were reviewed and it was found that proper procurement processes were used to select them. The District used proper competitive procedures such as request for proposals and obtaining quotations. |
There were no recommendations.
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Internal controls over the District’s claims processing function are not appropriately designed and are not operating effectively. Board members do not review each claim to ensure that the proper original documentation is attached to the claim.
Additionally, $129,564 in claims was not properly documented. The District’s purchasing policies and procedures contain inconsistencies which make them unclear with respect to the process and dollar amounts for obtaining written quotations.
Internal controls over the District treasurer’s duties were also not operating effectively. The treasurer is responsible for recording receipts; making daily deposits; transferring funds between and from District accounts; signing checks; and preparing, entering, and approving journal entries. All of these duties are done without any oversight or review. Board approved bank reconciliations also incorporated a number of inconsistencies and errors. |
The report's recommendations focused primarily on strengthening policies and procedures regarding claims processing and the segregation of duties.
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There were numerous problems in District financial operations mostly due to poor policies and procedures. District officials deliberately eliminated a key control over wire transfers, and now unlimited transfers of District funds are being allowed by the authorization of one official. Additionally, 66 percent of the accounts in the trust agency fund do not belong there. District officials did not take the time to determine the correct way to handle these accounts.
There were also weaknesses found in the controls for assigning user rights to the computer system, the use of passwords, and the addition and deletion of users from the system. The District has not adopted internal controls for cash transfers and there is no approval or documentation for the monitoring of cash transfers. The District was also able to make $20 million in bank transfers without any authorization.
Twelve separation payments were reviewed and the District inappropriately paid $1,932 to four employees in accumulated sick benefits, and did not appropriately calculate for one employee, resulting in an underpayment of $7,255. |
The report's recommendations focused primarily on strengthening policies and procedures regarding information technology, cash transfers, claims processing, payroll, and the trust and agency fund.
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There were weaknesses in the District’s control over non-payroll disbursement transactions. The business manager/treasurer has unchecked control over the accounting records for non-payroll cash disbursements; has check writing and wire transfer authority; and controls bank reconciliations. He also has full transaction authority and administrator rights to the District’s computerized accounting system.
The board did not implement an adequate internal control system over the auditing, approval, and payment of claims. The business manager/treasurer improperly paid $500,000 for claims that he did not present to anyone else for audit and authorization.
The board also approved District contracts for the purchase of liability insurance coverage through an agent who is the spouse of a board member which was not previously disclosed and therefore, violates General Municipal Law. |
The report's recommendations focused primarily on strengthening policies and procedures regarding cash disbursements, claims, and conflicts of interest.
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The District’s accounting for tax certioraris was not in compliance with generally accepted accounting principles. The amounts encumbered have not been based upon court decisions or judgments and have consistently exceeded annual payments. It appears that the District has encumbered funds instead of establishing a reserve to circumvent the restrictions placed on reserve funds.
The Board also has not established formal policies to address potential computer-related disasters and backup tapes were not stored off-site. Passwords were not required to be changed, and locking screens were disabled on five of the six computers. |
The report's recommendations focused primarily on strengthening policies and procedures regarding financial transactions and information technology.
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There were weaknesses in the design and operation of the internal controls over cash receipts and disbursements. The claims auditor does not directly report to the board and is not independent of business office operations. The cash disbursements process does not properly minimize the risk of unauthorized disbursements occurring and being detected. There is also insufficient segregation of duties over the cash receipts process.
Ten sample claims were tested, and six of them did not have supporting evidence that staff solicited the recommended three quotes. The purchases were also approved without the required quotes. |
The report's recommendations focused primarily on strengthening policies and procedures regarding cash receipts, disbursements, and purchasing.
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The District's cash handling procedures appeared to be effective in both design and implementation. Duties were properly segregated and cash transactions were properly initiated, approved, recorded, and documented. There were no discrepancies or inconsistencies. |
There were no recommendations.
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The District officials did not always adhere to board-adopted policies regarding purchasing and credit card use. The District did not solicit requests for proposals when obtaining professional services and paid four professional service providers $107,168 during the 2005-2006 fiscal year without the benefit of competition. A fifth professional, who received $11,605 did not have a contract with the District. Also, the District paid a computer parts vendor $47,630 during the 2005-2006 fiscal year without soliciting competitive bids. There was no proper documentation submitted with $1,704 in credit card charges.
