Meeting of the Board of Regents | February 2008
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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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January 24, 2008
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Goal 5
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Executive Summary
Issues for Discussion
Two items are presented for discussion with the Members of the Subcommittee on Audits including:
- Audit Trend – Claims Processing (Attachment II)
- Completed Audits – Including a Summary of the Department’s Internal Audit Workgroup (Attachment III)
- Executive Session of the Regents Subcommittee on 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 Trend – Claims Processing – The results of the many audits of school districts conducted by the Office of the State Comptroller and others have been summarized and tracked over several months. One of the most common audit findings is in the area of claims processing. Department staff will describe the issue in more detail including possible legal and regulatory guidance. (Attachment II)
2. Completed Audits
The Subcommittee is being presented with 28 audits this month. The audits have been reviewed by the Department’s Internal Audit Workgroup. Their report is attached. (Attachment III)
Reports are provided as follows:
Office of the State Comptroller
Arkport Central School District
Ausable Valley Central School District
East Williston Union Free School District
Fishers Island Union Free School District
Fonda-Fultonville Central School District
Freeport Union Free School District
Frontier Central School District
Harborfields Central School District
Hunter-Tannersville Central School District
Iroquois Central School District
Liberty Central School District
Menands Union Free School District
Moravia Central School District
Mount Vernon City School District
Nanuet Union Free School District
Naples Central School District
New Paltz Central School District
Orchard Park Central School District
Oyster Bay - East Norwich Central School District
Portville Central School District
Putnam Valley Central School District
Rockville Centre Union Free School District
Rotterdam-Mohonasen Central School District
South Colonie Central School District
South Kortright Central School District
Watervliet City School District
Watkins Glen Central School District
White Plains City School District
3. Executive Session of the Regents Subcommittee on Audits
Recommendation
For item one (Audit Trend), the advice and guidance of the Members of the Subcommittee is sought. For item two (Completed Audits), no further action is recommended.
Timetable for Implementation
N/A
The following materials are attached:
- Roadmap
- Minutes of the January Meeting (Attachment I)
- Audit Trend – Claims Processing (Attachment II)
- Review of Audits Presented – Department’s Internal Audit Workgroup (Attachment III)
- Summary of Audit Findings (Attachment IV)
- Audit Report Abstracts (Attachment V)
REGENTS SUBCOMMITTEE ON AUDITS
MEETING ROADMAP
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Opening Remarks |
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Chair |
3 |
Review Agenda/Minutes (Attachment I) |
Approval |
Conway |
2 |
Audit Trend – Claims Processing (Attachment II) |
Information |
OAS Staff |
20 |
Completed Audits – Including a Summary of the Department’s Internal Audit Workgroup (Attachment III), Summary of Audit Findings (Attachment IV), and Audit Report Abstracts (Attachment V) |
Questions answered |
OSC and Department Audit Staff |
15 |
Executive Session |
Information |
Department Staff |
20 |
Your Subcommittee on Audits held its scheduled meeting on January 14, 2008
Subcommittee Members in Attendance:
Regent Geraldine D. Chapey, Chair
Regent Milton L. Cofield
Regent Arnold B. Gardner
Regent Joseph Bowman Jr.
Other Members of the Board of Regents in Attendance:
Vice Chancellor Merryl H. Tisch
Regent Roger B. Tilles
Discussion Items
- Regent Chapey opened the meeting reminding everyone of Regents’ goal #5 “Resources under our care will be used or maintained in the public interest” and emphasized the importance of remaining focused on that in these times of great change.
- The new process for reviewing audits presented to the Subcommittee was also discussed. As a result of the discussion, it was agreed that summary points from the review of audits by the Department’s Internal Audit Workgroup will be provided to the members at each meeting.
