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[Type text]
y
Auditor‐Controller‐Treasurer‐TaxCollector
Sonom
aCount
CAL‐Card Program Countywide Audit
July12010ndashJune302012
The policies procedures and internal controls over the CAL‐Card program are generally adequately designed to detect unauthorized transactions However internal controls such as management oversight authorization and documentation need to be strength
ened to reduce the rate of unauthorized purchases Our audit also indicates that the County can realize significant savings through proactively
man
aging the program
Audit No 3108 December 2013
AuditChief KanchanK Charan CPACGMAAuditSupervisor Damian Gonshorowski CPA Auditor ChristinaLiu CPA
Executive Summary 1 Introduction amp Background 6 The Countyrsquos CAL‐Card Spending Profile 8 Objectives amp Scope 11 Methodology Sample Selection amp Results 12
Opportunities for Improvement Observations and Recommendations 13
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases 13
ARestrictedandUnallowablePurchases
BLackofProperAuthorization
CUntimelyTravelAuthorization
DSplitTransactions
Observation 2 Strengthen Controls over Meal Expenses 17
AControlWeaknessoverDocumentation
BRe‐EvaluatetheCurrentMealPolicy
Observation 3 Adopt A Risk Based Approach to Audit the CAL‐Card Program 21
Observation 4 Consider Deactivating Infrequently Used Cards 22
Observation 5 Establish Proper Spend Limits and Commodity Ranges 23
ATheCal‐CardProgramExpansion
BEffective UseofResources
Observation 6 Proactively Manage the CAL‐Card to Achieve Cost Savings 25
APerformSpendAnalysistoSupportCountywidePurchasingStrategies
BRequireDepartmentstoPurchasethroughBPOorGroupBuying Contracts
CMaximizeUseoftheCAL‐Card toAchieveHighLevelof Efficiency
DExplorethePossibilitiesofPartneringwith OtherCard Providers
Appendix A Best Practices for Purchase Card Program Management 30 Appendix B Best Practices for Selecting a Purchase Card Provider 31 Appendix C List of Recommendation 32 Appendix D Management Responses 34
Table of Contents
CAL‐CardProgram CountywideAudit AuditNo3108
Executive Summary
Executive SummaryOn February 5 2013 the Sonoma County (County) Board of Supervisors adopted the CAL‐Card review plan which requires the County Administrator the County Auditor‐ControllerTreasurer‐Tax Collector (ACTTC) and the General Services Department to implement anaction plan to ensure continued compliance with the County policies and the effectivenessof the CAL‐Card program Our audit is a part of that plan and covers the CAL‐Card purchase transactions from FY1011 to FY1112 Our primary objectives were to determine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
The County spends approximately $2 million annually through the CAL‐Card program The CAL‐Card can be used to obtain supplies and for travel expenses within the Countyrsquos guidelines The Water Agency by far is the most frequent user accounting forapproximately 43 of the total annual CAL‐Card purchases The next most frequent user theSheriff Departmentaccounts foronly9 ofthetotalannualpurchases
Currently department heads are able to purchase goods and supplies valued at $2500 ontheir own under the delegated purchasing agreement executed in 2000 Individual CAL‐Cardtransactionsarelimitedto $2500based onthesameagreement
The County policy prohibits the use of the CAL‐Card to procure certain types of goods and services Due to the nature of these transactions reviews and approvals performed by thePurchasingDivision (Purchasing) and otherCounty departments ordivisions are necessaryto reduce a variety of risks Agreements for work performed on‐site for example require Purchasing in consultation with the Risk Management Division (Risk Management) to assessthe adequacyofthevendor insurance coverage
The policies procedures and internal controls over the CAL‐Card program are generallyadequately designed to detect fraudulent improper or abusive transactions However theexceptions noted during the audit (See details at Opportunities for Improvement section) and our discussions with Purchasing and ACTTC staff indicate that internal control procedures at the department level are not being adequately complied with Therefore weconclude that the internal control system over the CAL‐Card program is not functioning effectivelyas intendedto prevent unallowablepurchases
In order to cost effectively reduce risks to an acceptable level an internal control systemrelies on detective as well as preventative controls Together these two types of controlsachieve the objective of lowering the overall risk that errors and irregularities will occur
CAL‐CardProgram CountywideAudit AuditNo3108 Page1
Executive Summary
and not bedetected in a timely manner Giventhat the department levelcontrols(CAL‐Card usersrsquo awareness and Department Approving Officialsrsquo (AO) reviews) are notfunction
occur
nature a
a
Ourrev
ningdn
oeffectt be d
ivelyetec
we consid
ndvolumeoftheCAL‐Carted in a tim
ereltyhemaonvernearll torisk be
thhaight Tunau
histhorized riskwill
trincreaseansactions
aswtheill
managingtheCAL‐Cardprogram iew also
dtrans
sh hatt he
actionsincreas
ows t C
e
o u nty canrealize
significant
savingst hroughp roactively
inTh eitsfo
ellntowir
ietyng i
insaAsppendixum
maryDofoAurmroreecom
detmaeilneddat
dioiscussionnsMana
referencedisgementrsquos
response is
reportasprovided in theb
ody
included
Observatio
of the
purchases
The intern
al
n 1 Strengthen Controls to Reduce Unauthorized Purchases (Page 13)
purchasesare T
hec
arenotexecuted
ontrolsCAL‐Card
areusersrsquono
t fuanctionwareness
ing
effectively to prevent unauthorized CAL‐Card
the primarypreventative controls
ofproper to ens
spureending
thata unndallowableaccountability
transacfortionsthe
iAlthoughtem
s
theCAL‐Cardprogramrsquosblocking feature isutilized topreventsomeprohibited
Weand
f unallooundcar
dsheverol
dealrsicnstaould
nces
s till
where makeu
enmployeesallowa
bl
ev piolaturc
ha
sesase
videnced
wableitemswerepurchasedauthorizationsed
werepolicies
nota
n
odbtainedguidelin
by our est
xpenditur
es t
ele
trav
bypasspurchasingcontrols
R
e
swere mad
ewithout
travel
re‐approval
p
a ndt
ransactio
whnserewere
results
requirestr
ictede
split
d
to
Controls such
discouragepurchases
futureA
sasev reviews
violaidenced
tions
byby AOsrep
andeat
ACCTC violatio
staffns
report the
viola
tions W
detectthe con
rathertrols
tchaurnrentlypreven
i
the
n
charges
cardholders
tunauthorized
other prohibited
trans
actions
plac
e do not
transactio
ns
the cardholders
In
amajority
ofthese
werehen
reqACuTiredT
C
Atoccreimburseou
nts Painstyab
alen (cesAP)the s
AOsdidnotdetectand
such as work performed the
o
premise
Countyn
ftoarff p
s requested
identified ersonal
and AOs were imply notified and
ssu h
oc se
r pxlpite p nsuersc F
to ensureh asoesr
complianceinthefuture
We
tran shaavection
discusseds o n page
1
a
includes
number
without a policy that
6 H
violators
of strategies
for reducing
the rate
of
odeactivwever
atingthe effectiveness of such controls will
unauthorized b
e limite
d
The
Observatio
County
n
c
harged
2 Strengthen
$90518
Controls
tomeal
over
expenses
Meal
suspending
Expenses
o
(Page
r can
celling
17)
accounts of repeat
meals)out
of w approximately
hichControls should be
$560stre
was sp
inentthe
through
following
the
ngthened00
within
the
C
AL‐Car
aCreasounty
d(as program
in town in F
businessY1112
providedm
CAL‐CardProgram
ealexpensesare
County
effectivelymanaged
t
o ensure t hat County‐
AuditNo3108
wideA
udit
Page2
Executive Summary
A Control Weakness over DocumentationThe current policy does not require the cardholder to submit a detailed listing of items purchased for the CAL‐Card meal expenses As a result reviewers are not able todetermine if prohibited items such as alcohol were purchased and paid by the County The Countyshouldre‐assessthecurrent policyfor adequacytobetterdefine thedocumentation standards
B Re‐Evaluate the Current Meal PolicyThecurrent policyallowsmealreimbursementforout‐of‐towntravelof$90perpersonperday regardless of the travel destination County departments at their discretion may usethe Federal reimbursement rates which vary based on the travel destinations Based onour analysis the County could have potentialsavings in out‐of‐town meal expenses rangingfrom 17 to as much as 54 by adopting Federal rates The meals reimbursement policyshould be reviewed periodically to ensure that reimbursements closely reflect the actualcost
The current in County meal reimbursement policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documented in detail We noted a number of the CAL‐Card charges were forbreakfast for events such as management team and combined fund drive kickoff meetingsAlthough the business purpose was indicated we were unable to determine why it neededtobeconductedoverthemeal
As evidenced by high percentage of in County meal (62 of total CAL‐Card meal expenses) allowable practices should be better defined to reduce the risk of wasteful spending CAL‐Card meal purchases that do not meet the Countyrsquos requirements should be consideredunallowableafter adequatetraininghasbeen providedto theCAL‐CardusersandAOs
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions (Page 21)
Currently the ACTTCrsquos AP section is reviewing 100 of the CAL‐Card transactions forcompliance with the Countyrsquos guidelines Between February 2013 and July 2013 $281 personal expenses were identified and reimbursed from responsible employees Howeverthere were no consequences on the cardholders or the departments for other violationsnotedsuchasworkperformedon premisesor splitpurchasestransactions
Auditing a sample of transactions selected based on risk together with a policy to address misuse such as deactivation suspension or cancellation of accounts of repeat violators wouldbeamorecosteffectivealternative tothecurrent practice
Observation 4 Consider Deactivating Infrequently Used Cards (Page 22)
Best practices suggest that organizations issue the minimum number of cards necessary tomeet their business needs The risk of misuse abuse and fraud increases as the number ofcardsinuseincreases
CAL‐CardProgram CountywideAudit AuditNo3108 Page3
Executive Summary
The County does not have any procedures in place to identify infrequent users and assess their continued need for the cards Purchasing should monitor card usage and in consultation withtheuserdepartmentsdeactivateinfrequently usedcardsasnecessary
Observation 5 Establish Proper Spend Limits and Commodity Ranges (Page 23)
A The CAL‐Card Program Expansion To ensure that the CAL‐Card program continues to meet its objectives spend limits and commodity ranges should be periodically reviewed No such review has been performedfor the program since its inception in 2000 when the single transaction limit was set at $2500 Our analysis indicates that the increase of the individual CAL‐Card transaction limit to $5000 will result in approximately 300 additional transactions such as office suppliesand smalltoolseligible for theCAL‐Cardprogram
B Effective Use of ResourcesCurrently Buyers spend an average of four hours on each transaction processed throughtheregularpurchasingprocessBy shifting low dollarvaluetransactions wherethe Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar valuetransactions analysisandotheractivitiesthatwouldaddgreatervalue
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs and allocate its resources to more critical areas such as contract negotiation reviewofbidsandpreparationof specification
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings (Page 25)
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Our analysis indicates that strategies discussed above could be applied to approximately$600000 in CAL‐Card transactions representing top vendors and frequently used airlinesand hotels Purchasing should periodically perform a spend analysis and use thatinformation to better negotiate discounts explore potential purchasing partners and refineotherareasofitsoverall purchasingstrategy
CAL‐CardProgram CountywideAudit AuditNo3108 Page4
Executive Summary
B Require Departments to Purchase through BPO Agreements or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other te have been pre‐negotiated The County also ticipates in Western State
93 par
Contracting rms
(WSCA) agreement formed in 19 which allows participating Alliancegovernment entities to join together in cooperative multi‐State contracting Currently the C d es not have a process n p ace to ensu e th t po ential BPO and WSCA elig ble iCoAuLn‐Cty i l r
da
dt
ardo transactions are identified and purchase un er the terms of appropriate
contracts Approximately $96000 in such CAL‐Card transactions were processed in FY1112
Purchasing should uexplore means for obtaining disco nts for th CAL‐Card purchasescovered under the County BPOs and WSCA Arrangements could be
emade with respective
vendors which will allow users to identify appropriate agreements at the time of thepurchase to receive discounts An ongoing monitoring of BPO and WSCA eligible transactionswillensure continuedeffectivenessoftheprocedureslistedabove
C Maximize Use of the CAL‐Card to Achieve Higher Level of Efficiency The CAL‐Card program is successfully achieving its objectives by providing a convenient and cost effective alternative to the regular purchasing process Department managers are able to procure goods and service in a timely manner The processing cost of $27 per warrantisavoidedbyusingthe CAL‐Card
Our analysis indicates that 1275 small dollar value transactions through the regular allyput
accounts payable process in FY1112 could have been potenti paid through the CAL‐Card program saving approximately $20000 in warrant production os t Purchasinshould periodically identify CAL‐Card eligible transactions processed thro
c nd work
gugh AP a
withtheuserdepartmentstoexpandtheCAL‐Cardusewhereappropriate
D Explore the Possibilities of Partnering with Other Card ProvidersPurchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftrans c on o st
kc nter y
dstem lso a lows on lin access f i la t i
Us t
de s The s l or r ev ew and approva
functions S Bco an oes not provi e the
ase features to th
ee County As a result numerous
hours of data entry time is expended o enter the CAL‐Card transaction in the Countyrsquos i
My
An ili e ices of
h
dtaccount ng s stem The Cou ty has ut
t zed the s rv US Bank throu h the S ate
negotiated aster Services greement since 2006 Partners ip with othegr provi ers
shouldbeexploredfor better termsconditionsandfeaturessuchasabove
We strongly recommend that management develop a plan that prioritizes recommendations and establishes timelines for implementation For some of ourrecommendations additional research may be required before specific steps and timelinescan be determined I anternal Audit will provide ssistance where needed and perfo mfollow‐ups based on managementrsquos implementation plan or at least on a six‐month ba
rsis
untilmajorissuesare resolved
CAL‐CardProgram CountywideAudit AuditNo3108 Page5
Introduction amp Background
IntroductionWeconducted
have
Practice of
completed
theInternal
audit
the
Auditingin a
auditccordance (St
of
andards)
thewSithonomathe
analyze eva
International Standards for the Professional
objectives Wluatee believ
ande documentthat the evid
sufficenceient
Countyrsquos
(County) CAL‐Card program We
resultsobserva
ndrecommenda
tions
a
informaThese S
tiontandards require that we identify
tionscobontainedtained provides
and
aev
ridence
itreporteasonable
t
ouraud
o
in
The purpose of this audit report is to furnish management
independent
achbasisieve
forauditthe
analys esrecommendations
andot
her
informa
and objective
auditreportisatoolto
helpm
anagement
identifyation
concerning
t
he
act ivities reviewed The
throughoutWewouldlike
theaudittothankmanagementand
ndimplemen
for their
timprovements
staff
timeinformation and cooperation
Background
OverviewThe
ptraditionurc
Countyal paper implement
and ledabor‐intens
the purchivease
ofCa
and
procurementcard(CAL‐Card)
process
programfor