Additionally, the proper policies and procedures were not implemented to safeguard computer data. The business administrator also acts as the purchasing agent and finance system administrator, and has the ability to perform management overrides. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding procurement and information technology.
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There are no written policies and procedures outlining the roles and responsibilities for the claims auditor. The Board failed to conduct a proper audit of claims prior to appointing a claims auditor and failed to provide the claims auditor with a written job description.
There were also numerous occurrences where claims were paid prior to audit and approval by the board or the claims auditor.
Eleven credit card claims ($4,752) were not supported with the appropriate receipts and six claims ($135,605) did not have evidence of an audit by the board or claims auditor. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding claims auditing.
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The employment contract of the former assistant superintendent for business did not clearly explain when leave time provided under the contract was to be considered earned and thereby payable upon separation from the District. The District officials’ interpretation of her contract resulted in a separation payment for unused leave time that reflected the vacation and sick leave that she was entitled to, had she worked the entire year. The District superintendent received payment for unused leave time based on leave earned for a full year, rather than an amount proportionate to her six months of service.
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The report’s recommendation focused primarily on strengthening the policies and procedures regarding separation payments.
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Internal controls over cash receipts and disbursements were not appropriately designed or operating effectively. There were no written policies adopted for cash receipts and no job descriptions provided to staff involved. Duties were not properly segregated, especially in terms of access rights to financial software and wire transfer processes. Additionally, there is no written job description, nor any training provided to the claims auditor.
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The report’s recommendations focused primarily on strengthening policies and procedures regarding cash receipts and disbursements and the segregation of duties.
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District management has not adequately segregated cash disbursement duties. The treasurer can perform most cash recordkeeping and disbursement transactions with little effective oversight. We found that the former claims auditor had not audited 9 of the 35 claims because District procedures (at that time) did not require it.
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The report’s recommendation focused primarily on strengthening policies and procedures regarding segregation of cash disbursement duties.
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There were internal control weaknesses in the District’s operations relating to cash disbursements that could lead to errors or irregularities occurring and not being detected. In addition, the treasurer’s duties were not effectively segregated. The treasurer’s signature is applied to District checks without her direct supervision.
The payroll clerk’s duties are also not properly segregated. Duties include adding new employees, updating salaries, inputting bi-weekly payroll, and directly receiving signed checks.
District computer access controls were also deficient in that many employees have full access to all phases of the District’s computerized financial system. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding cash disbursements, information technology, and payroll.
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The board did not establish control policies and procedures to safeguard the District’s IT system equipment and data. The board’s limited IT policies do not provide adequate overall controls of the District’s technology systems. For example, communications to prohibit the use of web-based e-mail accounts were not supported by an official board policy.
There were no established policies or procedures for creating and administering the user’s network passwords. The District also did not require the computer network connection to time out after a reasonable period of inactivity. |
The report’s recommendations primarily focused on strengthening policies and procedures regarding information technology.
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There were instances where the board had either not established critical internal controls or controls that had been established were not implemented correctly.
In the extraclassroom activity fund, the moneys were not maintained in accordance with the policy. There was no indication that transactions were adequately monitored. The extraclassroom activity fund’s software lacks the controls to prevent sequentially-issued check and receipt numbers from being edited and re-issued. There were 13 cancelled checks with duplicate numbers ($7,482) and two receipts totaling $798 with duplicate receipt numbers.
There are also no written policies and procedures to provide guidance and internal controls for payroll processing; leave time accruals; and cash receipts. The District’s multi-fund bank account also was overstated by at least $21,035 and as much as $78,128 for the period. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding extraclassroom activity funds, financial operations, and information technology.
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The Regional Information Center (RIC) personnel print checks for several school districts using signatures embedded in the software at the RIC. There is no requirement that the treasurer from the school district oversee the printing of checks.
Several of the support staff have access to the financial accounting applications and data of those districts that have their financial data processed and stored by the RIC.
Onondaga-Cortland-Madison BOCES does not perform a complete, regionwide annual inventory of its technological assets or require annual inventories of BOCES equipment.
