Okaloosa County BOCC — January 18, 2013 — Attorney General P&T Audit — reading text

payable and payroll employees, had the ability to record journal entries. However, CCC procedures did not provide for an independent review of all journal entries recorded in the accounting system to determine that the journal entries were properly authorized. County IT personnel indicated that, due to software limitations, an employee?s ability to record journal entries could not be limited without also limiting the employee?s ability to view certain accounting records. Two CCC payroll employees and the CCC?s Financial Services Manager had the ability to record pay rate and other changes in the payroll system. These employees also had the ability to process payroll transactions and print payroll checks. However, CCC procedures did not provide for an independent review of all changes recorded in the payroll system to determine that the changes were properly authorized by the Human Resources Department. Two CCC accounts payable employees had the ability to add new vendors and make other changes in the master vendor file. These employees also had the ability to process and pay vendor invoices, and print and distribute checks to vendors. However, CCC procedures did not provide for an independent review of all changes made to the master vendor file to determine that the changes were properly authorized by the Purchasing Department. We also noted that end-user departments were not routinely required to review employee access privileges to County resources (e.g., accounting records, payroll system data, master vendor files) to determine whether these access privileges were necessary and appropriate given an employee?s job responsibilities. Without such reviews, unnecessary or incompatible access privileges may not be timely detected and addressed by the County, increasing the risk of unauthorized disclosure, modification, creation, or destruction of data and IT resources. Recommendation: The County should strengthen its procedures to include the periodic review of access privileges granted to employees and timely remove or modify unnecessary or incompatible access privileges detected. Public Records Finding No. 25: TDC and TDC Subcommittee Meeting Minutes Section 286.011, Florida Statutes, commonly referred to as the Sunshine Law, requires that minutes of public board or commission meetings be promptly recorded and open to public inspection. Florida?s Government-in-the-Sunshine Manual, compiled by the Florida Attorney General?s Office, further provides that advisory boards and committees created by public agencies may be subject to the Sunshine Law, even though their recommendations are not binding upon the entities that create them. When an advisory board or committee has been delegated decision-making authority as opposed to mere information-gathering or fact-finding authority, their meetings must be open to public scrutiny, regardless of the review procedures eventually used by the traditional governmental body. 27  ****PRELIMINARY AND TENTATIVE FINDINGS**** The TDC is responsible for advising the BCC on the implementation of its tourist development plan, including making recommendations to the BCC regarding the effective use of tourist development taxes. In carrying out its responsibilities, the TDC established two standing subcommittees that met during the period May 2010 through May 2012. The Promotion Review Subcommittee met periodically until October 2010 when it was disbanded. The Marketing Subcommittee was then formed and began meeting in May 2011. The stated responsibilities of both subcommittees included reviewing and recommending advertising and marketing consultants to the TDC and reviewing and recommending specific tourism marketing proposals presented to the TDC by private industry and nonprofit organizations. As discussed in finding No. 15, the TDC and TDC Marketing Subcommittee also awarded special event grants to selected groups or organizations. Based on their responsibilities, both the TDC and the TDC subcommittees are subject to the Sunshine Law. The minutes of the TDC and TDC subcommittee meetings were generally recorded, approved at subsequent meetings, and electronically stored by the County. However, our review of the minutes of the TDC and TDC subcommittee meetings disclosed that County procedures for maintaining official records of the meetings needed improvement. For example, we noted that minutes were not recorded for a TDC meeting and a TDC subcommittee meeting held on December 8, 2010, and October 28, 2010, respectively. We also noted that the minutes of the remaining meetings were not signed by the committee or subcommittee chairman or the employee who recorded the minutes. In addition, we noted several meetings for which two versions of the minutes were retained by the County. The County?s legal counsel indicated that the different versions represented draft and final versions of the minutes, and a specific file for the final approved and official meeting minutes of the TDC and TDC subcommittees was not maintained. In the absence of meeting minutes signed by the TDC or TDC subcommittee chairman and the employee who recorded the minutes, the County cannot demonstrate that the minutes made available for public inspection represent the official record of the discussions and actions taken at the meetings. In September 2012, the BCC adopted policies and procedures regarding TDC and TDC subcommittee minutes as part of the TDC?s operations and procedures manual. These policies and procedures require written minutes to be maintained for all TDC and TDC subcommittee meetings and an audio recording of each TDC meeting to be made and retained as a public record. Recommendation: The County should continue to strengthen its procedures for maintaining official minutes of the TDC and TDC subcommittees by recording minutes for all meetings and requiring that the final approved minutes made available for public inspection be signed by the TDC or TDC subcommittee chairman and the employee who recorded the minutes. RELATED INFORMATION The State Attorney, 1st Judicial Circuit, and several law enforcement agencies, including the Okaloosa County Sheriff?s Office, the Florida Department of Law Enforcement, and the Federal Bureau of Investigation, are investigating alleged improprieties involving the TDC and the former TDC Executive Director. At the close of our audit fieldwork, these investigations were ongoing. 28