- The Subcommittee discussed methods of addressing the findings that are being identified through audits. Possible ways to address the trends include the adoption of new policies and enforcement actions that may be available to the Department. Department counsel confirmed that if there is violation of law, the Commissioner could enforce action and bring lawsuits. If there is willful violation of law, the Commissioner could remove school board members and officers. Counsel cautioned that the threshold is high in order to prove this. A pattern of willful violation would have to be established. Other possible actions to address the findings include: comprehensive and concrete follow-up and coordination with OSC, require policy changes as trends are identified, consider recommending stronger statutory provision and more training. It was requested that as audit trends are presented to the members, it should include a list of proposed enforcement actions.
- Audit staff discussed the recently issued Office of Audit Services (OAS) audit of the Title I program at the William Floyd School District. The U.S. Department of Education’s Office of Inspector General had conducted a prior audit and determined that documentation of Title I expenditures was insufficient and there were potentially $4.6 million in unsupported Title I expenditures. The Assistant Secretary for Elementary and Secondary Education issued a program determination directing the Department to audit the funds and determine the extent of unsupported expenditures. OAS conducted the audit and identified over $500,000 in unsupported Title I expenditures.
- Completed audits presented this month:
Office of Audit Services (OAS)
William Floyd Union Free School District
Office of the State Comptroller
Alden Central School District
Bloomfield Central School District
Bradford Central School District
Brushton-Moira Central School District
Burnt Hills-Ballston Lake Central School District
Canastota Central School District
Cazenovia Central School District
Chateaugay Central School District
Clinton Central School District
Dover Union Free School District
Fallsburg Central School District
Fort Ann Central School District
Fort Edward Union Free School District
Gananda Central School District
Guilderland Central School District
Hauppauge Union Free School District
Holland Central School District
Holley Central School District
Hudson Falls Central School District
Kendall Central School District
Lansingburgh Central School District
Monticello Central School District
Mount Markham Central School District
Mount Sinai Union Free School District
New York Mills Union Free School District
Norwich City School District
Oakfield-Alabama Central School District
Pelham Union Free School District
Pine Valley Central School District
Pinnacle Charter School
Pulaski Academy and Central School District
Sauquoit Valley Central School District
Southern Cayuga Central School District
Starpoint Central School District
Sullivan County BOCES
Wainscott Common School District
Weedsport Central School District
Attachment II
Regents Subcommittee on Audits
February 2008
Audit Trend – Claims Processing
Background
The audit and approval of claims is a fundamental and critical element of a school district’s internal control system. Under Education Law, each board of education is responsible for auditing its district’s claims before they are paid. If the board chooses, it may appoint a claims auditor to assume the powers and duties of the board with respect to auditing claims. A proper audit of claims will include verification that documentation exists to support the claim, proper approvals have been obtained, and statue, regulation and district policy have been followed.
Common Findings
The audits conducted by the Office of the State Comptroller (OSC) have identified numerous findings related to an improper audit of claims. More specifically, the audits have found:
- Claims auditor not appointed and claims not reviewed by board or only some reviewed;
- Appointing an unqualified person or a person lacking independence (i.e., a clerk in the business office);
- Claims auditor not reviewing all claims;
- Lack of documentation for claims; and
- Appointing two claims auditors (i.e., a deputy claims auditor).
Audit findings related to claims processing were found in 18 of the 37 OSC audits presented to the Regents Subcommittee on Audits in January and in 13 of the 28 audits being presented this month. Since May 2007, 93 of the 227 OSC audits presented to the Subcommittee contained findings related to claims processing, more than any other audit issue.
Criteria
The requirement for claims processing is established in law. A school board is required to either audit each claim or to appoint a claims auditor to do so. The 2005 accountability legislation enhanced the claims auditor function through establishment of the Office of Claims Auditor. Commissioner’s regulations approved in 2006 clarified the qualifications and duties of the Office of Claims Auditor.
Guidance and Training
Following passage of the Accountability legislation in 2005, SED staff, along with the New York State School Boards Association, New York State Council of School Superintendents, New York State Association of School Business Officials and the Office of the State Comptroller, conducted a number of workshops across the state about the new accountability provisions including information about the Office of Claims Auditor and the duties of such office.