in2000tostreamline
certain
small dollar
the
value
requ
less
hliafosersniCa Tu
rhreeCntAlyL
‐Ct
haerdCAalLl o‐Cwasrtd
hiesCmoaunaged
oisfiftiicoenss toord rireeccetliyvinmgarkee l w o a
transacp
o d ll rnvatyludee
than$2500per tionorts
including TheC
AtaxesL ‐Ca
bpyaUrtmSeBntasnBkoinarpartnershipdofSupervisor
withst tate
uagencheS
pdr
ies
rIcc
tahnasbeesu sweidthout
canalsobetouosedb tpareparing
forin s
traveluppli
e purchase
esxpenses costing
allowedwithin
the Cou
ntyrsquos
Travel
and
Meal Reimbursement
Countybusiness
Polic
y guidelin
es
while on
The rdsystem
mCAL‐Ca
usesmerchantcategorycode(MCC)toidentifythetypeofbusinessa
ecaerrdc
hhoalndtecr
oisn adbul c ett
s
o Tpuhre
cChaountyuses
MCCsto
cont
rolthe
ty
pes ofproducts
or
services
xa mp
leareproh
ibited
for
saellPcau
rrd
chhoal
sdie
nrg
soafntd
imaettsehmarpetssaa
nrdedidaentt
ing
or
bettings
ervices fo
ar
Tonhteh er
ach
Ce
Am
(Purchasing)authorizationandapprovalL‐C rd
an its rsquosnMoCtCtoE b
aec husceadrd
fhora ts raasninsagcletiotrnasn sthacatti ro neqliumiriet tand
ifieda monthlyandblocked
spend
blimitased
he
In
Purchasing Divisionrsquos
s$2249016ig
FY1112
n au
CAL‐ C arsde Ur
ach
Cou
agEthe
emeCounty
sreers M
nta
nty
fehmployee
nouraml wT
ad approximately
oissued
h provideich wa
292 cardholders who charged a total of
guida
a
s lasnC
tceAL‐Card
r t
is
eocard
equired
v ised
holders n
r
i
Janthe tCountyo
attend
dev
traeloped
in ing
atnhed
intranet
gsapurPDFcal_card_user_manualpdf)uary 2013 (httpsc
‐
In(ATTC)
February 2013 Purchasing
ApprovijoinngO
tlyf
ficpresenials(
AtOesd)theAll
an
andu
County Auditor‐
c anrdalhorefreshldersa n
erdA traOinsa ingC
e toontroller Trea
r r eqaullirceardholdersd toa
surer‐Tax
Collector
c know
andledg
Deepartmentreceiving
traininginordertocontinueperformingtheirassignedfunctionsTh traie ningprovidedan
CAL‐CardProgram CountywideAudit AuditNo3108 Page6
Introduction amp Background
overview of the CAL‐Card program and policies guidelines and procedures thatcardholders and AOs are required to comply with Key areas such as roles andresponsibilities
author
ized
key componen
t of
the
programrsquos
u se an
idntrere qnalui
recdontroldocu
msystenemta
tiodesignw
enedrec
toovered
redu
cTe tr
noncompliancewithpo
liciesa
ndp
roceduresandtoestablishacc
aining
ountability
he risk
is o
af
theAs we
County discuss
as onwell
pageas
24indiv
datiduala provided
department
y
b the
developingeffectivepurchasingstrategiesVendor
and MCC can be used to compensate for the
n
spendinCAL‐Car
d
provide
can
lac
r
kprov
beu
sed
toestablish
purchasingcardenviroorm
ally r
eq
u ired
b
ynment
th
e trad itional
proc
urement
g profiles which can be useful in
opf pidedre‐a
fue tahtourriezsationsuch
pa
rocssp
eessnd limits
rocedures but not practica thatl
in
ias
PoliciesTheforimplement
and Procedures Countyrsquos Purchasing
ingtheprogram Agent
at isthe
t
he
depar
C
AL‐CardProgramAdministratorwho
programand enforcing
tment levelprovidin
g training
a
Departmearnte 1)
thetheprCogramAL‐Card
policiesuser 2)
andthe
p roceduresDepartmen
The key
roles in
Billing Officialand 4)theProgramAdminis
trtaAOtor
T3)hethe
responsibilitACCT
isresponsible
aredescrib
e
din
t
heCAL‐Cardpo
liciesandproceduremanual
nd
Cthe
d
Aevelopin
PCAL‐Card
ies sotafffeach
g
4)
Departmentf
headssettheindividualtransaction(upto$2500)andmonthlyspendlimits
appropriataonrd eau hrc
pc c
haarsdi
nignpuosl
eicie
sThe
cardholde
rs arerespo
nsib
le
for com
plyin
edocumenta
t
g
activities
toensur
ethat
wi
th
th
eC
AL‐Card
aprocedurespplicatio
ns
The Billing
or can
cella
ionpre
toparsuinpg
all
purchases
ptohretmto CA
een
appropriatcthhaly
arh rges
LT‐ChaerdAOPsurrcehvaiesweRandepoapprortand
vepraccountoviding
Officia
ls c
oordinate
einaccordancewiththepoliciesand
receives and audits the CAL‐Cati
on ofrd in
paaymentctiv
e o
nes
T
activities
he A
CT
T
suchC A
as
lcco
c aimstoensurethatea
processinguchntschargePayable
o
f new
supported
card
ff
is a
(AP)dequat
stelya
CAL‐CardProgram CountywideAudit AuditNo3108 Page7
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
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er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Executive Summary 1 Introduction amp Background 6 The Countyrsquos CAL‐Card Spending Profile 8 Objectives amp Scope 11 Methodology Sample Selection amp Results 12
Opportunities for Improvement Observations and Recommendations 13
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases 13
ARestrictedandUnallowablePurchases
BLackofProperAuthorization
CUntimelyTravelAuthorization
DSplitTransactions
Observation 2 Strengthen Controls over Meal Expenses 17
AControlWeaknessoverDocumentation
BRe‐EvaluatetheCurrentMealPolicy
Observation 3 Adopt A Risk Based Approach to Audit the CAL‐Card Program 21
Observation 4 Consider Deactivating Infrequently Used Cards 22
Observation 5 Establish Proper Spend Limits and Commodity Ranges 23
ATheCal‐CardProgramExpansion
BEffective UseofResources
Observation 6 Proactively Manage the CAL‐Card to Achieve Cost Savings 25
APerformSpendAnalysistoSupportCountywidePurchasingStrategies
BRequireDepartmentstoPurchasethroughBPOorGroupBuying Contracts
CMaximizeUseoftheCAL‐Card toAchieveHighLevelof Efficiency
DExplorethePossibilitiesofPartneringwith OtherCard Providers
Appendix A Best Practices for Purchase Card Program Management 30 Appendix B Best Practices for Selecting a Purchase Card Provider 31 Appendix C List of Recommendation 32 Appendix D Management Responses 34
Table of Contents
CAL‐CardProgram CountywideAudit AuditNo3108
Executive Summary
Executive SummaryOn February 5 2013 the Sonoma County (County) Board of Supervisors adopted the CAL‐Card review plan which requires the County Administrator the County Auditor‐ControllerTreasurer‐Tax Collector (ACTTC) and the General Services Department to implement anaction plan to ensure continued compliance with the County policies and the effectivenessof the CAL‐Card program Our audit is a part of that plan and covers the CAL‐Card purchase transactions from FY1011 to FY1112 Our primary objectives were to determine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
The County spends approximately $2 million annually through the CAL‐Card program The CAL‐Card can be used to obtain supplies and for travel expenses within the Countyrsquos guidelines The Water Agency by far is the most frequent user accounting forapproximately 43 of the total annual CAL‐Card purchases The next most frequent user theSheriff Departmentaccounts foronly9 ofthetotalannualpurchases
Currently department heads are able to purchase goods and supplies valued at $2500 ontheir own under the delegated purchasing agreement executed in 2000 Individual CAL‐Cardtransactionsarelimitedto $2500based onthesameagreement
The County policy prohibits the use of the CAL‐Card to procure certain types of goods and services Due to the nature of these transactions reviews and approvals performed by thePurchasingDivision (Purchasing) and otherCounty departments ordivisions are necessaryto reduce a variety of risks Agreements for work performed on‐site for example require Purchasing in consultation with the Risk Management Division (Risk Management) to assessthe adequacyofthevendor insurance coverage
The policies procedures and internal controls over the CAL‐Card program are generallyadequately designed to detect fraudulent improper or abusive transactions However theexceptions noted during the audit (See details at Opportunities for Improvement section) and our discussions with Purchasing and ACTTC staff indicate that internal control procedures at the department level are not being adequately complied with Therefore weconclude that the internal control system over the CAL‐Card program is not functioning effectivelyas intendedto prevent unallowablepurchases
In order to cost effectively reduce risks to an acceptable level an internal control systemrelies on detective as well as preventative controls Together these two types of controlsachieve the objective of lowering the overall risk that errors and irregularities will occur
CAL‐CardProgram CountywideAudit AuditNo3108 Page1
Executive Summary
and not bedetected in a timely manner Giventhat the department levelcontrols(CAL‐Card usersrsquo awareness and Department Approving Officialsrsquo (AO) reviews) are notfunction
occur
nature a
a
Ourrev
ningdn
oeffectt be d
ivelyetec
we consid
ndvolumeoftheCAL‐Carted in a tim
ereltyhemaonvernearll torisk be
thhaight Tunau
histhorized riskwill
trincreaseansactions
aswtheill
managingtheCAL‐Cardprogram iew also
dtrans
sh hatt he
actionsincreas
ows t C
e
o u nty canrealize
significant
savingst hroughp roactively
inTh eitsfo
ellntowir
ietyng i
insaAsppendixum
maryDofoAurmroreecom
detmaeilneddat
dioiscussionnsMana
referencedisgementrsquos
response is
reportasprovided in theb
ody
included
Observatio
of the
purchases
The intern
al
n 1 Strengthen Controls to Reduce Unauthorized Purchases (Page 13)
purchasesare T
hec
arenotexecuted
ontrolsCAL‐Card
areusersrsquono
t fuanctionwareness
ing
effectively to prevent unauthorized CAL‐Card
the primarypreventative controls
ofproper to ens
spureending
thata unndallowableaccountability
transacfortionsthe
iAlthoughtem
s
theCAL‐Cardprogramrsquosblocking feature isutilized topreventsomeprohibited
Weand
f unallooundcar
dsheverol
dealrsicnstaould
nces
s till
where makeu
enmployeesallowa
bl
ev piolaturc
ha
sesase
videnced
wableitemswerepurchasedauthorizationsed
werepolicies
nota
n
odbtainedguidelin
by our est
xpenditur
es t
ele
trav
bypasspurchasingcontrols
R
e
swere mad
ewithout
travel
re‐approval
p
a ndt
ransactio
whnserewere
results
requirestr
ictede
split
d
to
Controls such
discouragepurchases
futureA
sasev reviews
violaidenced
tions
byby AOsrep
andeat
ACCTC violatio
staffns
report the
viola
tions W
detectthe con
rathertrols
tchaurnrentlypreven
i
the
n
charges
cardholders
tunauthorized
other prohibited
trans
actions
plac
e do not
transactio
ns
the cardholders
In
amajority
ofthese
werehen
reqACuTiredT
C
Atoccreimburseou
nts Painstyab
alen (cesAP)the s
AOsdidnotdetectand
such as work performed the
o
premise
Countyn
ftoarff p
s requested
identified ersonal
and AOs were imply notified and
ssu h
oc se
r pxlpite p nsuersc F
to ensureh asoesr
complianceinthefuture
We
tran shaavection
discusseds o n page
1
a
includes
number
without a policy that
6 H
violators
of strategies
for reducing
the rate
of
odeactivwever
atingthe effectiveness of such controls will
unauthorized b
e limite
d
The
Observatio
County
n
c
harged
2 Strengthen
$90518
Controls
tomeal
over
expenses
Meal
suspending
Expenses
o
(Page
r can
celling
17)
accounts of repeat
meals)out
of w approximately
hichControls should be
$560stre
was sp
inentthe
through
following
the
ngthened00
within
the
C
AL‐Car
aCreasounty
d(as program
in town in F
businessY1112
providedm
CAL‐CardProgram
ealexpensesare
County
effectivelymanaged
t
o ensure t hat County‐
AuditNo3108
wideA
udit
Page2
Executive Summary
A Control Weakness over DocumentationThe current policy does not require the cardholder to submit a detailed listing of items purchased for the CAL‐Card meal expenses As a result reviewers are not able todetermine if prohibited items such as alcohol were purchased and paid by the County The Countyshouldre‐assessthecurrent policyfor adequacytobetterdefine thedocumentation standards
B Re‐Evaluate the Current Meal PolicyThecurrent policyallowsmealreimbursementforout‐of‐towntravelof$90perpersonperday regardless of the travel destination County departments at their discretion may usethe Federal reimbursement rates which vary based on the travel destinations Based onour analysis the County could have potentialsavings in out‐of‐town meal expenses rangingfrom 17 to as much as 54 by adopting Federal rates The meals reimbursement policyshould be reviewed periodically to ensure that reimbursements closely reflect the actualcost
The current in County meal reimbursement policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documented in detail We noted a number of the CAL‐Card charges were forbreakfast for events such as management team and combined fund drive kickoff meetingsAlthough the business purpose was indicated we were unable to determine why it neededtobeconductedoverthemeal
As evidenced by high percentage of in County meal (62 of total CAL‐Card meal expenses) allowable practices should be better defined to reduce the risk of wasteful spending CAL‐Card meal purchases that do not meet the Countyrsquos requirements should be consideredunallowableafter adequatetraininghasbeen providedto theCAL‐CardusersandAOs
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions (Page 21)
Currently the ACTTCrsquos AP section is reviewing 100 of the CAL‐Card transactions forcompliance with the Countyrsquos guidelines Between February 2013 and July 2013 $281 personal expenses were identified and reimbursed from responsible employees Howeverthere were no consequences on the cardholders or the departments for other violationsnotedsuchasworkperformedon premisesor splitpurchasestransactions
Auditing a sample of transactions selected based on risk together with a policy to address misuse such as deactivation suspension or cancellation of accounts of repeat violators wouldbeamorecosteffectivealternative tothecurrent practice
Observation 4 Consider Deactivating Infrequently Used Cards (Page 22)
Best practices suggest that organizations issue the minimum number of cards necessary tomeet their business needs The risk of misuse abuse and fraud increases as the number ofcardsinuseincreases
CAL‐CardProgram CountywideAudit AuditNo3108 Page3
Executive Summary
The County does not have any procedures in place to identify infrequent users and assess their continued need for the cards Purchasing should monitor card usage and in consultation withtheuserdepartmentsdeactivateinfrequently usedcardsasnecessary
Observation 5 Establish Proper Spend Limits and Commodity Ranges (Page 23)
A The CAL‐Card Program Expansion To ensure that the CAL‐Card program continues to meet its objectives spend limits and commodity ranges should be periodically reviewed No such review has been performedfor the program since its inception in 2000 when the single transaction limit was set at $2500 Our analysis indicates that the increase of the individual CAL‐Card transaction limit to $5000 will result in approximately 300 additional transactions such as office suppliesand smalltoolseligible for theCAL‐Cardprogram
B Effective Use of ResourcesCurrently Buyers spend an average of four hours on each transaction processed throughtheregularpurchasingprocessBy shifting low dollarvaluetransactions wherethe Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar valuetransactions analysisandotheractivitiesthatwouldaddgreatervalue
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs and allocate its resources to more critical areas such as contract negotiation reviewofbidsandpreparationof specification
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings (Page 25)
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Our analysis indicates that strategies discussed above could be applied to approximately$600000 in CAL‐Card transactions representing top vendors and frequently used airlinesand hotels Purchasing should periodically perform a spend analysis and use thatinformation to better negotiate discounts explore potential purchasing partners and refineotherareasofitsoverall purchasingstrategy
CAL‐CardProgram CountywideAudit AuditNo3108 Page4
Executive Summary
B Require Departments to Purchase through BPO Agreements or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other te have been pre‐negotiated The County also ticipates in Western State
93 par
Contracting rms
(WSCA) agreement formed in 19 which allows participating Alliancegovernment entities to join together in cooperative multi‐State contracting Currently the C d es not have a process n p ace to ensu e th t po ential BPO and WSCA elig ble iCoAuLn‐Cty i l r
da
dt
ardo transactions are identified and purchase un er the terms of appropriate