Lastly, the RIC does not periodically update its disaster recovery plan. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding claims processing, information technology, and financial reporting.
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The board did not establish and implement adequate internal controls over payroll, budget transfers, and claims processing.
There were also significant internal control weaknesses relating to the policies and procedures designed to prevent and detect unauthorized and inaccurate budget transfers. The audit reviewed 33 budget transfers and noted 7 instances where the actual transfers were different from the board-authorized amounts.
The board and District officials also did not adopt formal policies and procedures for processing payroll, especially adding and removing substitute teachers from the payroll system.
Of the 127 separate payments to substitute teachers reviewed, 66 were incorrect. Errors in payments were due to manual calculation by the payroll clerks.
In addition, the claims auditor does not report to the Board. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding budget transfers, payroll, and claims.
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The treasurer’s responsibilities are not properly segregated due to limited personnel. Recently, the District hired an assistant to work with payroll issues and assigned the reconciliation of bank accounts to another employee.
Certain users of the accounting system had unlimited rights to all of the modules, while others had unlimited rights to a limited number of modules. This allows the possibility that staff could make changes without appropriate approval. The District also had not prepared a secure backup plan for financial and student data. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding information technology and cash disbursements.
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After initial testing showing payments of claims prior to audit, the test was expanded to include a total of 79 claims paid in July and August of 2006. Results of the test showed that 40 of the 79 claims amounting to $51,151 were paid without prior audit.
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The report’s recommendations focused primarily on strengthening the policies and procedures regarding claims processing.
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The District has established adequate internal controls over payroll and personal services. We reviewed payroll related payments to all 28 District employees and all employees were paid in accordance with their respective salary agreements, collective bargaining agreements, and board resolutions. |
There were no recommendations.
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The board has not established effective internal controls over its claims processing function and has not adopted any written procedures for the duties of the claims auditor.
Thirty-five claims were reviewed ($145,418), and exceptions were found with 32 of them ($137,514). The deficiencies included lack of proper documentation, itemization of expenses, evidence of approval by the department head, evidence of approval by the purchasing agent, evidence that goods or services were received, and/or an indication that the claim was a proper District expense.
In addition, 47 credit card purchases amounting to $4,029 were also reviewed, and found 33 purchases worth $3,295 with exceptions.
Officials should also strengthen controls over the District’s payroll function. The superintendent’s duties are not properly segregated, such as certifying payroll, authorizing absences and approving leave time requests. The former superintendent authorized employees to leave earlier without charging leave time throughout the 2005-2006 fiscal year. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding claims processing and payroll.
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The system of internal controls over purchasing was well designed and compliance with the system was adequate. Additionally, purchase orders were properly approved prior to making each purchase, claims were properly audited by the District prior to payment, and all purchases included documentation that indicated a specific District purpose. |
There were no recommendations.
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The audit examined the District's compliance with the terms of the Fiscal Accountability Legislation. The District is in compliance with requirements related to claims auditing, board training, requests for proposals for independent auditing services, and audit committees. However, from July 1, 2006 through March 23, 2007, the District expended $973,000 on services provided by Questar III (inter-municipal agreement with Rensselaer, Columbia and Greene Counties BOCES). Because of the material nature of these payments, a Questar III employee serving as the internal auditor would not be independent in performing the internal audit function. The current arrangement is not acceptable because significant programs or services being evaluated as part of the internal audit function include the services provided to the District by Questar III, the employer of the internal auditor. |
The report’s recommendation focused primarily on strengthening the policies and procedures regarding claims processing.
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There were discrepancies in the District’s controls and procedures over procurement of professional services, computer operations, and disposition of capital assets.
District officials did not consistently follow the board’s policy requiring competition of Requests for Proposals when awarding contracts for professional services. The District paid 19 professional service providers a total of over $1.8 million without soliciting any form of competition, and 21 of the services procured were not approved by the board. Also, $355,554 in services were rendered without a contract.
The District has not established a disaster recovery plan, or a computer security policy with protocols, procedures, and controls for maintaining a secure and reliable IT system.
The function of the financial software is not properly segregated from the accounting function. The senior accountant who maintains the District’s accounting records is also the system administrator of the District’s financial software. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding procurements and information technology.