The Department has detailed information on its website describing the issues school boards should consider before appointing a claims auditor, and information on the qualifications and duties of a claims auditor.
http://www.emsc.nysed.gov/mgtserv/AuditorS-Overview8-9-06.doc
http://www.emsc.nysed.gov/mgtserv/auditing/internal_claims_auditor_role.doc
The Office of Education Management Services and the Office of Audit Services provide technical assistance to board members, CPAs, and claims auditors as requested.
The New York State School Boards Association and the New York State Association of School Business Officials provide training to its members.
Recommendations for Enforcement
The following possible actions have been considered to address the findings of claims processing:
- expanded training and outreach; and
- The Department provides considerable information regarding claims processing; however, the results of the audits suggest it has not reached everyone it needs to. We recommend that SED work with the various associations representing school boards and business officials to increase awareness of the requirements.
- comprehensive and concrete follow-up with the districts including on-site verification of corrective actions in coordination with OSC;
If necessary, the following additional actions may need to be considered:
- stronger statutory provisions and/or policy changes; and
- sanctions which could include a Commissioner’s order for failure to comply.
Attachment III
Regents Subcommittee on Audits
February 2008
Review of Audits Presented
Department’s Internal Audit Workgroup
Newly Presented Audits
We reviewed the 28 school district audits that are being presented to the Subcommittee this month. The audits were all issued by the Office of the State Comptroller and the findings were in the areas of procurement, claims processing, payroll, cash, financial reporting, information technology, extraclassroom activity fund, budgeting and other.
The Department has issued letters to all of the districts reminding them of the requirement to submit corrective action plans to the Department within 90 days of their receipt of the audit report.
- We found no instances requiring the immediate action by the Department.
- We identified 8 audits as having significant findings and on which we will focus on the adequacy of the corrective action plans; in 6 instances the audit has recommended the district conduct internal reviews to determine if a recovery of funds by the district should be undertaken. We will follow-up on those actions. Follow-up actions could include correspondence to the district requesting further information and/or requiring actions, on-site verification of corrective actions and more formal sanctions.
- Frontier Central School District
- Harborfields Central School District
- Menands Union Free School District
- Mount Vernon City School District – identified as a fiscal stress district
- Orchard Park Central School District
- Oyster Bay – East Norwich Central School District
- Watervliet City School District – identified as a fiscal stress and Contract for Excellence district
- Watkins Glen Central School District
- The school districts have indicated agreement with almost all of the recommendations made by the Office of the State Comptroller.
Follow-up Actions
Since the last Subcommittee meeting, audit staff have reviewed the corrective action plans of five school districts that had been previously identified for follow-up. They have requested additional information from one district and also contacted a County District Attorney requesting information. Audit staff have also alerted the Department’s Office of Teaching Initiatives of an audit finding related to fingerprinting requirements.