contracts Approximately $96000 in such CAL‐Card transactions were processed in FY1112
Purchasing should uexplore means for obtaining disco nts for th CAL‐Card purchasescovered under the County BPOs and WSCA Arrangements could be
emade with respective
vendors which will allow users to identify appropriate agreements at the time of thepurchase to receive discounts An ongoing monitoring of BPO and WSCA eligible transactionswillensure continuedeffectivenessoftheprocedureslistedabove
C Maximize Use of the CAL‐Card to Achieve Higher Level of Efficiency The CAL‐Card program is successfully achieving its objectives by providing a convenient and cost effective alternative to the regular purchasing process Department managers are able to procure goods and service in a timely manner The processing cost of $27 per warrantisavoidedbyusingthe CAL‐Card
Our analysis indicates that 1275 small dollar value transactions through the regular allyput
accounts payable process in FY1112 could have been potenti paid through the CAL‐Card program saving approximately $20000 in warrant production os t Purchasinshould periodically identify CAL‐Card eligible transactions processed thro
c nd work
gugh AP a
withtheuserdepartmentstoexpandtheCAL‐Cardusewhereappropriate
D Explore the Possibilities of Partnering with Other Card ProvidersPurchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftrans c on o st
kc nter y
dstem lso a lows on lin access f i la t i
Us t
de s The s l or r ev ew and approva
functions S Bco an oes not provi e the
ase features to th
ee County As a result numerous
hours of data entry time is expended o enter the CAL‐Card transaction in the Countyrsquos i
My
An ili e ices of
h
dtaccount ng s stem The Cou ty has ut
t zed the s rv US Bank throu h the S ate
negotiated aster Services greement since 2006 Partners ip with othegr provi ers
shouldbeexploredfor better termsconditionsandfeaturessuchasabove
We strongly recommend that management develop a plan that prioritizes recommendations and establishes timelines for implementation For some of ourrecommendations additional research may be required before specific steps and timelinescan be determined I anternal Audit will provide ssistance where needed and perfo mfollow‐ups based on managementrsquos implementation plan or at least on a six‐month ba
rsis
untilmajorissuesare resolved
CAL‐CardProgram CountywideAudit AuditNo3108 Page5
Introduction amp Background
IntroductionWeconducted
have
Practice of
completed
theInternal
audit
the
Auditingin a
auditccordance (St
of
andards)
thewSithonomathe
analyze eva
International Standards for the Professional
objectives Wluatee believ
ande documentthat the evid
sufficenceient
Countyrsquos
(County) CAL‐Card program We
resultsobserva
ndrecommenda
tions
a
informaThese S
tiontandards require that we identify
tionscobontainedtained provides
and
aev
ridence
itreporteasonable
t
ouraud
o
in
The purpose of this audit report is to furnish management
independent
achbasisieve
forauditthe
analys esrecommendations
andot
her
informa
and objective
auditreportisatoolto
helpm
anagement
identifyation
concerning
t
he
act ivities reviewed The
throughoutWewouldlike
theaudittothankmanagementand
ndimplemen
for their
timprovements
staff
timeinformation and cooperation
Background
OverviewThe
ptraditionurc
Countyal paper implement
and ledabor‐intens
the purchivease
ofCa
and
procurementcard(CAL‐Card)
process
programfor
in2000tostreamline
certain
small dollar
the
value
requ
less
hliafosersniCa Tu
rhreeCntAlyL
‐Ct
haerdCAalLl o‐Cwasrtd
hiesCmoaunaged
oisfiftiicoenss toord rireeccetliyvinmgarkee l w o a
transacp
o d ll rnvatyludee
than$2500per tionorts
including TheC
AtaxesL ‐Ca
bpyaUrtmSeBntasnBkoinarpartnershipdofSupervisor
withst tate
uagencheS
pdr
ies
rIcc
tahnasbeesu sweidthout
canalsobetouosedb tpareparing
forin s
traveluppli
e purchase
esxpenses costing
allowedwithin
the Cou
ntyrsquos
Travel
and
Meal Reimbursement
Countybusiness
Polic
y guidelin
es
while on
The rdsystem
mCAL‐Ca
usesmerchantcategorycode(MCC)toidentifythetypeofbusinessa
ecaerrdc
hhoalndtecr
oisn adbul c ett
s
o Tpuhre
cChaountyuses
MCCsto
cont
rolthe
ty
pes ofproducts
or
services
xa mp
leareproh
ibited
for
saellPcau
rrd
chhoal
sdie
nrg
soafntd
imaettsehmarpetssaa
nrdedidaentt
ing
or
bettings
ervices fo
ar
Tonhteh er
ach
Ce
Am
(Purchasing)authorizationandapprovalL‐C rd
an its rsquosnMoCtCtoE b
aec husceadrd
fhora ts raasninsagcletiotrnasn sthacatti ro neqliumiriet tand
ifieda monthlyandblocked
spend
blimitased
he
In
Purchasing Divisionrsquos
s$2249016ig
FY1112
n au
CAL‐ C arsde Ur
ach
Cou
agEthe
emeCounty
sreers M
nta
nty
fehmployee
nouraml wT
ad approximately
oissued
h provideich wa
292 cardholders who charged a total of
guida
a
s lasnC
tceAL‐Card
r t
is
eocard
equired
v ised
holders n
r
i
Janthe tCountyo
attend
dev
traeloped
in ing
atnhed
intranet
gsapurPDFcal_card_user_manualpdf)uary 2013 (httpsc
‐
In(ATTC)
February 2013 Purchasing
ApprovijoinngO
tlyf
ficpresenials(
AtOesd)theAll
an
andu
County Auditor‐
c anrdalhorefreshldersa n
erdA traOinsa ingC
e toontroller Trea
r r eqaullirceardholdersd toa
surer‐Tax
Collector
c know
andledg
Deepartmentreceiving
traininginordertocontinueperformingtheirassignedfunctionsTh traie ningprovidedan
CAL‐CardProgram CountywideAudit AuditNo3108 Page6
Introduction amp Background
overview of the CAL‐Card program and policies guidelines and procedures thatcardholders and AOs are required to comply with Key areas such as roles andresponsibilities
author
ized
key componen
t of
the
programrsquos
u se an
idntrere qnalui
recdontroldocu
msystenemta
tiodesignw
enedrec
toovered
redu
cTe tr
noncompliancewithpo
liciesa
ndp
roceduresandtoestablishacc
aining
ountability
he risk
is o
af
theAs we
County discuss
as onwell
pageas
24indiv
datiduala provided
department
y
b the
developingeffectivepurchasingstrategiesVendor
and MCC can be used to compensate for the
n
spendinCAL‐Car
d
provide
can
lac
r
kprov
beu
sed
toestablish
purchasingcardenviroorm
ally r
eq
u ired
b
ynment
th
e trad itional
proc
urement
g profiles which can be useful in
opf pidedre‐a
fue tahtourriezsationsuch
pa
rocssp
eessnd limits
rocedures but not practica thatl
in
ias
PoliciesTheforimplement
and Procedures Countyrsquos Purchasing
ingtheprogram Agent
at isthe
t
he
depar
C
AL‐CardProgramAdministratorwho
programand enforcing
tment levelprovidin
g training
a
Departmearnte 1)
thetheprCogramAL‐Card
policiesuser 2)
andthe
p roceduresDepartmen
The key
roles in
Billing Officialand 4)theProgramAdminis
trtaAOtor
T3)hethe
responsibilitACCT
isresponsible
aredescrib
e
din
t
heCAL‐Cardpo
liciesandproceduremanual
nd
Cthe
d
Aevelopin
PCAL‐Card
ies sotafffeach
g
4)
Departmentf
headssettheindividualtransaction(upto$2500)andmonthlyspendlimits
appropriataonrd eau hrc
pc c
haarsdi
nignpuosl
eicie
sThe
cardholde
rs arerespo
nsib
le
for com
plyin
edocumenta
t
g
activities
toensur
ethat
wi
th
th
eC
AL‐Card
aprocedurespplicatio
ns
The Billing
or can
cella
ionpre
toparsuinpg
all
purchases
ptohretmto CA
een
appropriatcthhaly
arh rges
LT‐ChaerdAOPsurrcehvaiesweRandepoapprortand
vepraccountoviding
Officia
ls c
oordinate
einaccordancewiththepoliciesand
receives and audits the CAL‐Cati
on ofrd in
paaymentctiv
e o
nes
T
activities
he A
CT
T
suchC A
as
lcco
c aimstoensurethatea
processinguchntschargePayable
o
f new
supported
card
ff
is a
(AP)dequat
stelya
CAL‐CardProgram CountywideAudit AuditNo3108 Page7
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Executive Summary
Executive SummaryOn February 5 2013 the Sonoma County (County) Board of Supervisors adopted the CAL‐Card review plan which requires the County Administrator the County Auditor‐ControllerTreasurer‐Tax Collector (ACTTC) and the General Services Department to implement anaction plan to ensure continued compliance with the County policies and the effectivenessof the CAL‐Card program Our audit is a part of that plan and covers the CAL‐Card purchase transactions from FY1011 to FY1112 Our primary objectives were to determine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
The County spends approximately $2 million annually through the CAL‐Card program The CAL‐Card can be used to obtain supplies and for travel expenses within the Countyrsquos guidelines The Water Agency by far is the most frequent user accounting forapproximately 43 of the total annual CAL‐Card purchases The next most frequent user theSheriff Departmentaccounts foronly9 ofthetotalannualpurchases
Currently department heads are able to purchase goods and supplies valued at $2500 ontheir own under the delegated purchasing agreement executed in 2000 Individual CAL‐Cardtransactionsarelimitedto $2500based onthesameagreement
The County policy prohibits the use of the CAL‐Card to procure certain types of goods and services Due to the nature of these transactions reviews and approvals performed by thePurchasingDivision (Purchasing) and otherCounty departments ordivisions are necessaryto reduce a variety of risks Agreements for work performed on‐site for example require Purchasing in consultation with the Risk Management Division (Risk Management) to assessthe adequacyofthevendor insurance coverage
The policies procedures and internal controls over the CAL‐Card program are generallyadequately designed to detect fraudulent improper or abusive transactions However theexceptions noted during the audit (See details at Opportunities for Improvement section) and our discussions with Purchasing and ACTTC staff indicate that internal control procedures at the department level are not being adequately complied with Therefore weconclude that the internal control system over the CAL‐Card program is not functioning effectivelyas intendedto prevent unallowablepurchases
In order to cost effectively reduce risks to an acceptable level an internal control systemrelies on detective as well as preventative controls Together these two types of controlsachieve the objective of lowering the overall risk that errors and irregularities will occur
CAL‐CardProgram CountywideAudit AuditNo3108 Page1
Executive Summary
and not bedetected in a timely manner Giventhat the department levelcontrols(CAL‐Card usersrsquo awareness and Department Approving Officialsrsquo (AO) reviews) are notfunction
occur
nature a
a
Ourrev
ningdn
oeffectt be d
ivelyetec
we consid
ndvolumeoftheCAL‐Carted in a tim
ereltyhemaonvernearll torisk be
thhaight Tunau
histhorized riskwill
trincreaseansactions
aswtheill
managingtheCAL‐Cardprogram iew also
dtrans
sh hatt he
actionsincreas
ows t C
e
o u nty canrealize
significant
savingst hroughp roactively
inTh eitsfo
ellntowir
ietyng i
insaAsppendixum
maryDofoAurmroreecom
detmaeilneddat
dioiscussionnsMana
referencedisgementrsquos
response is
reportasprovided in theb
ody
included
Observatio
of the
purchases
The intern
al
n 1 Strengthen Controls to Reduce Unauthorized Purchases (Page 13)
purchasesare T
hec
arenotexecuted
ontrolsCAL‐Card
areusersrsquono
t fuanctionwareness
ing
effectively to prevent unauthorized CAL‐Card
the primarypreventative controls
ofproper to ens
spureending
thata unndallowableaccountability
transacfortionsthe
iAlthoughtem
s
theCAL‐Cardprogramrsquosblocking feature isutilized topreventsomeprohibited
Weand
f unallooundcar
dsheverol
dealrsicnstaould
nces
s till
where makeu
enmployeesallowa
bl
ev piolaturc
ha
sesase
videnced
wableitemswerepurchasedauthorizationsed
werepolicies
nota
n
odbtainedguidelin
by our est
xpenditur
es t
ele
trav
bypasspurchasingcontrols
R
e
swere mad
ewithout
travel
re‐approval
p
a ndt
ransactio
whnserewere
results
requirestr
ictede
split
d
to
Controls such
discouragepurchases
futureA
sasev reviews
violaidenced
tions
byby AOsrep
andeat
ACCTC violatio
staffns
report the
viola
tions W
detectthe con
rathertrols
tchaurnrentlypreven
i
the
n
charges
cardholders
tunauthorized
other prohibited
trans
actions
plac
e do not
transactio
ns
the cardholders
In
amajority
ofthese
werehen
reqACuTiredT
C
Atoccreimburseou
nts Painstyab
alen (cesAP)the s
AOsdidnotdetectand
such as work performed the
o
premise
Countyn
ftoarff p
s requested
identified ersonal
and AOs were imply notified and
ssu h
oc se
r pxlpite p nsuersc F
to ensureh asoesr
complianceinthefuture
We
tran shaavection
discusseds o n page
1
a
includes
number
without a policy that
6 H
violators
of strategies
for reducing
the rate
of
odeactivwever
atingthe effectiveness of such controls will
unauthorized b
e limite
d
The
Observatio
County
n
c
harged
2 Strengthen
$90518
Controls
tomeal
over
expenses
Meal
suspending
Expenses
o
(Page
r can
celling
17)
accounts of repeat
meals)out
of w approximately
hichControls should be
$560stre
was sp
inentthe
through
following
the
ngthened00
within
the
C
AL‐Car
aCreasounty
d(as program
in town in F
businessY1112
providedm
CAL‐CardProgram
ealexpensesare
County
effectivelymanaged
t
o ensure t hat County‐
AuditNo3108
wideA
udit
Page2
Executive Summary
A Control Weakness over DocumentationThe current policy does not require the cardholder to submit a detailed listing of items purchased for the CAL‐Card meal expenses As a result reviewers are not able todetermine if prohibited items such as alcohol were purchased and paid by the County The Countyshouldre‐assessthecurrent policyfor adequacytobetterdefine thedocumentation standards
B Re‐Evaluate the Current Meal PolicyThecurrent policyallowsmealreimbursementforout‐of‐towntravelof$90perpersonperday regardless of the travel destination County departments at their discretion may usethe Federal reimbursement rates which vary based on the travel destinations Based onour analysis the County could have potentialsavings in out‐of‐town meal expenses rangingfrom 17 to as much as 54 by adopting Federal rates The meals reimbursement policyshould be reviewed periodically to ensure that reimbursements closely reflect the actualcost
The current in County meal reimbursement policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documented in detail We noted a number of the CAL‐Card charges were forbreakfast for events such as management team and combined fund drive kickoff meetingsAlthough the business purpose was indicated we were unable to determine why it neededtobeconductedoverthemeal
As evidenced by high percentage of in County meal (62 of total CAL‐Card meal expenses) allowable practices should be better defined to reduce the risk of wasteful spending CAL‐Card meal purchases that do not meet the Countyrsquos requirements should be consideredunallowableafter adequatetraininghasbeen providedto theCAL‐CardusersandAOs
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions (Page 21)
Currently the ACTTCrsquos AP section is reviewing 100 of the CAL‐Card transactions forcompliance with the Countyrsquos guidelines Between February 2013 and July 2013 $281 personal expenses were identified and reimbursed from responsible employees Howeverthere were no consequences on the cardholders or the departments for other violationsnotedsuchasworkperformedon premisesor splitpurchasestransactions
Auditing a sample of transactions selected based on risk together with a policy to address misuse such as deactivation suspension or cancellation of accounts of repeat violators wouldbeamorecosteffectivealternative tothecurrent practice
Observation 4 Consider Deactivating Infrequently Used Cards (Page 22)
Best practices suggest that organizations issue the minimum number of cards necessary tomeet their business needs The risk of misuse abuse and fraud increases as the number ofcardsinuseincreases
CAL‐CardProgram CountywideAudit AuditNo3108 Page3
Executive Summary
The County does not have any procedures in place to identify infrequent users and assess their continued need for the cards Purchasing should monitor card usage and in consultation withtheuserdepartmentsdeactivateinfrequently usedcardsasnecessary
Observation 5 Establish Proper Spend Limits and Commodity Ranges (Page 23)
