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Okaloosa County BOCC — November 5, 2013 — reading text
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Department to all other departments of the County.
In particular, the County amended the following sections of the Purchasing Manual
relating to the review of whether a particular expenditure serves a public purpose:
Section G.2.e. provides:
Prior to authorizing any expenditure listed above, the Department
Director shall review the purchase and determine that the
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expenditure serves a public purpose and that the necessary
approval and procedures for the expenditure has been complied
with.
Section G.9.b.(1) provides:
The Finance Department shall review the purchase order and
determine that the expenditure serves a public purpose, that the
necessary approval and procedures for the expenditure have been
complied with and certify that funds are available for the
purchase. The funds are encumbered and obligated at this point in
the purchasing process. The Finance Department shall forward
the certified purchase order to the Purchasing Department.
The Finance Department referred to in Section G.9.b.(1) above is under the authority and
supervision of the CCC. These amendments strengthen the controls related to the issues raised
by this Finding.
Finding No. 11: The BCC needed to enhance its procedures relating to the use of purchasing
cards.
Recommendation: The BCC should strengthen its p-card policies and procedures to ensure that
an independent review and approval is documented for all purchases; p-card expenditure reports
include the required statement that employees and reviewers have certified they reviewed the
applicable p-card expenditure report, the report is supported by receipts, all purchases made were
for official County business, and the purchases were in accordance with applicable rules and
directives; single transaction limits have not been exceeded; prior to payment, employees have
acknowledged the receipt of goods and services purchased; BCC records evidence the authorized
public purpose served by the expenditures; and p-cards for terminated employees are timely
canceled.
COUNTY RESPONSE:
The County agrees with the audit finding and recommendation.
As noted in the Findings, a review of P-card expenditures during the period of October
2011 through February 2013 disclosed deficiencies in the controls and monitoring of P-card
expenditures. As part of the corrective action plan implemented by the County in response to
Auditor General Report No. 2013-085, issued January 2013, the County prepared significant
revisions to its Purchasing Manual on April 2, 2013. The purpose of these changes was to apply
many of the controls that were implemented for the Tourist Development Department to all other
departments of the County.
In particular, the County amended Section N of the Purchasing Policy relating to
Purchasing Card Policy and Procedures. These amendments strengthen the controls related to
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the issues raised by this Finding. The following is a list of revisions made to the Purchasing
Manual:
• Section N.C.10.(c) requires P-card expenditure reports of Department Directors
to be reviewed by the County Administrator. Reports of the County Administrator
are reviewed by the Chairman of the BCC. Reports of the BCC members are
reviewed by the Clerk’s Finance Department.
• Section N.A.3. relating to the cancellation of P-cards for cardholders that are no
longer employed by the County.
• Section N.C.2 and 3 requiring that goods or services are received prior to
payment.
• The revised P-card Expenditure Report (page 63 of Purchasing Manual) requires
employees and reviewers to certify they reviewed the report, the report is
supported by receipts, all purchases were made for official County business, the
purchases were in accordance with applicable rules and directives, documents
the public purpose of the purchases, and the date on which the goods/services
were received.
The County recognizes the importance of P-cards in the elimination of petty cash for
small purchases as well as the intangible benefit of rebates from the issuer. In that regard, the
County will also review and consider the amendment of the policies and procedures to address
controls related to the use of P-cards, as determined to be needed by the County.
Finding No. 12: The BCC did not document the necessity of paying for certain goods and
services in advance of their receipt, contrary to law.
Recommendation: The BCC should strengthen policies and procedures to ensure that advance
payments are approved and paid only if the payments result in a savings that is equal to or
greater than the amount that would be earned by investing the funds and paying later, or if the
payments are essential to the BCC’s operations and the goods or services being paid for are
available only if advance payment is made.
COUNTY RESPONSE:
The County agrees with the audit finding and recommendations.
As noted, the County has adopted amendments to its Purchasing Manual on April 2, 2013
which significantly strengthened the review and documentation required for expenditures. The
County will continue to review and strengthen these controls, as necessary, including limitations
on the advancement of payments.