Audit |
Procurement |
Claims Processing |
Payroll |
Cash |
Financial Reporting |
Information Technology |
Extra - classroom Activity Fund |
Budgeting |
Other |
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Arkport Central School District |
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√ |
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√ |
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Ausable Valley Central School District |
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√ |
√ |
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East Williston Union Free School District |
√ |
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√ |
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Fishers Island Union Free School District |
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√ |
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Fonda-Fultonville Central School District |
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Freeport Union Free School District |
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Frontier Central School District |
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√ |
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Harborfields Central School District |
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√ |
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√ |
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Hunter-Tannersville Central School District |
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√ |
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√ |
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Iroquois Central School District |
√ |
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Liberty Central School District |
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√ |
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√ |
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Menands Union Free School District |
√ |
√ |
√ |
√ |
√ |
√ |
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Moravia Central School District |
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√ |
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Mount Vernon City School District |
√ |
√ |
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√ |
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Nanuet Union Free School District |
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√ |
√ |
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√ |
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Naples Central School District |
√ |
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√ |
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√ |
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New Paltz Central School District |
√ |
√ |
√ |
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√ |
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Orchard Park Central School District |
√ |
√ |
√ |
√ |
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√ |
Oyster Bay - East Norwich Central School District |
√ |
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√ |
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Portville Central School District |
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√ |
√ |
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√ |
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Putnam Valley Central School District |
√ |
√ |
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√ |
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Rockville Centre Union Free School District |
√ |
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√ |
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Rotterdam-Mohonasen Central School District |
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√ |
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√ |
√ |
√ |
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South Colonie Central School District |
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√ |
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√ |
√ |
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South Kortright Central School District |
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√ |
√ |
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√ |
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Watervliet City School District |
√ |
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√ |
√ |
√ |
√ |
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Watkins Glen Central School District |
√ |
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√ |
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White Plains City School District |
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√ |
√ |
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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 |
January 2008 |
February 2008 |
Running Total |
Procurement |
9 |
11 |
12 |
20 |
12 |
11 |
12 |
87 |
Capital Assets |
10 |
1 |
2 |
4 |
0 |
0 |
0 |
17 |
Claims Processing |
13 |
3 |
12 |
17 |
17 |
18 |
13 |
93 |
Payroll |
12 |
3 |
11 |
20 |
18 |
14 |
12 |
90 |
Cash |
6 |
2 |
8 |
15 |
14 |
15 |
8 |
68 |
Financial Reporting |
12 |
3 |
2 |
16 |
6 |
11 |
4 |
54 |
Information Technology |
10 |
10 |
9 |
14 |
15 |
15 |
17 |
90 |
Capital Construction |
2 |
1 |
1 |
0 |
0 |
1 |
0 |
5 |
Extraclassroom Activity Fund |
1 |
1 |
0 |
1 |
1 |
2 |
1 |
7 |
Segregation of Duties |
0 |
0 |
3 |
0 |
15 |
19 |
0 |
37 |
Budgeting |
2 |
3 |
0 |
1 |
1 |
0 |
1 |
8 |
Conflict of Interest |
0 |
0 |
0 |
4 |
3 |
3 |
0 |
10 |
Other |
0 |
2 |
0 |
0 |
0 |
1 |
1 |
4 |
Total |
77 |
40 |
60 |
112 |
102 |
110 |
69 |
570 |
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.
Extraclassroom Activity Fund – 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.
Other – District did not appropriately administer its Flexible Fringe Benefit Program.
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Payroll clerk duties are not properly segregated because the payroll clerk’s responsibilities include adding, deleting, and modifying employee information, adding and changing pay rates and salaries, printing payroll checks with the treasurer’s signature, as well as distributing checks.
The board has not effectively addressed the safeguarding of computer data by failing to adopt policies and procedures to address the use of passwords for the financial software. The board must also implement a disaster recovery plan, in order to protect important data. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding payroll segregation of duties, and information technology.
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Twenty cash receipts of the extraclassroom activity funds for the 2005-06 fiscal year were examined, and 100 percent of them were not deposited in a timely manner. Also, District officials were unable to produce student activity deposit forms for the 2006-07 fiscal year. As a result, no tests could be conducted pertaining to the timeliness of cash receipt deposits. The audit did not find that activity fund monies had been used innapropriately.
IT controls pertaining to passwords, access, and disaster recovery need to be strengthened.
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The report’s recommendations focused primarily on strengthening policies and procedures regarding extraclassroom activity funds and information technology.
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The District paid six professionals a total of $494,610 without soliciting competitive proposals. The District also made payments to three professionals, totaling $107,094, for services not specified in the contract. In addition, District officials also paid three other professionals $93,788 without receiving sufficiently itemized invoices.
The District also paid 11 vendors a total of $173,324 without soliciting competitive bids or quotations.
Lastly, passwords are not changed periodically, and computer hardware is not protected from unauthorized access. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding procurement and information technology.
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The board did not audit claims or appoint a claims auditor from July 1, 2006 through September 20, 2006. As a result, 225 claims ($357,000) were not audited.