A The CAL‐Card Program Expansion To ensure that the CAL‐Card program continues to meet its objectives spend limits and commodity ranges should be periodically reviewed No such review has been performedfor the program since its inception in 2000 when the single transaction limit was set at $2500 Our analysis indicates that the increase of the individual CAL‐Card transaction limit to $5000 will result in approximately 300 additional transactions such as office suppliesand smalltoolseligible for theCAL‐Cardprogram
B Effective Use of ResourcesCurrently Buyers spend an average of four hours on each transaction processed throughtheregularpurchasingprocessBy shifting low dollarvaluetransactions wherethe Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar valuetransactions analysisandotheractivitiesthatwouldaddgreatervalue
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs and allocate its resources to more critical areas such as contract negotiation reviewofbidsandpreparationof specification
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings (Page 25)
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Our analysis indicates that strategies discussed above could be applied to approximately$600000 in CAL‐Card transactions representing top vendors and frequently used airlinesand hotels Purchasing should periodically perform a spend analysis and use thatinformation to better negotiate discounts explore potential purchasing partners and refineotherareasofitsoverall purchasingstrategy
CAL‐CardProgram CountywideAudit AuditNo3108 Page4
Executive Summary
B Require Departments to Purchase through BPO Agreements or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other te have been pre‐negotiated The County also ticipates in Western State
93 par
Contracting rms
(WSCA) agreement formed in 19 which allows participating Alliancegovernment entities to join together in cooperative multi‐State contracting Currently the C d es not have a process n p ace to ensu e th t po ential BPO and WSCA elig ble iCoAuLn‐Cty i l r
da
dt
ardo transactions are identified and purchase un er the terms of appropriate
contracts Approximately $96000 in such CAL‐Card transactions were processed in FY1112
Purchasing should uexplore means for obtaining disco nts for th CAL‐Card purchasescovered under the County BPOs and WSCA Arrangements could be
emade with respective
vendors which will allow users to identify appropriate agreements at the time of thepurchase to receive discounts An ongoing monitoring of BPO and WSCA eligible transactionswillensure continuedeffectivenessoftheprocedureslistedabove
C Maximize Use of the CAL‐Card to Achieve Higher Level of Efficiency The CAL‐Card program is successfully achieving its objectives by providing a convenient and cost effective alternative to the regular purchasing process Department managers are able to procure goods and service in a timely manner The processing cost of $27 per warrantisavoidedbyusingthe CAL‐Card
Our analysis indicates that 1275 small dollar value transactions through the regular allyput
accounts payable process in FY1112 could have been potenti paid through the CAL‐Card program saving approximately $20000 in warrant production os t Purchasinshould periodically identify CAL‐Card eligible transactions processed thro
c nd work
gugh AP a
withtheuserdepartmentstoexpandtheCAL‐Cardusewhereappropriate
D Explore the Possibilities of Partnering with Other Card ProvidersPurchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftrans c on o st
kc nter y
dstem lso a lows on lin access f i la t i
Us t
de s The s l or r ev ew and approva
functions S Bco an oes not provi e the
ase features to th
ee County As a result numerous
hours of data entry time is expended o enter the CAL‐Card transaction in the Countyrsquos i
My
An ili e ices of
h
dtaccount ng s stem The Cou ty has ut
t zed the s rv US Bank throu h the S ate
negotiated aster Services greement since 2006 Partners ip with othegr provi ers
shouldbeexploredfor better termsconditionsandfeaturessuchasabove
We strongly recommend that management develop a plan that prioritizes recommendations and establishes timelines for implementation For some of ourrecommendations additional research may be required before specific steps and timelinescan be determined I anternal Audit will provide ssistance where needed and perfo mfollow‐ups based on managementrsquos implementation plan or at least on a six‐month ba
rsis
untilmajorissuesare resolved
CAL‐CardProgram CountywideAudit AuditNo3108 Page5
Introduction amp Background
IntroductionWeconducted
have
Practice of
completed
theInternal
audit
the
Auditingin a
auditccordance (St
of
andards)
thewSithonomathe
analyze eva
International Standards for the Professional
objectives Wluatee believ
ande documentthat the evid
sufficenceient
Countyrsquos
(County) CAL‐Card program We
resultsobserva
ndrecommenda
tions
a
informaThese S
tiontandards require that we identify
tionscobontainedtained provides
and
aev
ridence
itreporteasonable
t
ouraud
o
in
The purpose of this audit report is to furnish management
independent
achbasisieve
forauditthe
analys esrecommendations
andot
her
informa
and objective
auditreportisatoolto
helpm
anagement
identifyation
concerning
t
he
act ivities reviewed The
throughoutWewouldlike
theaudittothankmanagementand
ndimplemen
for their
timprovements
staff
timeinformation and cooperation
Background
OverviewThe
ptraditionurc
Countyal paper implement
and ledabor‐intens
the purchivease
ofCa
and
procurementcard(CAL‐Card)
process
programfor
in2000tostreamline
certain
small dollar
the
value
requ
less
hliafosersniCa Tu
rhreeCntAlyL
‐Ct
haerdCAalLl o‐Cwasrtd
hiesCmoaunaged
oisfiftiicoenss toord rireeccetliyvinmgarkee l w o a
transacp
o d ll rnvatyludee
than$2500per tionorts
including TheC
AtaxesL ‐Ca
bpyaUrtmSeBntasnBkoinarpartnershipdofSupervisor
withst tate
uagencheS
pdr
ies
rIcc
tahnasbeesu sweidthout
canalsobetouosedb tpareparing
forin s
traveluppli
e purchase
esxpenses costing
allowedwithin
the Cou
ntyrsquos
Travel
and
Meal Reimbursement
Countybusiness
Polic
y guidelin
es
while on
The rdsystem
mCAL‐Ca
usesmerchantcategorycode(MCC)toidentifythetypeofbusinessa
ecaerrdc
hhoalndtecr
oisn adbul c ett
s
o Tpuhre
cChaountyuses
MCCsto
cont
rolthe
ty
pes ofproducts
or
services
xa mp
leareproh
ibited
for
saellPcau
rrd
chhoal
sdie
nrg
soafntd
imaettsehmarpetssaa
nrdedidaentt
ing
or
bettings
ervices fo
ar
Tonhteh er
ach
Ce
Am
(Purchasing)authorizationandapprovalL‐C rd
an its rsquosnMoCtCtoE b
aec husceadrd
fhora ts raasninsagcletiotrnasn sthacatti ro neqliumiriet tand
ifieda monthlyandblocked
spend
blimitased
he
In
Purchasing Divisionrsquos
s$2249016ig
FY1112
n au
CAL‐ C arsde Ur
ach
Cou
agEthe
emeCounty
sreers M
nta
nty
fehmployee
nouraml wT
ad approximately
oissued
h provideich wa
292 cardholders who charged a total of
guida
a
s lasnC
tceAL‐Card
r t
is
eocard
equired
v ised
holders n
r
i
Janthe tCountyo
attend
dev
traeloped
in ing
atnhed
intranet
gsapurPDFcal_card_user_manualpdf)uary 2013 (httpsc
‐
In(ATTC)
February 2013 Purchasing
ApprovijoinngO
tlyf
ficpresenials(
AtOesd)theAll
an
andu
County Auditor‐
c anrdalhorefreshldersa n
erdA traOinsa ingC
e toontroller Trea
r r eqaullirceardholdersd toa
surer‐Tax
Collector
c know
andledg
Deepartmentreceiving
traininginordertocontinueperformingtheirassignedfunctionsTh traie ningprovidedan
CAL‐CardProgram CountywideAudit AuditNo3108 Page6
Introduction amp Background
overview of the CAL‐Card program and policies guidelines and procedures thatcardholders and AOs are required to comply with Key areas such as roles andresponsibilities
author
ized
key componen
t of
the
programrsquos
u se an
idntrere qnalui
recdontroldocu
msystenemta
tiodesignw
enedrec
toovered
redu
cTe tr
noncompliancewithpo
liciesa
ndp
roceduresandtoestablishacc
aining
ountability
he risk
is o
af
theAs we
County discuss
as onwell
pageas
24indiv
datiduala provided
department
y
b the
developingeffectivepurchasingstrategiesVendor
and MCC can be used to compensate for the
n
spendinCAL‐Car
d
provide
can
lac
r
kprov
beu
sed
toestablish
purchasingcardenviroorm
ally r
eq
u ired
b
ynment
th
e trad itional
proc
urement
g profiles which can be useful in
opf pidedre‐a
fue tahtourriezsationsuch
pa
rocssp
eessnd limits
rocedures but not practica thatl
in
ias
PoliciesTheforimplement
and Procedures Countyrsquos Purchasing
ingtheprogram Agent
at isthe
t
he
depar
C
AL‐CardProgramAdministratorwho
programand enforcing
tment levelprovidin
g training
a
Departmearnte 1)
thetheprCogramAL‐Card
policiesuser 2)
andthe
p roceduresDepartmen
The key
roles in
Billing Officialand 4)theProgramAdminis
trtaAOtor
T3)hethe
responsibilitACCT
isresponsible
aredescrib
e
din
t
heCAL‐Cardpo
liciesandproceduremanual
nd
Cthe
d
Aevelopin
PCAL‐Card
ies sotafffeach
g
4)
Departmentf
headssettheindividualtransaction(upto$2500)andmonthlyspendlimits
appropriataonrd eau hrc
pc c
haarsdi
nignpuosl
eicie
sThe
cardholde
rs arerespo
nsib
le
for com
plyin
edocumenta
t
g
activities
toensur
ethat
wi
th
th
eC
AL‐Card
aprocedurespplicatio
ns
The Billing
or can
cella
ionpre
toparsuinpg
all
purchases
ptohretmto CA
een
appropriatcthhaly
arh rges
LT‐ChaerdAOPsurrcehvaiesweRandepoapprortand
vepraccountoviding
Officia
ls c
oordinate
einaccordancewiththepoliciesand
receives and audits the CAL‐Cati
on ofrd in
paaymentctiv
e o
nes
T
activities
he A
CT
T
suchC A
as
lcco
c aimstoensurethatea
processinguchntschargePayable
o
f new
supported
card
ff
is a
(AP)dequat
stelya
CAL‐CardProgram CountywideAudit AuditNo3108 Page7
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Executive Summary
and not bedetected in a timely manner Giventhat the department levelcontrols(CAL‐Card usersrsquo awareness and Department Approving Officialsrsquo (AO) reviews) are notfunction
occur
nature a
a
Ourrev
ningdn
oeffectt be d
ivelyetec
we consid
ndvolumeoftheCAL‐Carted in a tim
ereltyhemaonvernearll torisk be
thhaight Tunau
histhorized riskwill
trincreaseansactions
aswtheill
managingtheCAL‐Cardprogram iew also
dtrans
sh hatt he
actionsincreas
ows t C
e
o u nty canrealize
significant
savingst hroughp roactively
inTh eitsfo
ellntowir
ietyng i
insaAsppendixum
maryDofoAurmroreecom
detmaeilneddat
dioiscussionnsMana
referencedisgementrsquos
response is
reportasprovided in theb
ody
included
Observatio
of the
purchases
The intern
al
n 1 Strengthen Controls to Reduce Unauthorized Purchases (Page 13)
purchasesare T
hec
arenotexecuted
ontrolsCAL‐Card
areusersrsquono
t fuanctionwareness
ing
effectively to prevent unauthorized CAL‐Card
the primarypreventative controls
ofproper to ens
spureending
thata unndallowableaccountability
transacfortionsthe
iAlthoughtem
s
theCAL‐Cardprogramrsquosblocking feature isutilized topreventsomeprohibited
Weand
f unallooundcar
dsheverol
dealrsicnstaould
nces
s till
where makeu
enmployeesallowa
bl
ev piolaturc
ha
sesase
videnced
wableitemswerepurchasedauthorizationsed
werepolicies
nota
n
odbtainedguidelin
by our est
xpenditur
es t
ele
trav
bypasspurchasingcontrols
R
e
swere mad
ewithout
travel
re‐approval
p
a ndt
ransactio
whnserewere
results
requirestr
ictede
split
d
to
Controls such
discouragepurchases
futureA
sasev reviews
violaidenced
tions
byby AOsrep
andeat
ACCTC violatio
staffns
report the
viola
tions W
detectthe con
rathertrols
tchaurnrentlypreven
i
the
n
charges
cardholders
tunauthorized
other prohibited
trans
actions
plac
e do not
transactio
ns
the cardholders
In
amajority
ofthese
werehen
reqACuTiredT
C
Atoccreimburseou
nts Painstyab
alen (cesAP)the s
AOsdidnotdetectand
such as work performed the
o
premise
Countyn
ftoarff p
s requested
identified ersonal
and AOs were imply notified and
ssu h
oc se
r pxlpite p nsuersc F
to ensureh asoesr
complianceinthefuture
We
tran shaavection
discusseds o n page
1
a
includes
number
without a policy that
6 H
violators
of strategies
for reducing
the rate
of
odeactivwever
atingthe effectiveness of such controls will
unauthorized b
e limite
d
The
Observatio
County
n
c
harged
2 Strengthen
$90518
Controls
tomeal
over
expenses
Meal
suspending
Expenses
o
(Page
r can
celling
17)
accounts of repeat
meals)out
of w approximately
hichControls should be
$560stre
was sp
inentthe
through
following
the
ngthened00
within
the
C
AL‐Car
aCreasounty
d(as program
in town in F
businessY1112
providedm
CAL‐CardProgram
ealexpensesare
County
effectivelymanaged
t
o ensure t hat County‐
AuditNo3108
wideA
udit
Page2
Executive Summary
A Control Weakness over DocumentationThe current policy does not require the cardholder to submit a detailed listing of items purchased for the CAL‐Card meal expenses As a result reviewers are not able todetermine if prohibited items such as alcohol were purchased and paid by the County The Countyshouldre‐assessthecurrent policyfor adequacytobetterdefine thedocumentation standards
B Re‐Evaluate the Current Meal PolicyThecurrent policyallowsmealreimbursementforout‐of‐towntravelof$90perpersonperday regardless of the travel destination County departments at their discretion may usethe Federal reimbursement rates which vary based on the travel destinations Based onour analysis the County could have potentialsavings in out‐of‐town meal expenses rangingfrom 17 to as much as 54 by adopting Federal rates The meals reimbursement policyshould be reviewed periodically to ensure that reimbursements closely reflect the actualcost
The current in County meal reimbursement policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documented in detail We noted a number of the CAL‐Card charges were forbreakfast for events such as management team and combined fund drive kickoff meetingsAlthough the business purpose was indicated we were unable to determine why it neededtobeconductedoverthemeal
As evidenced by high percentage of in County meal (62 of total CAL‐Card meal expenses) allowable practices should be better defined to reduce the risk of wasteful spending CAL‐Card meal purchases that do not meet the Countyrsquos requirements should be consideredunallowableafter adequatetraininghasbeen providedto theCAL‐CardusersandAOs
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions (Page 21)
Currently the ACTTCrsquos AP section is reviewing 100 of the CAL‐Card transactions forcompliance with the Countyrsquos guidelines Between February 2013 and July 2013 $281 personal expenses were identified and reimbursed from responsible employees Howeverthere were no consequences on the cardholders or the departments for other violationsnotedsuchasworkperformedon premisesor splitpurchasestransactions
Auditing a sample of transactions selected based on risk together with a policy to address misuse such as deactivation suspension or cancellation of accounts of repeat violators wouldbeamorecosteffectivealternative tothecurrent practice
Observation 4 Consider Deactivating Infrequently Used Cards (Page 22)
Best practices suggest that organizations issue the minimum number of cards necessary tomeet their business needs The risk of misuse abuse and fraud increases as the number ofcardsinuseincreases
CAL‐CardProgram CountywideAudit AuditNo3108 Page3
Executive Summary
The County does not have any procedures in place to identify infrequent users and assess their continued need for the cards Purchasing should monitor card usage and in consultation withtheuserdepartmentsdeactivateinfrequently usedcardsasnecessary
Observation 5 Establish Proper Spend Limits and Commodity Ranges (Page 23)
A The CAL‐Card Program Expansion To ensure that the CAL‐Card program continues to meet its objectives spend limits and commodity ranges should be periodically reviewed No such review has been performedfor the program since its inception in 2000 when the single transaction limit was set at $2500 Our analysis indicates that the increase of the individual CAL‐Card transaction limit to $5000 will result in approximately 300 additional transactions such as office suppliesand smalltoolseligible for theCAL‐Cardprogram
B Effective Use of ResourcesCurrently Buyers spend an average of four hours on each transaction processed throughtheregularpurchasingprocessBy shifting low dollarvaluetransactions wherethe Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar valuetransactions analysisandotheractivitiesthatwouldaddgreatervalue