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TRAVEL
Finding No. 13: Several County Commissioners received monthly travel allowances based on
typical months’ travel statements that were outdated, included unallowed mileage, or did not
include adequate descriptions of the travel claimed.
Recommendation: The BCC should strengthen its procedures to ensure that travel allowances
are paid based on typical month’s travel statements that are updated annually, include
sufficiently detailed information, and are correctly calculated in accordance with the provisions
of law and guidance provided in applicable Attorney General opinions.
COUNTY RESPONSE:
Though the County does not necessarily agree that all of the examples cited in the
Finding were contrary to the requirements of law, the County will review and revise where
necessary, its procedures to ensure that travel allowances are paid based upon the requirements
of Florida law.
CONTRIBUTIONS
Finding No. 14: The BCC had not adopted policies and procedures for making contributions to
private nonprofit corporations. Also, the BCC did not consistently document how contributions
to the corporations served an authorized public purpose, require the corporations to enter into a
written agreement stating the purpose for which the contributions should be used, or obtain a
subsequent accounting from the corporations as to how the contributions were ultimately used.
Recommendation: The BCC should adopt written policies and procedures addressing criteria to
be used to make contributions to private nonprofit corporations, the methodology for calculating
the amount of the contributions, and the responsibilities of the corporations receiving the
contributions to provide an accounting as to how the contributions were ultimately used. In
addition, the BCC should document how each contribution serves an authorized public purpose
and obtain a subsequent accounting from each corporation to document that the authorized
public purpose was accomplished.
COUNTY RESPONSE:
The County agrees with the findings and recommendations.
The County will consider the adoption of written policies and procedures addressing
criteria to be used to make contributions to private nonprofit corporations, the methodology for
calculating the amount of the contributions, and the responsibilities of the corporations
receiving the contributions to provide an accounting as to how the contributions were ultimately
used. In addition, the County will strengthen its procedures to establish how contributions serve
a public purpose.
MOTOR VEHICLES
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Finding No. 15: The BCC had not established adequate controls over the use of fuel cards.
Recommendation: The BCC should continue its efforts to strengthen controls over the use of
fuel cards by requiring BCC departments to retain all receipts from retail locations and perform
reconciliations of fuel charges to those receipts.
COUNTY RESPONSE:
The County agrees with the audit finding and recommendation.
The County currently monitors fuel sales through a variety of documentation. The
primary source of review is the electronic transaction data which establishes the purchaser, the
fuel card number, the vehicle that was fueled, the fueling location, the amount purchased and the
price. The County has already reviewed the parameters for all fuel cards and adjusted the
parameters where appropriate.
The County will continue to review its procedures and controls to provide assurance that
adequate documentation is available. The County will also strengthen its vehicle usage
procedures to include fuel consumption parameters and more effective use of its fuel card
exception reports. Further, the County will review the viability of requiring user department
reconciliation of fuel charges to gas receipts and the retention of all gas receipts by user
departments.
Findings 16 through 21 are directed to the Clerk of the Circuit Court and as such, no response is
required by the County.
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FINDINGS AND RECOMMENDATIONS
Our report No. 2013-085, issued in January 2013, included our findings related to the BCC’s oversight of the
Tourist Development Council and use of tourist development taxes by the Tourist Development
Department, a BCC department. The scope of this audit did not include a review of Tourist Development
Department transactions. However, for the areas of BCC operations that were included within the scope of
this audit, we found several issues that were similar to issues also noted in our report No. 2013-085. This
may be attributable to the fact that the period (October 2011 through February 2013) in which we primarily
focused our examination of records and transactions for this audit overlaps to some extent with the period
(May 2010 through May 2012) covered in report No. 2013-085. The County’s efforts to address the
recommendations included in report No. 2013-085 are ongoing, and include corrective actions such as
revision of its purchasing-related policies in April 2013 as indicated in finding Nos. 3, 9, and 11.
Finding No. 2: Statements of Financial Interests
Section 112.3145(6), Florida Statutes, provides that the Florida Commission on Ethics (Commission) shall
annually prepare a listing of local officers required to file a statement of financial interests and provide that
listing to the local supervisor of elections. Section 112.3145(2), Florida Statutes, provides that each local
officer must file a statement of financial