Additionally, 7 claims and 13 credit card charges ($2,980) did not contain original itemized receipts.
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The report’s recommendations focused primarily on strengthening the policies and procedures regarding the audit of claims.
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The 2006-07 salaries of 20 employees were reviewed in order to ensure that payments were calculated correctly, and verified that the leave time records for 15 employees were accurate. No deficiencies were found.
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The report focused on strengthening policies and procedures pertaining to internal controls over payroll.
There are no recommendations. |
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The payments made to 20 employees ($400,900) were reviewed to determine if District officials made payments in compliance with the terms of the relevant agreements. The District’s system for verifying and approving separation payments was found to be appropriately designed and operating effectively.
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The report focused on strengthening the policies and procedures regarding separation payments.
There were no recommendations. |
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There were weaknesses found in the internal controls over separation compensation of 7 out of 15 employees, resulting in overpayments of $10,864.
The board did not authorize or review a “merit pay” salary increase for a former superintendent, which caused the District to overpay him by $3,111. The District paid the interim superintendent at a weekly rate even when he did not work the minimum number of days per week stipulated in his contract. This resulted in an overpayment of $2,725. The District also paid $1,932 to a former assistant superintendent for unused sick leave that he had not earned. The board also paid an employee $2,222 for unused leave time.
The District purchased split-dollar life insurance policies for $50,000 more for each policy than was required by employment contracts. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding separation and salary payments and split-dollar life insurance policies.
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The District overpaid four former administrators $83,342 for unused vacation and sick leave that was not provided in their employment agreements, or by board resolutions. Additionally, two employees were paid a total of $1,095 for days to which they were not entitled.
There were also weaknesses relating to computer operations. Four users of the financial software had full access to the District’s financial applications and data. Backup tapes were also not stored off-site, which increases the risk that a disaster could destroy important financial data.
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The report’s recommendations focused primarily on strengthening the policies and procedures regarding separation payments, leave accruals and information technology.
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The claims auditor does not report directly to the board, as required. Instead, the claims auditor reports to the business manager. There were also deficiencies in the claims audit process. Of the 26 claims that were tested, 8 claims totaling $10,329 were not properly supported.
IT controls were also improperly designed because the District does not have physical safeguards over its computer equipment and does not store backup computer data at a secure off-site location.
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The report's recommendations focused primarily on strengthening the policies and procedures regarding claims processing and information technology.
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Twenty-five purchases ranging in cost from $1,780 to $114,675 were tested to determine if the District complied with the provisions of its purchasing policy. Of the 25 tested, 13 of them lacked proper documentation.
The purchase of tires and two-way radios were purchased through State contract, however, the supporting documentation did not specify which State contract was used.
The District also paid significantly more for certain items than it would have had they been purchased through readily available alternative sources. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding purchasing.
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The claims auditor had user access rights to the financial software system, including the ability to add and update vendors and print checks. The board did not establish plans to protect IT equipment and data from potential disasters. The board also had not adopted a formal disaster recovery plan.
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The report's recommendations focused primarily on strengthening policies and procedures regarding information technology and claims processing.
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Eight out of 28 copies of deposit slips, provided by the cafeteria cashier, did not agree with the bank deposit slip copies. In two of the eight deposits, the treasurer submitted two personal checks for cash. For 82 deposits examined, there were 15 cases where the treasurer did not deposit monies until more than 100 days after receipt and did not deposit 10 others until more than 150 days after receipt.
The board is also not auditing claims, but is relying on an employee in the business office to audit District claims. Thirty purchases packets (totaling $92,005) were reviewed, and it was found that the District paid 14 claims even though one or more items of required documentation were incomplete or missing.
Additionally, the District made payments ($582,403) for employee compensation, $136,211 for health and dental benefits, and provided leave benefits ($36,228) that were not properly supported by contract provisions or a board resolution.
Finally, the BOCES employee serving as the District’s internal auditor is not independent in performing the internal audit function. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding cash and disbursements, purchasing and claims processing, payroll, information technology and internal auditor.