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs and allocate its resources to more critical areas such as contract negotiation reviewofbidsandpreparationof specification
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings (Page 25)
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Our analysis indicates that strategies discussed above could be applied to approximately$600000 in CAL‐Card transactions representing top vendors and frequently used airlinesand hotels Purchasing should periodically perform a spend analysis and use thatinformation to better negotiate discounts explore potential purchasing partners and refineotherareasofitsoverall purchasingstrategy
CAL‐CardProgram CountywideAudit AuditNo3108 Page4
Executive Summary
B Require Departments to Purchase through BPO Agreements or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other te have been pre‐negotiated The County also ticipates in Western State
93 par
Contracting rms
(WSCA) agreement formed in 19 which allows participating Alliancegovernment entities to join together in cooperative multi‐State contracting Currently the C d es not have a process n p ace to ensu e th t po ential BPO and WSCA elig ble iCoAuLn‐Cty i l r
da
dt
ardo transactions are identified and purchase un er the terms of appropriate
contracts Approximately $96000 in such CAL‐Card transactions were processed in FY1112
Purchasing should uexplore means for obtaining disco nts for th CAL‐Card purchasescovered under the County BPOs and WSCA Arrangements could be
emade with respective
vendors which will allow users to identify appropriate agreements at the time of thepurchase to receive discounts An ongoing monitoring of BPO and WSCA eligible transactionswillensure continuedeffectivenessoftheprocedureslistedabove
C Maximize Use of the CAL‐Card to Achieve Higher Level of Efficiency The CAL‐Card program is successfully achieving its objectives by providing a convenient and cost effective alternative to the regular purchasing process Department managers are able to procure goods and service in a timely manner The processing cost of $27 per warrantisavoidedbyusingthe CAL‐Card
Our analysis indicates that 1275 small dollar value transactions through the regular allyput
accounts payable process in FY1112 could have been potenti paid through the CAL‐Card program saving approximately $20000 in warrant production os t Purchasinshould periodically identify CAL‐Card eligible transactions processed thro
c nd work
gugh AP a
withtheuserdepartmentstoexpandtheCAL‐Cardusewhereappropriate
D Explore the Possibilities of Partnering with Other Card ProvidersPurchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftrans c on o st
kc nter y
dstem lso a lows on lin access f i la t i
Us t
de s The s l or r ev ew and approva
functions S Bco an oes not provi e the
ase features to th
ee County As a result numerous
hours of data entry time is expended o enter the CAL‐Card transaction in the Countyrsquos i
My
An ili e ices of
h
dtaccount ng s stem The Cou ty has ut
t zed the s rv US Bank throu h the S ate
negotiated aster Services greement since 2006 Partners ip with othegr provi ers
shouldbeexploredfor better termsconditionsandfeaturessuchasabove
We strongly recommend that management develop a plan that prioritizes recommendations and establishes timelines for implementation For some of ourrecommendations additional research may be required before specific steps and timelinescan be determined I anternal Audit will provide ssistance where needed and perfo mfollow‐ups based on managementrsquos implementation plan or at least on a six‐month ba
rsis
untilmajorissuesare resolved
CAL‐CardProgram CountywideAudit AuditNo3108 Page5
Introduction amp Background
IntroductionWeconducted
have
Practice of
completed
theInternal
audit
the
Auditingin a
auditccordance (St
of
andards)
thewSithonomathe
analyze eva
International Standards for the Professional
objectives Wluatee believ
ande documentthat the evid
sufficenceient
Countyrsquos
(County) CAL‐Card program We
resultsobserva
ndrecommenda
tions
a
informaThese S
tiontandards require that we identify
tionscobontainedtained provides
and
aev
ridence
itreporteasonable
t
ouraud
o
in
The purpose of this audit report is to furnish management
independent
achbasisieve
forauditthe
analys esrecommendations
andot
her
informa
and objective
auditreportisatoolto
helpm
anagement
identifyation
concerning
t
he
act ivities reviewed The
throughoutWewouldlike
theaudittothankmanagementand
ndimplemen
for their
timprovements
staff
timeinformation and cooperation
Background
OverviewThe
ptraditionurc
Countyal paper implement
and ledabor‐intens
the purchivease
ofCa
and
procurementcard(CAL‐Card)
process
programfor
in2000tostreamline
certain
small dollar
the
value
requ
less
hliafosersniCa Tu
rhreeCntAlyL
‐Ct
haerdCAalLl o‐Cwasrtd
hiesCmoaunaged
oisfiftiicoenss toord rireeccetliyvinmgarkee l w o a
transacp
o d ll rnvatyludee
than$2500per tionorts
including TheC
AtaxesL ‐Ca
bpyaUrtmSeBntasnBkoinarpartnershipdofSupervisor
withst tate
uagencheS
pdr
ies
rIcc
tahnasbeesu sweidthout
canalsobetouosedb tpareparing
forin s
traveluppli
e purchase
esxpenses costing
allowedwithin
the Cou
ntyrsquos
Travel
and
Meal Reimbursement
Countybusiness
Polic
y guidelin
es
while on
The rdsystem
mCAL‐Ca
usesmerchantcategorycode(MCC)toidentifythetypeofbusinessa
ecaerrdc
hhoalndtecr
oisn adbul c ett
s
o Tpuhre
cChaountyuses
MCCsto
cont
rolthe
ty
pes ofproducts
or
services
xa mp
leareproh
ibited
for
saellPcau
rrd
chhoal
sdie
nrg
soafntd
imaettsehmarpetssaa
nrdedidaentt
ing
or
bettings
ervices fo
ar
Tonhteh er
ach
Ce
Am
(Purchasing)authorizationandapprovalL‐C rd
an its rsquosnMoCtCtoE b
aec husceadrd
fhora ts raasninsagcletiotrnasn sthacatti ro neqliumiriet tand
ifieda monthlyandblocked
spend
blimitased
he
In
Purchasing Divisionrsquos
s$2249016ig
FY1112
n au
CAL‐ C arsde Ur
ach
Cou
agEthe
emeCounty
sreers M
nta
nty
fehmployee
nouraml wT
ad approximately
oissued
h provideich wa
292 cardholders who charged a total of
guida
a
s lasnC
tceAL‐Card
r t
is
eocard
equired
v ised
holders n
r
i
Janthe tCountyo
attend
dev
traeloped
in ing
atnhed
intranet
gsapurPDFcal_card_user_manualpdf)uary 2013 (httpsc
‐
In(ATTC)
February 2013 Purchasing
ApprovijoinngO
tlyf
ficpresenials(
AtOesd)theAll
an
andu
County Auditor‐
c anrdalhorefreshldersa n
erdA traOinsa ingC
e toontroller Trea
r r eqaullirceardholdersd toa
surer‐Tax
Collector
c know
andledg
Deepartmentreceiving
traininginordertocontinueperformingtheirassignedfunctionsTh traie ningprovidedan
CAL‐CardProgram CountywideAudit AuditNo3108 Page6
Introduction amp Background
overview of the CAL‐Card program and policies guidelines and procedures thatcardholders and AOs are required to comply with Key areas such as roles andresponsibilities
author
ized
key componen
t of
the
programrsquos
u se an
idntrere qnalui
recdontroldocu
msystenemta
tiodesignw
enedrec
toovered
redu
cTe tr
noncompliancewithpo
liciesa
ndp
roceduresandtoestablishacc
aining
ountability
he risk
is o
af
theAs we
County discuss
as onwell
pageas
24indiv
datiduala provided
department
y
b the
developingeffectivepurchasingstrategiesVendor
and MCC can be used to compensate for the
n
spendinCAL‐Car
d
provide
can
lac
r
kprov
beu
sed
toestablish
purchasingcardenviroorm
ally r
eq
u ired
b
ynment
th
e trad itional
proc
urement
g profiles which can be useful in
opf pidedre‐a
fue tahtourriezsationsuch
pa
rocssp
eessnd limits
rocedures but not practica thatl
in
ias
PoliciesTheforimplement
and Procedures Countyrsquos Purchasing
ingtheprogram Agent
at isthe
t
he
depar
C
AL‐CardProgramAdministratorwho
programand enforcing
tment levelprovidin
g training
a
Departmearnte 1)
thetheprCogramAL‐Card
policiesuser 2)
andthe
p roceduresDepartmen
The key
roles in
Billing Officialand 4)theProgramAdminis
trtaAOtor
T3)hethe
responsibilitACCT
isresponsible
aredescrib
e
din
t
heCAL‐Cardpo
liciesandproceduremanual
nd
Cthe
d
Aevelopin
PCAL‐Card
ies sotafffeach
g
4)
Departmentf
headssettheindividualtransaction(upto$2500)andmonthlyspendlimits
appropriataonrd eau hrc
pc c
haarsdi
nignpuosl
eicie
sThe
cardholde
rs arerespo
nsib
le
for com
plyin
edocumenta
t
g
activities
toensur
ethat
wi
th
th
eC
AL‐Card
aprocedurespplicatio
ns
The Billing
or can
cella
ionpre
toparsuinpg
all
purchases
ptohretmto CA
een
appropriatcthhaly
arh rges
LT‐ChaerdAOPsurrcehvaiesweRandepoapprortand
vepraccountoviding
Officia
ls c
oordinate
einaccordancewiththepoliciesand
receives and audits the CAL‐Cati
on ofrd in
paaymentctiv
e o
nes
T
activities
he A
CT
T
suchC A
as
lcco
c aimstoensurethatea
processinguchntschargePayable
o
f new
supported
card
ff
is a
(AP)dequat
stelya
CAL‐CardProgram CountywideAudit AuditNo3108 Page7
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Executive Summary
A Control Weakness over DocumentationThe current policy does not require the cardholder to submit a detailed listing of items purchased for the CAL‐Card meal expenses As a result reviewers are not able todetermine if prohibited items such as alcohol were purchased and paid by the County The Countyshouldre‐assessthecurrent policyfor adequacytobetterdefine thedocumentation standards
B Re‐Evaluate the Current Meal PolicyThecurrent policyallowsmealreimbursementforout‐of‐towntravelof$90perpersonperday regardless of the travel destination County departments at their discretion may usethe Federal reimbursement rates which vary based on the travel destinations Based onour analysis the County could have potentialsavings in out‐of‐town meal expenses rangingfrom 17 to as much as 54 by adopting Federal rates The meals reimbursement policyshould be reviewed periodically to ensure that reimbursements closely reflect the actualcost
The current in County meal reimbursement policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documented in detail We noted a number of the CAL‐Card charges were forbreakfast for events such as management team and combined fund drive kickoff meetingsAlthough the business purpose was indicated we were unable to determine why it neededtobeconductedoverthemeal
As evidenced by high percentage of in County meal (62 of total CAL‐Card meal expenses) allowable practices should be better defined to reduce the risk of wasteful spending CAL‐Card meal purchases that do not meet the Countyrsquos requirements should be consideredunallowableafter adequatetraininghasbeen providedto theCAL‐CardusersandAOs
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions (Page 21)
Currently the ACTTCrsquos AP section is reviewing 100 of the CAL‐Card transactions forcompliance with the Countyrsquos guidelines Between February 2013 and July 2013 $281 personal expenses were identified and reimbursed from responsible employees Howeverthere were no consequences on the cardholders or the departments for other violationsnotedsuchasworkperformedon premisesor splitpurchasestransactions
Auditing a sample of transactions selected based on risk together with a policy to address misuse such as deactivation suspension or cancellation of accounts of repeat violators wouldbeamorecosteffectivealternative tothecurrent practice
Observation 4 Consider Deactivating Infrequently Used Cards (Page 22)
Best practices suggest that organizations issue the minimum number of cards necessary tomeet their business needs The risk of misuse abuse and fraud increases as the number ofcardsinuseincreases
CAL‐CardProgram CountywideAudit AuditNo3108 Page3
Executive Summary
The County does not have any procedures in place to identify infrequent users and assess their continued need for the cards Purchasing should monitor card usage and in consultation withtheuserdepartmentsdeactivateinfrequently usedcardsasnecessary
Observation 5 Establish Proper Spend Limits and Commodity Ranges (Page 23)
A The CAL‐Card Program Expansion To ensure that the CAL‐Card program continues to meet its objectives spend limits and commodity ranges should be periodically reviewed No such review has been performedfor the program since its inception in 2000 when the single transaction limit was set at $2500 Our analysis indicates that the increase of the individual CAL‐Card transaction limit to $5000 will result in approximately 300 additional transactions such as office suppliesand smalltoolseligible for theCAL‐Cardprogram
B Effective Use of ResourcesCurrently Buyers spend an average of four hours on each transaction processed throughtheregularpurchasingprocessBy shifting low dollarvaluetransactions wherethe Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar valuetransactions analysisandotheractivitiesthatwouldaddgreatervalue
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs and allocate its resources to more critical areas such as contract negotiation reviewofbidsandpreparationof specification
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings (Page 25)
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Our analysis indicates that strategies discussed above could be applied to approximately$600000 in CAL‐Card transactions representing top vendors and frequently used airlinesand hotels Purchasing should periodically perform a spend analysis and use thatinformation to better negotiate discounts explore potential purchasing partners and refineotherareasofitsoverall purchasingstrategy
CAL‐CardProgram CountywideAudit AuditNo3108 Page4
Executive Summary
B Require Departments to Purchase through BPO Agreements or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other te have been pre‐negotiated The County also ticipates in Western State
93 par
Contracting rms
(WSCA) agreement formed in 19 which allows participating Alliancegovernment entities to join together in cooperative multi‐State contracting Currently the C d es not have a process n p ace to ensu e th t po ential BPO and WSCA elig ble iCoAuLn‐Cty i l r
da
dt
ardo transactions are identified and purchase un er the terms of appropriate
contracts Approximately $96000 in such CAL‐Card transactions were processed in FY1112
Purchasing should uexplore means for obtaining disco nts for th CAL‐Card purchasescovered under the County BPOs and WSCA Arrangements could be
emade with respective
vendors which will allow users to identify appropriate agreements at the time of thepurchase to receive discounts An ongoing monitoring of BPO and WSCA eligible transactionswillensure continuedeffectivenessoftheprocedureslistedabove
C Maximize Use of the CAL‐Card to Achieve Higher Level of Efficiency The CAL‐Card program is successfully achieving its objectives by providing a convenient and cost effective alternative to the regular purchasing process Department managers are able to procure goods and service in a timely manner The processing cost of $27 per warrantisavoidedbyusingthe CAL‐Card
Our analysis indicates that 1275 small dollar value transactions through the regular allyput
accounts payable process in FY1112 could have been potenti paid through the CAL‐Card program saving approximately $20000 in warrant production os t Purchasinshould periodically identify CAL‐Card eligible transactions processed thro
c nd work
gugh AP a
withtheuserdepartmentstoexpandtheCAL‐Cardusewhereappropriate
D Explore the Possibilities of Partnering with Other Card ProvidersPurchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftrans c on o st
kc nter y
dstem lso a lows on lin access f i la t i
Us t
de s The s l or r ev ew and approva
functions S Bco an oes not provi e the
ase features to th
ee County As a result numerous
hours of data entry time is expended o enter the CAL‐Card transaction in the Countyrsquos i
My
An ili e ices of
h
dtaccount ng s stem The Cou ty has ut
t zed the s rv US Bank throu h the S ate
negotiated aster Services greement since 2006 Partners ip with othegr provi ers
shouldbeexploredfor better termsconditionsandfeaturessuchasabove
We strongly recommend that management develop a plan that prioritizes recommendations and establishes timelines for implementation For some of ourrecommendations additional research may be required before specific steps and timelinescan be determined I anternal Audit will provide ssistance where needed and perfo mfollow‐ups based on managementrsquos implementation plan or at least on a six‐month ba