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The board did not adequately segregate the treasurer's duties over cash disbursement or implement compensating controls. The District treasurer prepares and enters journal entries and performs electronic bank wire transfers to outside agencies and electronic transfers to District bank accounts. She also deposits cash receipts and prepares the monthly bank reconciliations. There is inadequate segregation of duties in payroll processing to ensure that wage and benefit payments are in accordance with board authorizations and approved employment contracts. |
The report's recommendation focused primarily on strengthening policies and procedures regarding cash and payroll.
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The District has limited controls and oversight over the check signing machine, the treasurer’s signature plate, and the blank manual check stock. The treasurer also had not compared check payments to certified warrants or payrolls for any of the District check payments prior to disbursement.
There was lack of segregation of duties for the senior account clerk and the payroll clerk positions.
Additionally, the claims auditor was not provided a written job description.
The District has not established adequate internal control over cafeteria sales receipts. Not all moneys received were ran through the cash register. There is no reconciliation of moneys received. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding cash, payroll, and claims processing.
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The District did not implement sufficient internal controls, nor did they follow established policies for claims processing. Of the 79 claims examined, the claims auditor did not review 44 percent of them prior to payment. The claims also did not contain adequate documentation such as itemized receipts or sufficient explanations to determine if expenditures were appropriate. The District also lacks policies and procedures for travel, expense reimbursement, gift and prepaid phone cards.
The District also did not follow proper procedures for donated computer equipment. Of the 149 donated computers, only 34 of them were placed in classrooms. These 34 computers were also the only donated computers that the District tracked by service tag and location. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding claims and information technology.
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District officials have not developed written procedures or regulations to supplement board policy on procurement of goods and services. District personnel have not received detailed guidance on when they are required to obtain RFPs/quotes, the number they must obtain, and the documentation they should retain.
The District’s Director of Food Services made purchases without soliciting competitive bids. Of the 11 payments ($542,695) to school lunch fund vendors reviewed, 4 payments amounting to $42,135 in goods were purchased without soliciting competitive bids. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding the procurement process.
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The District does not have adequate policies or procedures in place concerning payments for unused vacation leave to employees not covered under collective bargaining agreements. During the 2005-2006 fiscal year, the District allowed six District employees not covered under collective bargaining agreements to cash in 61 unused vacation days, for approximately $10,750. None of their individual contracts provided for the reimbursement of unused vacation leave.
The board also had not designated a District official to review proposed supplemental payments to confirm that they are provided for by contract terms or board resolution. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding payroll.
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The District has not adopted detailed regulations for credit card usage and travel reimbursements. Of the 55 credit card and travel-related purchases reviewed ($33,751), 49 exceptions were found ranging from lack of appropriate approvals, to lack of an appropriate original invoice.
Additionally, the BOCES employee serving as the internal auditor is not independent in performing the internal audit function.
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The report’s recommendations focused primarily on strengthening the policies and procedures regarding the internal audit function.
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The board has not adequately segregated incompatible duties with regard to the processing of claims. The board also does not review claims prior to payment, nor has it designated the responsibility to someone independent of the business function. The control environment has been weakened through the use of credit cards for many purchases. Eighteen of the 21 disbursements ($1.2 million), were determined to be without required board approval.
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The report's recommendations focused primarily on strengthening policies and procedures regarding claims processing and payments.
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The audit reviewed 26 claims which showed that purchase orders were properly initiated by the submission of a requisition form, purchase orders were approved before the purchases were made, and claims were properly audited by the District before the payments were made. |
There were no recommendations.
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There were weaknesses with the District's internal controls over separation payments, claims processing, and physical security over data generated by the District's computer system. There were two instances where District management deviated from the terms of board-approved individual employment contracts and overpaid two former administrators for unused vacation days ($7,531). There is no monitoring system for leave records for District administrators.
The District's claims auditor was not aware that she was required to report to the board and has not reported to the board at any time during her tenure.
Additionaly, adequate controls have not been established to provide adequate physical security over the business office computerized accounting system network. |
The report's recommendations focused primarily on strengthening policies and procedures regarding payroll, claims and information technology.
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