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The District uses a computerized electronic signature stamp to sign checks and to place approving signatures on purchase orders. The password for the treasurer’s signature is known by both the payroll clerk and the accounts payable clerk. Additionally, the payroll clerk holds the incompatible position of system administrator, and 5 out of 13 system users have inappropriate levels of access to the general financial system module.
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The report’s recommendations focused primarily on strengthening the policies and procedures regarding the computerized business management system.
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The purchasing agent did not use required competitive bidding to make purchases totaling $1,119,742. The staff also made purchases of $120,519 without first seeking prior approval.
District officials made year-end budget transfers for the 2003-04, 2004-05, 2005-06 fiscal years totaling $9,531,266, $2,297,480 and $1,310,000, respectively without board pre-approval.
The District also paid vendors without supporting documentation as required by District policy. Payments were made to 175 vendors that totaled $3,123,581, and 34 vendor payments, totaling $363,433, did not include receiving reports.
The District treasurer also issued hand-written checks in excess of one quarter of a billion dollars. These checks included approximately $281 million in payroll related items including checks to transfer funds into payroll accounts. Checks were found in amounts as high as $3.9 million which only required the treasurer’s signature and are not approved by the claims auditor prior to payment.
There was also a lack of segregation of duties for the treasury and internal audit functions. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding purchasing, cash disbursements and claims processing.
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Timesheets were examined, and there were excessive amounts of overtime claimed by employees. Two employees claimed 89½ and 90½ hours overtime in one week and another employee claimed to have worked 17½ consecutive hours. One employee also received $78,346 in overtime pay during the two-year audit period which amounted to 144 percent of his annual salary. There was also an overpayment of $13,593 to facilities workers.
The superintendent also did not certify the payroll as required by District policy and the duties of the senior payroll clerk were not properly segregated.
The District did not use the RFP process to solicit competition, as required by District policy for services of more than $20,000.
The assistant superintendent made budget transfers of $2,368,701 at the end of the 2005-06 fiscal year without board pre-approval. District officials repeated this practice at the end of the 2006-07 fiscal year, transferring $1,093,500 to rectify deficit balances on budgetary line items incurred throughout the preceding year.
Lastly, there was inadequate segregation of duties related to the cash receipts and disbursements responsibilities of the treasurer. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding payroll, budgetary controls and cash receipts and disbursements.
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District officials did not effectively assign responsibilities to the treasurer/payroll clerk to ensure there was a proper segregation of duties and did not establish sufficient compensating controls.
Professional services were also not always procured in conformance with General Municipal Law. Payments for accounting services exceeded contracted amounts by $20,275 and payments for legal services exceeded agreed upon amounts by a minimum of $2,680.
Internal controls to protect fuel inventories against fraud, abuse or misuse were also not adequate. District personnel are not accurately reconciling measurements of deliveries, usage and inventories on hand to calculate losses or gains of fuel.
The board also has not established policies and procedures to sufficiently address the safeguarding of computerized data and assets. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding treasurer’s office operations, professional service contracts, internal control over fuel inventories and information technology.
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The District did not competitively bid the purchase of a bucket truck costing $13,200, nor solicit quotes for the construction of an office costing $16,500.
The District's claims auditor was not properly auditing claims. Those claims that were reviewed were missing necessary documentation, but were still approved by the claims auditor. The superintendent should reimburse the District for spousal expenses.
Certain payroll controls were weak, and as a result, six employees earned over $4,200 of compensatory time off that was not authorized by their contracts.
The District also had not developed a backup policy or disaster recovery plan. |
The report's recommendations focused primarily on strengthening the policies and procedures regarding purchasing, claims processing, compensated absences and leave time and information technology.
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District employees were improperly paid separation benefits and special assignment pay totaling $265,104. The personnel office also did not have timesheets to support 2004-05 payroll payments to the treasurer, the District clerk/secretary to the superintendent and eight support staff, totaling $376,572.