rsis
untilmajorissuesare resolved
CAL‐CardProgram CountywideAudit AuditNo3108 Page5
Introduction amp Background
IntroductionWeconducted
have
Practice of
completed
theInternal
audit
the
Auditingin a
auditccordance (St
of
andards)
thewSithonomathe
analyze eva
International Standards for the Professional
objectives Wluatee believ
ande documentthat the evid
sufficenceient
Countyrsquos
(County) CAL‐Card program We
resultsobserva
ndrecommenda
tions
a
informaThese S
tiontandards require that we identify
tionscobontainedtained provides
and
aev
ridence
itreporteasonable
t
ouraud
o
in
The purpose of this audit report is to furnish management
independent
achbasisieve
forauditthe
analys esrecommendations
andot
her
informa
and objective
auditreportisatoolto
helpm
anagement
identifyation
concerning
t
he
act ivities reviewed The
throughoutWewouldlike
theaudittothankmanagementand
ndimplemen
for their
timprovements
staff
timeinformation and cooperation
Background
OverviewThe
ptraditionurc
Countyal paper implement
and ledabor‐intens
the purchivease
ofCa
and
procurementcard(CAL‐Card)
process
programfor
in2000tostreamline
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the
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hliafosersniCa Tu
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‐Ct
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oisfiftiicoenss toord rireeccetliyvinmgarkee l w o a
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ies
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canalsobetouosedb tpareparing
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e purchase
esxpenses costing
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ntyrsquos
Travel
and
Meal Reimbursement
Countybusiness
Polic
y guidelin
es
while on
The rdsystem
mCAL‐Ca
usesmerchantcategorycode(MCC)toidentifythetypeofbusinessa
ecaerrdc
hhoalndtecr
oisn adbul c ett
s
o Tpuhre
cChaountyuses
MCCsto
cont
rolthe
ty
pes ofproducts
or
services
xa mp
leareproh
ibited
for
saellPcau
rrd
chhoal
sdie
nrg
soafntd
imaettsehmarpetssaa
nrdedidaentt
ing
or
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ervices fo
ar
Tonhteh er
ach
Ce
Am
(Purchasing)authorizationandapprovalL‐C rd
an its rsquosnMoCtCtoE b
aec husceadrd
fhora ts raasninsagcletiotrnasn sthacatti ro neqliumiriet tand
ifieda monthlyandblocked
spend
blimitased
he
In
Purchasing Divisionrsquos
s$2249016ig
FY1112
n au
CAL‐ C arsde Ur
ach
Cou
agEthe
emeCounty
sreers M
nta
nty
fehmployee
nouraml wT
ad approximately
oissued
h provideich wa
292 cardholders who charged a total of
guida
a
s lasnC
tceAL‐Card
r t
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eocard
equired
v ised
holders n
r
i
Janthe tCountyo
attend
dev
traeloped
in ing
atnhed
intranet
gsapurPDFcal_card_user_manualpdf)uary 2013 (httpsc
‐
In(ATTC)
February 2013 Purchasing
ApprovijoinngO
tlyf
ficpresenials(
AtOesd)theAll
an
andu
County Auditor‐
c anrdalhorefreshldersa n
erdA traOinsa ingC
e toontroller Trea
r r eqaullirceardholdersd toa
surer‐Tax
Collector
c know
andledg
Deepartmentreceiving
traininginordertocontinueperformingtheirassignedfunctionsTh traie ningprovidedan
CAL‐CardProgram CountywideAudit AuditNo3108 Page6
Introduction amp Background
overview of the CAL‐Card program and policies guidelines and procedures thatcardholders and AOs are required to comply with Key areas such as roles andresponsibilities
author
ized
key componen
t of
the
programrsquos
u se an
idntrere qnalui
recdontroldocu
msystenemta
tiodesignw
enedrec
toovered
redu
cTe tr
noncompliancewithpo
liciesa
ndp
roceduresandtoestablishacc
aining
ountability
he risk
is o
af
theAs we
County discuss
as onwell
pageas
24indiv
datiduala provided
department
y
b the
developingeffectivepurchasingstrategiesVendor
and MCC can be used to compensate for the
n
spendinCAL‐Car
d
provide
can
lac
r
kprov
beu
sed
toestablish
purchasingcardenviroorm
ally r
eq
u ired
b
ynment
th
e trad itional
proc
urement
g profiles which can be useful in
opf pidedre‐a
fue tahtourriezsationsuch
pa
rocssp
eessnd limits
rocedures but not practica thatl
in
ias
PoliciesTheforimplement
and Procedures Countyrsquos Purchasing
ingtheprogram Agent
at isthe
t
he
depar
C
AL‐CardProgramAdministratorwho
programand enforcing
tment levelprovidin
g training
a
Departmearnte 1)
thetheprCogramAL‐Card
policiesuser 2)
andthe
p roceduresDepartmen
The key
roles in
Billing Officialand 4)theProgramAdminis
trtaAOtor
T3)hethe
responsibilitACCT
isresponsible
aredescrib
e
din
t
heCAL‐Cardpo
liciesandproceduremanual
nd
Cthe
d
Aevelopin
PCAL‐Card
ies sotafffeach
g
4)
Departmentf
headssettheindividualtransaction(upto$2500)andmonthlyspendlimits
appropriataonrd eau hrc
pc c
haarsdi
nignpuosl
eicie
sThe
cardholde
rs arerespo
nsib
le
for com
plyin
edocumenta
t
g
activities
toensur
ethat
wi
th
th
eC
AL‐Card
aprocedurespplicatio
ns
The Billing
or can
cella
ionpre
toparsuinpg
all
purchases
ptohretmto CA
een
appropriatcthhaly
arh rges
LT‐ChaerdAOPsurrcehvaiesweRandepoapprortand
vepraccountoviding
Officia
ls c
oordinate
einaccordancewiththepoliciesand
receives and audits the CAL‐Cati
on ofrd in
paaymentctiv
e o
nes
T
activities
he A
CT
T
suchC A
as
lcco
c aimstoensurethatea
processinguchntschargePayable
o
f new
supported
card
ff
is a
(AP)dequat
stelya
CAL‐CardProgram CountywideAudit AuditNo3108 Page7
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Executive Summary
The County does not have any procedures in place to identify infrequent users and assess their continued need for the cards Purchasing should monitor card usage and in consultation withtheuserdepartmentsdeactivateinfrequently usedcardsasnecessary
Observation 5 Establish Proper Spend Limits and Commodity Ranges (Page 23)
A The CAL‐Card Program Expansion To ensure that the CAL‐Card program continues to meet its objectives spend limits and commodity ranges should be periodically reviewed No such review has been performedfor the program since its inception in 2000 when the single transaction limit was set at $2500 Our analysis indicates that the increase of the individual CAL‐Card transaction limit to $5000 will result in approximately 300 additional transactions such as office suppliesand smalltoolseligible for theCAL‐Cardprogram
B Effective Use of ResourcesCurrently Buyers spend an average of four hours on each transaction processed throughtheregularpurchasingprocessBy shifting low dollarvaluetransactions wherethe Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar valuetransactions analysisandotheractivitiesthatwouldaddgreatervalue
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs and allocate its resources to more critical areas such as contract negotiation reviewofbidsandpreparationof specification
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings (Page 25)
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Our analysis indicates that strategies discussed above could be applied to approximately$600000 in CAL‐Card transactions representing top vendors and frequently used airlinesand hotels Purchasing should periodically perform a spend analysis and use thatinformation to better negotiate discounts explore potential purchasing partners and refineotherareasofitsoverall purchasingstrategy
CAL‐CardProgram CountywideAudit AuditNo3108 Page4
Executive Summary
B Require Departments to Purchase through BPO Agreements or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other te have been pre‐negotiated The County also ticipates in Western State
93 par
Contracting rms
(WSCA) agreement formed in 19 which allows participating Alliancegovernment entities to join together in cooperative multi‐State contracting Currently the C d es not have a process n p ace to ensu e th t po ential BPO and WSCA elig ble iCoAuLn‐Cty i l r
da
dt
ardo transactions are identified and purchase un er the terms of appropriate
contracts Approximately $96000 in such CAL‐Card transactions were processed in FY1112
Purchasing should uexplore means for obtaining disco nts for th CAL‐Card purchasescovered under the County BPOs and WSCA Arrangements could be
emade with respective
vendors which will allow users to identify appropriate agreements at the time of thepurchase to receive discounts An ongoing monitoring of BPO and WSCA eligible transactionswillensure continuedeffectivenessoftheprocedureslistedabove
C Maximize Use of the CAL‐Card to Achieve Higher Level of Efficiency The CAL‐Card program is successfully achieving its objectives by providing a convenient and cost effective alternative to the regular purchasing process Department managers are able to procure goods and service in a timely manner The processing cost of $27 per warrantisavoidedbyusingthe CAL‐Card
Our analysis indicates that 1275 small dollar value transactions through the regular allyput
accounts payable process in FY1112 could have been potenti paid through the CAL‐Card program saving approximately $20000 in warrant production os t Purchasinshould periodically identify CAL‐Card eligible transactions processed thro
c nd work
gugh AP a
withtheuserdepartmentstoexpandtheCAL‐Cardusewhereappropriate
D Explore the Possibilities of Partnering with Other Card ProvidersPurchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftrans c on o st
kc nter y
dstem lso a lows on lin access f i la t i
Us t
de s The s l or r ev ew and approva
functions S Bco an oes not provi e the
ase features to th
ee County As a result numerous
hours of data entry time is expended o enter the CAL‐Card transaction in the Countyrsquos i
My
An ili e ices of
h
dtaccount ng s stem The Cou ty has ut
t zed the s rv US Bank throu h the S ate
negotiated aster Services greement since 2006 Partners ip with othegr provi ers
shouldbeexploredfor better termsconditionsandfeaturessuchasabove
We strongly recommend that management develop a plan that prioritizes recommendations and establishes timelines for implementation For some of ourrecommendations additional research may be required before specific steps and timelinescan be determined I anternal Audit will provide ssistance where needed and perfo mfollow‐ups based on managementrsquos implementation plan or at least on a six‐month ba
rsis
untilmajorissuesare resolved
CAL‐CardProgram CountywideAudit AuditNo3108 Page5
Introduction amp Background
IntroductionWeconducted
have
Practice of
completed
theInternal
audit
the
Auditingin a
auditccordance (St
of
andards)
thewSithonomathe
analyze eva
International Standards for the Professional
objectives Wluatee believ
ande documentthat the evid
sufficenceient
Countyrsquos
(County) CAL‐Card program We
resultsobserva
ndrecommenda
tions
a
informaThese S
tiontandards require that we identify
tionscobontainedtained provides
and
aev
ridence
itreporteasonable
t
ouraud
o
in
The purpose of this audit report is to furnish management
independent
achbasisieve
forauditthe
analys esrecommendations
andot
her
informa
and objective
auditreportisatoolto
helpm
anagement
identifyation
concerning
t
he
act ivities reviewed The
throughoutWewouldlike
theaudittothankmanagementand
ndimplemen
for their
timprovements
staff
timeinformation and cooperation
Background
OverviewThe
ptraditionurc
Countyal paper implement
and ledabor‐intens
the purchivease
ofCa
and
procurementcard(CAL‐Card)
process
programfor
in2000tostreamline
certain
small dollar
the
value
requ
less
hliafosersniCa Tu
rhreeCntAlyL
‐Ct
haerdCAalLl o‐Cwasrtd
hiesCmoaunaged
oisfiftiicoenss toord rireeccetliyvinmgarkee l w o a
transacp
o d ll rnvatyludee
than$2500per tionorts
including TheC
AtaxesL ‐Ca
bpyaUrtmSeBntasnBkoinarpartnershipdofSupervisor
withst tate
uagencheS
pdr
ies
rIcc
tahnasbeesu sweidthout
canalsobetouosedb tpareparing
forin s
traveluppli
e purchase
esxpenses costing
allowedwithin
the Cou
ntyrsquos
Travel
and
Meal Reimbursement
Countybusiness
Polic
y guidelin
es
while on
The rdsystem
mCAL‐Ca
usesmerchantcategorycode(MCC)toidentifythetypeofbusinessa
ecaerrdc
hhoalndtecr
oisn adbul c ett
s
o Tpuhre
cChaountyuses
MCCsto
cont
rolthe
ty
pes ofproducts
or
services
xa mp
leareproh
ibited
for
saellPcau
rrd
chhoal
sdie
nrg
soafntd
imaettsehmarpetssaa
nrdedidaentt
ing
or
bettings
ervices fo
ar
Tonhteh er
ach
Ce
Am
(Purchasing)authorizationandapprovalL‐C rd
an its rsquosnMoCtCtoE b
aec husceadrd
fhora ts raasninsagcletiotrnasn sthacatti ro neqliumiriet tand
ifieda monthlyandblocked
spend
blimitased
he
In
Purchasing Divisionrsquos
s$2249016ig
FY1112
n au
CAL‐ C arsde Ur
ach
Cou
agEthe
emeCounty
sreers M
nta
nty
fehmployee
nouraml wT
ad approximately
oissued
h provideich wa
292 cardholders who charged a total of
guida
a
s lasnC
tceAL‐Card
r t
is
eocard
equired
v ised
holders n
r
i
Janthe tCountyo
attend
dev
traeloped
in ing
atnhed
intranet
gsapurPDFcal_card_user_manualpdf)uary 2013 (httpsc
‐
In(ATTC)
February 2013 Purchasing
ApprovijoinngO
tlyf
ficpresenials(
AtOesd)theAll
an
andu
County Auditor‐
c anrdalhorefreshldersa n
erdA traOinsa ingC
e toontroller Trea
r r eqaullirceardholdersd toa
surer‐Tax
Collector
c know
andledg
Deepartmentreceiving
traininginordertocontinueperformingtheirassignedfunctionsTh traie ningprovidedan
CAL‐CardProgram CountywideAudit AuditNo3108 Page6
Introduction amp Background
overview of the CAL‐Card program and policies guidelines and procedures thatcardholders and AOs are required to comply with Key areas such as roles andresponsibilities
author
ized
key componen
t of
the
programrsquos
u se an
idntrere qnalui
recdontroldocu
msystenemta
tiodesignw
enedrec
toovered
redu
cTe tr
noncompliancewithpo
liciesa
ndp
roceduresandtoestablishacc
aining
ountability
he risk
is o
af
theAs we
County discuss
as onwell
pageas
24indiv
datiduala provided
department
y
b the
developingeffectivepurchasingstrategiesVendor
and MCC can be used to compensate for the
n
spendinCAL‐Car
d
provide
can
lac
r
kprov
beu
sed
toestablish
purchasingcardenviroorm
ally r
eq
u ired
b
ynment
th
e trad itional
proc
urement
g profiles which can be useful in
opf pidedre‐a
fue tahtourriezsationsuch
pa
rocssp
eessnd limits
rocedures but not practica thatl
in
ias
PoliciesTheforimplement
and Procedures Countyrsquos Purchasing
ingtheprogram Agent
at isthe
t
he
depar
C
AL‐CardProgramAdministratorwho
programand enforcing
tment levelprovidin
g training
a
Departmearnte 1)
thetheprCogramAL‐Card
policiesuser 2)
andthe
p roceduresDepartmen
The key
roles in
Billing Officialand 4)theProgramAdminis
trtaAOtor
T3)hethe
responsibilitACCT
isresponsible
aredescrib
e
din
t
heCAL‐Cardpo
liciesandproceduremanual
nd
Cthe
d
Aevelopin
PCAL‐Card
ies sotafffeach
g
4)
Departmentf
headssettheindividualtransaction(upto$2500)andmonthlyspendlimits
appropriataonrd eau hrc
pc c
haarsdi
nignpuosl
eicie
sThe
cardholde
rs arerespo
nsib
le
for com
plyin
edocumenta
t
g
activities
toensur
ethat
wi
th
th
eC
AL‐Card
aprocedurespplicatio
ns
The Billing
or can
cella
ionpre
toparsuinpg
all
purchases
ptohretmto CA
een
appropriatcthhaly
arh rges
LT‐ChaerdAOPsurrcehvaiesweRandepoapprortand
vepraccountoviding
Officia
ls c
oordinate
einaccordancewiththepoliciesand
receives and audits the CAL‐Cati
on ofrd in
paaymentctiv
e o
nes
T
activities
he A
CT
T
suchC A
as
lcco
c aimstoensurethatea
processinguchntschargePayable
o
f new
supported
card
ff
is a
(AP)dequat
stelya
CAL‐CardProgram CountywideAudit AuditNo3108 Page7
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Executive Summary
B Require Departments to Purchase through BPO Agreements or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other te have been pre‐negotiated The County also ticipates in Western State
93 par
Contracting rms
(WSCA) agreement formed in 19 which allows participating Alliancegovernment entities to join together in cooperative multi‐State contracting Currently the C d es not have a process n p ace to ensu e th t po ential BPO and WSCA elig ble iCoAuLn‐Cty i l r
da
dt
ardo transactions are identified and purchase un er the terms of appropriate
contracts Approximately $96000 in such CAL‐Card transactions were processed in FY1112