The board had also not developed adequate procedures to govern its Flexible Fringe Benefits Program, which provides a Health Reimbursement Arrangement (HRA). The District allowed reimbursement for ineligible expenses, and did not verify that submitted expenses are supported by documentation, such as receipts from providers. The District also allowed certain former administrators to divert income to their HRA accounts, on a pre-tax basis to avoid jeopardizing their pension income from the New York State Teacher’s Retirement System, or to avoid taxes.
Additionally, District officials failed to obtain quotations when procuring insurance. Members of the Insurance Advisory Committee also shared fees and commissions arising from the District’s renewal of certain insurance policies. This resulted in the District making payments for coverage, totaling more than $1.3 million to the firm of one of the members of the committee, and from the amount paid to that firm, the other members received fees or commissions totaling $45,371.
There were also discrepancies involving segregation of duties in claims processing which resulted in $117,785 in payments with no evidence of claims auditor review or approval.
Lastly, there was no authorization indicating approval by the assistant superintendent of business for any of the outgoing wire transfers that were audited, totaling more than $1.4 million.
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The report’s recommendations focused primarily on strengthening the policies and procedures regarding control environment, employee compensation and benefits, the Flexible Fringe Benefits Program, insurance procurement, claims processing, and wire transfers.
Note: There has been changes in District administrative positions and the current board is comprised of new membership.
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Sixty-six purchase orders ($886,420) were identified, that were created and encumbered in February and March 2006, for which no actual commitments existed. This appears to have been an attempt to hide excessive fund balances.
The District has also failed to establish policies and procedures to safeguard computer data. The assistant superintendent is able to create a new user, update the user’s access rights, and perform other administrative functions.
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The report’s recommendations focused primarily on strengthening policies and procedures regarding encumbrances and computer data safeguards.
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Users of the District’s computerized financial system were able to change the access rights of other District users, as well as change District accounting data, without supervisory approval. The District has also failed to implement a formal disaster recovery program for its information technology systems.
The District is not properly administering the claims processing function. Fifty claims were reviewed ($188,532), and one or more exceptions were found in 35 claims ($130,727). Exceptions included purchase orders dated after the date of purchases, insufficient itemization and lack of proper receipt confirmation.
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 computerized data, claims processing, and the internal audit function.
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District officials did not follow General Municipal Law or their purchasing policy while making purchases. The District did not use request for proposals (RFP’s) to obtain the services of seven service providers totaling $253,143. They also did not solicit competitive bids for three purchases over the $10,000 bidding threshold. These purchases totaled $37,029.
The District’s claims auditor also has not conducted a thorough audit of claims. The District reimbursed nine administrators $22,199 for attending conferences without proper documentation.
Lastly, the tax collector took between 1 and 42 days to deposit tax payments and as a result the District lost $2,260 in interest. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding procurement, claims processing and cash receipts.
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Maintenance workers and night security employees often did not submit gas card receipts to indicate that charges were valid District obligations and District officials did not monitor gasoline usage. Of 407 gas charges, 58 percent lacked receipts. Additionally, six claims were examined (totaling $3,425) and there were no signatures attached to confirm that an official or employee received the goods.
Written policies and procedures regarding the District’s computer data system have also not been implemented.
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The report’s recommendations focused primarily on strengthening policies and procedures regarding credit card purchases and computer data safeguards.
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There were discrepancies between cafeteria sales recorded and moneys deposited. Net discrepancies over a five-month period totaled over $3,300. Also, other miscellaneous receipts were not deposited in a timely manner. Ten receipts totaling $43,735 were not recorded timely, and 19 receipts totaling $357,493 were not deposited timely. Also, the October 2006 and November 2006 bank reconciliations for the general investment fund were not properly performed.
District personnel failed to obtain quotes for 11 purchases, totaling $28,013. Additionally, 43 of 383 budget accounts tested were over-expended.
The District must also strengthen internal controls related to information technology, including the restoration of backup data, the implementation of a formal disaster recovery plan and effectively restricting system and physical access.