Purchasing should uexplore means for obtaining disco nts for th CAL‐Card purchasescovered under the County BPOs and WSCA Arrangements could be
emade with respective
vendors which will allow users to identify appropriate agreements at the time of thepurchase to receive discounts An ongoing monitoring of BPO and WSCA eligible transactionswillensure continuedeffectivenessoftheprocedureslistedabove
C Maximize Use of the CAL‐Card to Achieve Higher Level of Efficiency The CAL‐Card program is successfully achieving its objectives by providing a convenient and cost effective alternative to the regular purchasing process Department managers are able to procure goods and service in a timely manner The processing cost of $27 per warrantisavoidedbyusingthe CAL‐Card
Our analysis indicates that 1275 small dollar value transactions through the regular allyput
accounts payable process in FY1112 could have been potenti paid through the CAL‐Card program saving approximately $20000 in warrant production os t Purchasinshould periodically identify CAL‐Card eligible transactions processed thro
c nd work
gugh AP a
withtheuserdepartmentstoexpandtheCAL‐Cardusewhereappropriate
D Explore the Possibilities of Partnering with Other Card ProvidersPurchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftrans c on o st
kc nter y
dstem lso a lows on lin access f i la t i
Us t
de s The s l or r ev ew and approva
functions S Bco an oes not provi e the
ase features to th
ee County As a result numerous
hours of data entry time is expended o enter the CAL‐Card transaction in the Countyrsquos i
My
An ili e ices of
h
dtaccount ng s stem The Cou ty has ut
t zed the s rv US Bank throu h the S ate
negotiated aster Services greement since 2006 Partners ip with othegr provi ers
shouldbeexploredfor better termsconditionsandfeaturessuchasabove
We strongly recommend that management develop a plan that prioritizes recommendations and establishes timelines for implementation For some of ourrecommendations additional research may be required before specific steps and timelinescan be determined I anternal Audit will provide ssistance where needed and perfo mfollow‐ups based on managementrsquos implementation plan or at least on a six‐month ba
rsis
untilmajorissuesare resolved
CAL‐CardProgram CountywideAudit AuditNo3108 Page5
Introduction amp Background
IntroductionWeconducted
have
Practice of
completed
theInternal
audit
the
Auditingin a
auditccordance (St
of
andards)
thewSithonomathe
analyze eva
International Standards for the Professional
objectives Wluatee believ
ande documentthat the evid
sufficenceient
Countyrsquos
(County) CAL‐Card program We
resultsobserva
ndrecommenda
tions
a
informaThese S
tiontandards require that we identify
tionscobontainedtained provides
and
aev
ridence
itreporteasonable
t
ouraud
o
in
The purpose of this audit report is to furnish management
independent
achbasisieve
forauditthe
analys esrecommendations
andot
her
informa
and objective
auditreportisatoolto
helpm
anagement
identifyation
concerning
t
he
act ivities reviewed The
throughoutWewouldlike
theaudittothankmanagementand
ndimplemen
for their
timprovements
staff
timeinformation and cooperation
Background
OverviewThe
ptraditionurc
Countyal paper implement
and ledabor‐intens
the purchivease
ofCa
and
procurementcard(CAL‐Card)
process
programfor
in2000tostreamline
certain
small dollar
the
value
requ
less
hliafosersniCa Tu
rhreeCntAlyL
‐Ct
haerdCAalLl o‐Cwasrtd
hiesCmoaunaged
oisfiftiicoenss toord rireeccetliyvinmgarkee l w o a
transacp
o d ll rnvatyludee
than$2500per tionorts
including TheC
AtaxesL ‐Ca
bpyaUrtmSeBntasnBkoinarpartnershipdofSupervisor
withst tate
uagencheS
pdr
ies
rIcc
tahnasbeesu sweidthout
canalsobetouosedb tpareparing
forin s
traveluppli
e purchase
esxpenses costing
allowedwithin
the Cou
ntyrsquos
Travel
and
Meal Reimbursement
Countybusiness
Polic
y guidelin
es
while on
The rdsystem
mCAL‐Ca
usesmerchantcategorycode(MCC)toidentifythetypeofbusinessa
ecaerrdc
hhoalndtecr
oisn adbul c ett
s
o Tpuhre
cChaountyuses
MCCsto
cont
rolthe
ty
pes ofproducts
or
services
xa mp
leareproh
ibited
for
saellPcau
rrd
chhoal
sdie
nrg
soafntd
imaettsehmarpetssaa
nrdedidaentt
ing
or
bettings
ervices fo
ar
Tonhteh er
ach
Ce
Am
(Purchasing)authorizationandapprovalL‐C rd
an its rsquosnMoCtCtoE b
aec husceadrd
fhora ts raasninsagcletiotrnasn sthacatti ro neqliumiriet tand
ifieda monthlyandblocked
spend
blimitased
he
In
Purchasing Divisionrsquos
s$2249016ig
FY1112
n au
CAL‐ C arsde Ur
ach
Cou
agEthe
emeCounty
sreers M
nta
nty
fehmployee
nouraml wT
ad approximately
oissued
h provideich wa
292 cardholders who charged a total of
guida
a
s lasnC
tceAL‐Card
r t
is
eocard
equired
v ised
holders n
r
i
Janthe tCountyo
attend
dev
traeloped
in ing
atnhed
intranet
gsapurPDFcal_card_user_manualpdf)uary 2013 (httpsc
‐
In(ATTC)
February 2013 Purchasing
ApprovijoinngO
tlyf
ficpresenials(
AtOesd)theAll
an
andu
County Auditor‐
c anrdalhorefreshldersa n
erdA traOinsa ingC
e toontroller Trea
r r eqaullirceardholdersd toa
surer‐Tax
Collector
c know
andledg
Deepartmentreceiving
traininginordertocontinueperformingtheirassignedfunctionsTh traie ningprovidedan
CAL‐CardProgram CountywideAudit AuditNo3108 Page6
Introduction amp Background
overview of the CAL‐Card program and policies guidelines and procedures thatcardholders and AOs are required to comply with Key areas such as roles andresponsibilities
author
ized
key componen
t of
the
programrsquos
u se an
idntrere qnalui
recdontroldocu
msystenemta
tiodesignw
enedrec
toovered
redu
cTe tr
noncompliancewithpo
liciesa
ndp
roceduresandtoestablishacc
aining
ountability
he risk
is o
af
theAs we
County discuss
as onwell
pageas
24indiv
datiduala provided
department
y
b the
developingeffectivepurchasingstrategiesVendor
and MCC can be used to compensate for the
n
spendinCAL‐Car
d
provide
can
lac
r
kprov
beu
sed
toestablish
purchasingcardenviroorm
ally r
eq
u ired
b
ynment
th
e trad itional
proc
urement
g profiles which can be useful in
opf pidedre‐a
fue tahtourriezsationsuch
pa
rocssp
eessnd limits
rocedures but not practica thatl
in
ias
PoliciesTheforimplement
and Procedures Countyrsquos Purchasing
ingtheprogram Agent
at isthe
t
he
depar
C
AL‐CardProgramAdministratorwho
programand enforcing
tment levelprovidin
g training
a
Departmearnte 1)
thetheprCogramAL‐Card
policiesuser 2)
andthe
p roceduresDepartmen
The key
roles in
Billing Officialand 4)theProgramAdminis
trtaAOtor
T3)hethe
responsibilitACCT
isresponsible
aredescrib
e
din
t
heCAL‐Cardpo
liciesandproceduremanual
nd
Cthe
d
Aevelopin
PCAL‐Card
ies sotafffeach
g
4)
Departmentf
headssettheindividualtransaction(upto$2500)andmonthlyspendlimits
appropriataonrd eau hrc
pc c
haarsdi
nignpuosl
eicie
sThe
cardholde
rs arerespo
nsib
le
for com
plyin
edocumenta
t
g
activities
toensur
ethat
wi
th
th
eC
AL‐Card
aprocedurespplicatio
ns
The Billing
or can
cella
ionpre
toparsuinpg
all
purchases
ptohretmto CA
een
appropriatcthhaly
arh rges
LT‐ChaerdAOPsurrcehvaiesweRandepoapprortand
vepraccountoviding
Officia
ls c
oordinate
einaccordancewiththepoliciesand
receives and audits the CAL‐Cati
on ofrd in
paaymentctiv
e o
nes
T
activities
he A
CT
T
suchC A
as
lcco
c aimstoensurethatea
processinguchntschargePayable
o
f new
supported
card
ff
is a
(AP)dequat
stelya
CAL‐CardProgram CountywideAudit AuditNo3108 Page7
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Introduction amp Background
IntroductionWeconducted
have
Practice of
completed
theInternal
audit
the
Auditingin a
auditccordance (St
of
andards)
thewSithonomathe
analyze eva
International Standards for the Professional
objectives Wluatee believ
ande documentthat the evid
sufficenceient
Countyrsquos
(County) CAL‐Card program We
resultsobserva
ndrecommenda
tions
a
informaThese S
tiontandards require that we identify
tionscobontainedtained provides
and
aev
ridence
itreporteasonable
t
ouraud
o
in
The purpose of this audit report is to furnish management
independent
achbasisieve
forauditthe
analys esrecommendations
andot
her
informa
and objective
auditreportisatoolto
helpm
anagement
identifyation
concerning
t
he
act ivities reviewed The
throughoutWewouldlike
theaudittothankmanagementand
ndimplemen
for their
timprovements
staff
timeinformation and cooperation
Background
OverviewThe
ptraditionurc
Countyal paper implement
and ledabor‐intens
the purchivease
ofCa
and
procurementcard(CAL‐Card)
process
programfor
in2000tostreamline
certain
small dollar
the
value
requ
less
hliafosersniCa Tu
rhreeCntAlyL
‐Ct
haerdCAalLl o‐Cwasrtd
hiesCmoaunaged
oisfiftiicoenss toord rireeccetliyvinmgarkee l w o a
transacp
o d ll rnvatyludee
than$2500per tionorts
including TheC
AtaxesL ‐Ca
bpyaUrtmSeBntasnBkoinarpartnershipdofSupervisor
withst tate
uagencheS
pdr
ies
rIcc
tahnasbeesu sweidthout
canalsobetouosedb tpareparing
forin s
traveluppli
e purchase
esxpenses costing
allowedwithin
the Cou
ntyrsquos
Travel
and
Meal Reimbursement
Countybusiness
Polic
y guidelin
es
while on
The rdsystem
mCAL‐Ca
usesmerchantcategorycode(MCC)toidentifythetypeofbusinessa
ecaerrdc
hhoalndtecr
oisn adbul c ett
s
o Tpuhre
cChaountyuses
MCCsto
cont
rolthe
ty
pes ofproducts
or
services
xa mp
leareproh
ibited
for
saellPcau
rrd
chhoal
sdie
nrg
soafntd
imaettsehmarpetssaa
nrdedidaentt
ing
or
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ervices fo
ar
Tonhteh er
ach
Ce
Am
(Purchasing)authorizationandapprovalL‐C rd
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aec husceadrd
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ifieda monthlyandblocked
spend
blimitased
he
In
Purchasing Divisionrsquos
s$2249016ig
FY1112
n au
CAL‐ C arsde Ur
ach
Cou
agEthe
emeCounty
sreers M
nta
nty
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nouraml wT
ad approximately
oissued
h provideich wa
292 cardholders who charged a total of
guida
a
s lasnC
tceAL‐Card
r t
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eocard
equired
v ised
holders n
r
i
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attend
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traeloped
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gsapurPDFcal_card_user_manualpdf)uary 2013 (httpsc
‐
In(ATTC)
February 2013 Purchasing
ApprovijoinngO
tlyf
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AtOesd)theAll
an
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surer‐Tax
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c know
andledg
Deepartmentreceiving
traininginordertocontinueperformingtheirassignedfunctionsTh traie ningprovidedan
CAL‐CardProgram CountywideAudit AuditNo3108 Page6
Introduction amp Background
overview of the CAL‐Card program and policies guidelines and procedures thatcardholders and AOs are required to comply with Key areas such as roles andresponsibilities
author
ized
key componen
t of
the
programrsquos
u se an
idntrere qnalui
recdontroldocu
msystenemta
tiodesignw
enedrec
toovered
redu
cTe tr
noncompliancewithpo
liciesa
ndp
roceduresandtoestablishacc
aining
ountability
he risk
is o
af
theAs we
County discuss
as onwell
pageas
24indiv
datiduala provided
department
y
b the
developingeffectivepurchasingstrategiesVendor
and MCC can be used to compensate for the
n
spendinCAL‐Car
d
provide
can
lac
r
kprov
beu
sed
toestablish
purchasingcardenviroorm
ally r
eq
u ired
b
ynment
th
e trad itional
proc
urement
g profiles which can be useful in
opf pidedre‐a
fue tahtourriezsationsuch
pa
rocssp
eessnd limits
rocedures but not practica thatl
in
ias
PoliciesTheforimplement
and Procedures Countyrsquos Purchasing
ingtheprogram Agent
at isthe
t
he
depar
C
AL‐CardProgramAdministratorwho
programand enforcing
tment levelprovidin
g training
a
Departmearnte 1)
thetheprCogramAL‐Card
policiesuser 2)
andthe
p roceduresDepartmen
The key
roles in
Billing Officialand 4)theProgramAdminis
trtaAOtor
T3)hethe
responsibilitACCT
isresponsible
aredescrib
e
din
t
heCAL‐Cardpo
liciesandproceduremanual
nd
Cthe
d
Aevelopin
PCAL‐Card
ies sotafffeach
g
4)
Departmentf
headssettheindividualtransaction(upto$2500)andmonthlyspendlimits
appropriataonrd eau hrc
pc c
haarsdi
nignpuosl
eicie
sThe
cardholde
rs arerespo
nsib
le
for com
plyin
edocumenta
t
g
activities
toensur
ethat
wi
th
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eC
AL‐Card
aprocedurespplicatio
ns
The Billing
or can
cella
ionpre
toparsuinpg
all
purchases
ptohretmto CA
een
appropriatcthhaly
arh rges
LT‐ChaerdAOPsurrcehvaiesweRandepoapprortand
vepraccountoviding
Officia
ls c
oordinate
einaccordancewiththepoliciesand
receives and audits the CAL‐Cati
on ofrd in
paaymentctiv
e o
nes
T
activities
he A
CT
T
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as
lcco
c aimstoensurethatea
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o
f new
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ff
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(AP)dequat
stelya
CAL‐CardProgram CountywideAudit AuditNo3108 Page7
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Introduction amp Background
overview of the CAL‐Card program and policies guidelines and procedures thatcardholders and AOs are required to comply with Key areas such as roles andresponsibilities
author
ized
key componen
t of
the
programrsquos
u se an
idntrere qnalui
recdontroldocu
msystenemta
tiodesignw
enedrec
toovered
redu
cTe tr
noncompliancewithpo
liciesa
ndp
roceduresandtoestablishacc
aining
ountability
he risk
is o
af
theAs we
County discuss
as onwell
pageas
24indiv
datiduala provided
department
y
b the
developingeffectivepurchasingstrategiesVendor
and MCC can be used to compensate for the
n
spendinCAL‐Car
d
provide
can
lac
r
kprov
beu
sed
toestablish
purchasingcardenviroorm
ally r
eq
u ired
b
ynment
th
e trad itional
proc
urement
g profiles which can be useful in
opf pidedre‐a
fue tahtourriezsationsuch
pa
rocssp
eessnd limits
rocedures but not practica thatl
in
ias
PoliciesTheforimplement
and Procedures Countyrsquos Purchasing
ingtheprogram Agent
at isthe
t
he
depar
C
AL‐CardProgramAdministratorwho
programand enforcing
tment levelprovidin
g training
a
Departmearnte 1)
thetheprCogramAL‐Card
policiesuser 2)
andthe
p roceduresDepartmen
The key
roles in
Billing Officialand 4)theProgramAdminis
trtaAOtor
T3)hethe
responsibilitACCT
isresponsible
aredescrib
e
din
t
heCAL‐Cardpo
liciesandproceduremanual
nd
Cthe
d
Aevelopin
PCAL‐Card
ies sotafffeach
g
4)
Departmentf
headssettheindividualtransaction(upto$2500)andmonthlyspendlimits
appropriataonrd eau hrc
pc c
haarsdi
nignpuosl
eicie
sThe
cardholde
rs arerespo
nsib
le
for com
plyin
edocumenta
t
g
activities
toensur
ethat
wi
th
th
eC
AL‐Card
aprocedurespplicatio
ns
The Billing
or can
cella
ionpre
toparsuinpg
all
purchases
ptohretmto CA
een
appropriatcthhaly
arh rges
LT‐ChaerdAOPsurrcehvaiesweRandepoapprortand
vepraccountoviding
Officia
ls c
oordinate
einaccordancewiththepoliciesand
receives and audits the CAL‐Cati
on ofrd in
paaymentctiv
e o
nes
T
activities
he A
CT
T
suchC A
as
lcco
c aimstoensurethatea
processinguchntschargePayable
o
f new
supported
card
ff
is a
(AP)dequat
stelya
CAL‐CardProgram CountywideAudit AuditNo3108 Page7
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
The Countyrsquos CAL Card Spending Profile
The Countyrsquos CAL‐Card Spending ProfileThe Countyrsquos CAL‐Card purchases increased 9 from $176 million in FY 0910 to $192 millioninFY1011and another 17to$225 millioninFY1112
COUNTYWIDE CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
$3000000
$2000000
$1000000
$0 FY0910 FY1011 FY1112
Source Purchase activities from 7109 to 63012 provided by US Bank
The top five user departments accounted for 67 of the total purchases in FY1112 withtheWaterAgencyaccountingfor43
Source Purchase activities from 7109 to 63012 provided by US Bank
$0$200000$400000$600000$800000
$1000000
FY0910 FY1011 FY1112
TOP 5 DEPARTMENT CAL‐CARD ACTIVITIES FY0910 THROUGH FY1112
Sonoma Water
SheriffDept
Trans amp Public
Human Services
Facilities Oper
In FY1112 292 cardholders charged about $225 million The number of cardholders perAO ranged from 2 to 11 The average CAL‐Card annual charge per user ranged from $970 to$21092