Lastly, the Capital Region BOCES employee serving as the internal auditor is not independent. In 2005-06 the District spent $2.6 million on general fund services provided by the Capital Region BOCES. The failure of the District to establish an effective internal audit function may result in the evaluation of significant District services or programs by someone who is not independent of those services/programs. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding cash receipts and disbursements, purchasing and claims processing, information technology and the internal auditor.
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The District’s computer-generated checks are not issued until after an audit, however the sample of hand-drawn checks that were reviewed were issued prior to audit.
Additionally, the BOCES employee serving as the internal auditor is not independent in performing the internal audit function.
Lastly, there were weaknesses in internal controls for information technology related to disaster recovery, backup storage and user rights access.
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The report’s recommendations focused primarily on strengthening the policies and procedures regarding claims processing, the internal auditor and computerized data.
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The principal’s secretary was appointed as the claims auditor for the 2005-06 and 2006-07 fiscal years, which may be prohibited because the principal’s secretary occasionally reported directly to the superintendent.
The treasurer also has complete control over the payroll process as well as full user access rights to the payroll functions in the financial software.
Lastly, the board has not established comprehensive policies and procedures to sufficiently address the safeguarding of computerized data and assets. District officials have not developed a disaster recovery plan. |
The reports recommendations focused primarily on strengthening the policies and procedures regarding the claims auditor, payroll, and computerized data and assets.
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The District’s general fund unreserved balance deteriorated from a positive balance of over $993,000 on June 30, 2004, to a fund deficit of over $1.4 million on June 30, 2006. The District incurred a general fund operating deficit of over $1.6 million for the fiscal year ended June 30, 2006, and an operating deficit of over $487,000 for the preceding fiscal year. As a result, the District issued Revenue Anticipation Notes (RANs) for $2.35 million. The plans to repay the RANs within the timeframe are not sufficient.
There were also internal control weaknesses over payroll, cash disbursements, and purchasing.
The former superintendent’s severance payment may have been overstated by as much as $20,000 in excess of what was allowed in her employment contract. During the last two years of her tenure, she charged 26 days to conference attendance, to which there was no documentation to support that.
The business manager’s responsibilities include several duties that are incompatible. He is responsible for auditing each claim and for approving each purchase. These functions are incompatible with his other duties as business manager.
The board has also failed to appoint a claims auditor and does not audit vendor claims themselves, as required by State Education Law.
Lastly, the District has not consistently complied with competitive bidding laws or their own procurement policy. |
The report’s recommendations focused primarily on strengthening policies and procedures regarding financial condition, leave time, cash disbursements, purchasing and computerized data.
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The District overpaid the former superintendent $14,208 for unused leave balances. The former superintendent also received a $470 reimbursement for Internet service at her personal residence despite the fact that none of her employment contracts contained a provision for such a reimbursement.
The claims auditor did not properly audit 55 of the 137 claims reviewed (40 percent). Further, thirty-seven checks ($7,755) were issued to purchase supplies. The claims auditor approved the payment prior to the actual purchase of goods, and did not verify that the receipts agreed with the purchase orders.
Additionally, it was found that individuals continually override budgetary controls, generating purchase orders even though sufficient appropriations were not available. Lastly, budget transfers totaled in excess of $1 million, of which 70 were line item transfers in excess of $5,000. |
The report’s recommendations focused primarily on strengthening the policies and procedures regarding payments to the former superintendent and the procurement process.
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Nineteen out of 32 payroll warrants, totaling $51,855,691 were not certified as required by Education Law and none had a date to indicate when they had been reviewed. Additionally, the Facilities and Operations Department incurred $614,837 of overtime without maintaining adequate documentation of overtime usage.
The District also did not comply with Education Law when it appointed two claims auditors, one of whom, the deputy claims auditor, is not independent of the business functions of the District.
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The report’s recommendations focused primarily on strengthening the policies and procedures regarding payroll and claims auditing.
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