Department
COUNTYWIDE CAL‐CARD ACTIVITIES SNAPSHOT (FY1112) of
Cardholder of
Approver of Trans
Net Purchase
of Net Purchase
WaterAgencySheriffDepartmentTransamp PublicWorksHumanServicesFacilitiesOperationProbationHuman ResourcesInformation SystemsDistrict AttorneyEmergencyServicesOtherDepartments
Total
50 17 3126 977579 4319 9 826 202207 935 13 628 127740 620 1 701 119594 56 2 252 90384 421 7 665 85482 414 6 521 78766 411 1 426 71979 323 7 382 51162 27 2 317 47855 286 44 2377 396268 18 292 109 10221 $2249016 100
Source Purchase activities from 7111 to 63012 provided by US Bank amp Purchasing
CAL‐CardProgram CountywideAudit AuditNo3108 Page8
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
The Countyrsquos CAL Card Spending Profile
Average annual charges by top ten users ranged from $33 2012 to $100986 and in total accountfor25oftotalcharges
COUNTYWIDE CAL‐CARD TOP 10 USERS (FY1112) Department Job Title Amount WaterAgency Principal Engineer 100986 Sheriff Department Department Analyst 70425 WaterAgency MaterialsEquipment Specialist 69687 WaterAgency Coordinator 67112 WaterAgency Coordinator 57405 Sheriff Department Department AccountingManager 43282 WaterAgency Coordinator 42797 WaterAgency AutomotiveMechanic 34482 WaterAgency EnvironmentalResourcesCoordinator 33253 WaterAgency Coordinator 33012
Total $552442 Total Countywide Spending $2249016
4333322211 25
Source Purchase activities from 7111 to 63012 provided by US Bank amp Payroll Division
Thespendingin retail storesaccountsforthelargestportion ofthetotalCAL‐CardchargesTheCounty couldidentifysavings opportunitiesif furtheranalysisof individual expenditurecategories isperformed
COUNTYWIDE TOP SEVEN CATEGORIES OF CAL‐CARD EXPENDITURES (FY1112)
Retail Store $757217 34
Business Services $328648 15
HotelMotel $255972 11
AirelineAirport $170154
8
Membership Registration $146571
7
Catalog Merchant $142006
6
Meals $90518 4
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page9
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
The Countyrsquos CAL Card Spending Profile
The top expenditure category data above can be used in conjunction with the top vendor data provided below to identify opportunities for consolidating purchases to negotiate priceandotherterms There appearstobesuchanopportunity forthetravelcategory
COUNTYWIDE TOP FIVE VENDOR OF CAL‐CARD EXPENDITURES (FY1112)
DELL $59604 27
Amazon $69735 31
Southwest $53126 24
United Airlines $40456 18
Hilton $31053 14
Hyatt $29898 13
Source Purchase activities from 7111 to 63012 provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page10
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Objectives amp Scope
ObjectivesOurprimaryauditobjectiveswere todetermine if
The CAL‐Card policies procedures and controls are adequately designed and functioning effectively to prevent or detect fraudulent improper and abusive transactions
Purchases made on the CAL‐Cards were in compliance with the CAL‐Card procedures andrelevant purchasingguidelines
We also identified ways to increase process efficiencies based on the best practices implementedbypeer entities
ScopeOn February 5 2013 the County Board of Supervisors adopted the CAL‐Card review planwhich requires the County Administrator the County ATTC and the General ServiceDepartment to implement an action plan to ensure continued compliance with the Countypolicies and the effectiveness of the CAL‐Card program Our audit is a part of that plan and coversthe CAL‐CardpurchasetransactionsfromFY1011toFY1112
During our audit period the County had approximately 292 cardholders who charged atotal of $4173836 Our audit was designed to assess the cardholdersrsquo compliance withestablished policies and procedures and the effectiveness of internal controls over tested areas We also identified opportunities to enhance the efficiency and effectiveness of theprogramAuditfieldworktookplacefromMay2013 throughAugust2013
The County management (management) is responsible for establishing and maintaining a system of internal controls to achieve the objectives of effective and efficient operations and compliance with policies and procedures The objectives of an internal control system are to provide management with reasonable but not absolute assurance that assets aresafeguarded against loss from unauthorized use or theft transactions are executed inaccordance with managementrsquos authorization and program or function goals and objectivesareachieved
Although we exercised due professional care in performing our audit unreportednoncompliance or irregularities may remain unidentified Audit procedures alone evenwhen carried out with professional care do not guarantee that fraud or irregularities will bedetectedThedeterrenceof fraudistheresponsibilityof management
In order to respond timely to managementrsquos request we excluded certain areas from our audit scope Our audit did not include a review of card issuance card deactivation system administration timeliness of reconciliations and the CAL‐Card provider contract compliance
CAL‐CardProgram CountywideAudit AuditNo3108 Page11
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
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rtm
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aren
otbein
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ransactionsforImprovement
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effectivelyasintendedtoprevent unallowablepurchases progr
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s Therefor
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proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
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County can realize significant savings t h
hroug
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nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Methodology
Reviewedt
heCAL‐Cardandrelevantpurchas
ingpolicies
a
IdentInterviewedpersonnelperforming
ified controls over the key pthekeyCAL‐Cardfuncrocesses including aut
andreconciliation
ures
ndproced
tions
horization approval
review
practices for purchase
Researched best c
mpractices)anageme
nt
implemented b y pe
er e ntitie
s (ardSe
programe Append
iprocessx A for e
pxamplesrocedures
of
banestd
ed
statReview
ementsj
f
operatioPerformed
nal
udgmentally‐selected
orev
data idencesofcompliancew
efficiencianal
esandeffectivenessysis of
samples of the CAL‐Card charges and cardholder
purchase
ithpoliciesantransactio
ns
td
oproced
identify
ures
opportunities
for
Sample
sTransactiotateme
n
Selection
tsn w samplesith
h
igh
w dere selec
unallowable charges Theoll
arsa
departments
ated
mplesmou
basednt
wers la
on
er gsea
elected n risk‐basedumb
etors
approac
cooverf tra
hWe
targeted
m
onthly
ns
aabcrtoionsad range
and pofotentiallyCounty
TheResults
adequately policies
procedur
duringtoesda
ions the
ectnd
except ndotedesig
ned et
audit
intfrauernaldulent
ontro s
(See
c l
deimpails
roperat
over the
t Opportunitieso rabusive
and
oceourdure
discussions
pr s
atthe
depawith
Purchas
ing and
ACTTC
rtm
en
t level
aren
otbein
CAL‐Cardprogramare generally
t
staff
in
ransactionsforImprovement
Howeversection)
the
conclude that the internal control system overg tahede
CqAL‐Carduatelyc
dicatom
pliede
thwithat
effectivelyasintendedtoprevent unallowablepurchases progr
am
s
internal
s Therefor
control
i n ot functioeniweng
proactivelymanagingtheCAL‐CardprogramOur review
lso indicates
that
the
a
County can realize significant savings t h
hroug
The
recommendationsresults
followingfrom those
sect
efficiencyandeffective
ipons
rocedures
provideanddeta
theiriled
imdiscussions of the audit work performed the
fornessasstrengthening
a ppropriatinteer nalplication
controlons theand
p rogenhanciramW
nge t hhaev pe prorogrvaidmersquods
Managementrsquos response to our observations and recommendations are a t Appendix D
Toachieveourauditobjectiveweperformedthefollowingauditprocedures
Methodology Sample Selection amp Results
CAL‐CardProgra
AuditNo3108
m
County
wideA
udit
Page12
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Observation 1 Strengthen Controls to Reduce Unauthorized Purchases
A Restricted and Unallowable PurchasesThe CAL‐Card Users Manual establishes the rules and guidelines that employees mustfollow in order to retain the privilege of having and using the CAL‐Card When applying for the card users confirm that they understand the rules governing card use and agree to comply with them To determine if the CAL‐Cards were used appropriately we judgmentally sampled 40 individual statements with 200 transactions from FY1011 to FY1112 for testing We noted that 39 or 20 of these transactions werefor purchases of services or supplies not allowed by the CAL‐Card policy Moreover a majority of these exceptions were identifiedbyACCTCAP staff andnotbythedesignatedAOs
ISSUES IDENTIFIED IN THE REVIEW OF SAMPLE Purchase Type of Trans Exception ITrelatedItems RestrictedCommodities 11Alcohol ProhibitedUse 5Mealsover DailyMaximum ProhibitedUse 5Work Performed On‐site Prohibited Use 18
6339
Total of Transaction Reviewed 200 20 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurther explanationoftheissuesshownabove
Restricted CommoditiesEleven IT‐related purchases including laptops and routers for approximately $17000 werepurchased without pre‐approval from Information Systems Department (ISD) or anappropriate designee As a result there is a risk that these equipments are incompatible with the Countyrsquos current IT infrastructure or pose security risks According to the CAL‐Card User Manual restricted purchases such as computer and software can only bepurchased upon advance approval of the ISD Director his designee or other authorized department oragency management
Unallowable ExpensesWeidentified$12627 inunallowablepurchasesasdetailedbelow
Purchase Amount UNALLOWABLE EXPENSES
Note Policy Reference AlcoholicbeverageonCounty travel
$100 EmployeesreimbursedtheCounty CAL‐CardUserManual3‐2
Alcoholrelateditems
$460 Basketscontaining winegivenawayat aconference
CAL‐CardUserManual3‐2
Meal Expense $81 Fouremployeesexceeded thedailymaximumof$90andreimbursedtheCountyfortheamountoverthedailyallowance
Policy for TravelampMealReimbursementsA‐2‐c
Work performedonCountyrsquosproperties
$11986 Servicesperformedon‐site shouldbedonethrougheither service agreementor purchase order
CAL‐CardUserManual3‐2
Total $12627 Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page13
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Approximately $12000 in services performed on‐site were paid using the CAL‐Card andnot through the service agreement process as required All services agreements arereviewedbyPurchasing toensure that
Deliverables are sufficiently described to fix the contactorrsquos responsibilities (County Counselisconsultedasnecessary)
Competitivebidprocessisfollowedifwarranted The vendor has adequate insurance coverage (Risk Management is consulted as
necessary)
When the required reviews and approvals of Purchasing County Counsel and RiskManagement as appropriate are bypassed the County becomes exposed to various risksFor example the services may not be performed as expected or be over‐priced TheCountymaybecomeliableforthe lackofperformancebyvendors
B Lack of Proper AuthorizationPreventive controls are designed to prevent the occurrence of errors or irregularities For example unauthorized expenditures can be identified through a managerrsquos review ofsupporting documents prior to payments being made Such controls have been implemented for the CAL‐Card program to ensure that the County only pays for allowable purchases The designated AO is required to verify the cardholderrsquos charges forappropriateness and approve the cardholderrsquos monthly statements before submitting toACCTC AP section forpaymentprocessing
Toassesstheeffectivenessoftheapprovalprocesswejudgmentally sampledandreviewed100 statements from FY1112 for proper authorizations We noted that 30 or 30 werenotapprovedorapprovedbyan unauthorizedindividual
LACK OF PROPER CERTIFICATION OF STATEMENT (FY1112)ofCardholderrsquosstatementprocessedwithoutAOrsquossignature 13
Approved byStaffinsteadofDesignated AO 17Totalexceptions 30
TotalofStatementReviewed 100 Exception Rate 30
Source Auditor‐generated workpaper from files scanned in Softfile
Thefollowingprovides furtherexplanationof theissuesnoted above
a) Thirteen out of 100 statements reviewed were processed without any approval Thesestatements may have been reviewed by designated AOs however it cannot be substantiatedwithout asignature asevidence
b) We noted that another 17 statements were signed by employees other than the designated AO
In order for an internal control system over a purchase card program to functioneffectively allrequired reviews andapprovalsmustbeperformedby individuals whohave
CAL‐CardProgram CountywideAudit AuditNo3108 Page14
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
been officially designated to do so These individuals provided with appropriate trainingcanbeheldaccountablefortheirreviewsand approvals
C Untimely Travel AuthorizationEmployees are allowed to use the CAL‐Card for travel expenses such as meals airline tickets and lodging covered under the Countyrsquos Travel and Meal Reimbursement Policy Inaccordance with that policy travel authorization is required to be obtained before any related travel expense is incurred We reviewed 100 cardholdersrsquo travel authorization forms and noted that 18 (18) were not approved prior to the travel date The average delay was 28 days with one instance where the approval took place 64 days after the traveldate
UNTIMELY TRAVEL AUTHORIZATION (FY1112)
Employee
Date of Travel Expense Incurred
Date of Management Authorization
Gap between Approval amp Expense Incurred
1 12611 2812 64 2 52312 71612 54 3 53112 71612 46 4 103011 12611 37 5 11211 12711 35 6 61212 71612 34 7 61212 71612 34 8 21412 31612 31 9 6712 7812 31 10 111111 12811 2711 5212 52512 23 12 51012 6112 22 13 6712 62612 19 14 62712 71112 14 15 91711 92711 10 16 22812 3712 817 11811 111411 618 52412 53012 6
Average of Day Delayed 28 Source Auditor‐generated workpaper from files scanned in Softfile
Travel authorization is a preventive control to ensure that employees travel only when necessary After the fact travel authorizations indicate that travel expense is not managed asintended andthat theemployeesareunilaterallydetermining the need totravel
D Split TransactionsThe Countyrsquos CAL‐Cards are established to have a single‐transaction limit usually set at$2500 Among other reasons higher dollar value transactions need to be reviewed byPurchasing to determine if a bid process is warranted These limits also help to control the Countyrsquospertransactionexposuretofraud
A split transaction occurs when a cardholder splits a purchase in two or more transactionsto avoid being blocked for exceeding the per transaction limit We analyzed the CAL‐Card activities between FY1011 and FY1112 to identify potential split purchases We searched for instances where two or more transactions had the following in common and whenaddedtogetherexceeded$2500
CAL‐CardProgram CountywideAudit AuditNo3108 Page15
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Vendor name Transaction date Cardholderplacingthecharge
Wefoundmultipleinstanceswheretheabovecriteriaweremet
SPLIT TRANSACTIONS IDENTIFIED (FY1011‐FY1112) of Total Amt Exceeded
Year Instance Authorized Limit Majority of Purchased Item FY1112FY1011
15 $14446 Equipment ComputerSupplies 13 $15029 Equipment ComputerSupplies
Source Auditor‐generated workpaper from data provided by US Bank
These split transactions were approved by AOs In addition there was no evidence indicatingthatfollowupandor corrective actionsweretaken
As employees become aware of failures in controls such as prohibited items being approved those predisposed to misusing the card are likely to attempt fraudulent improper and abusive purchases Splitting of transactions also result in bypassing purchasingcontrolsdesignedtomanageavarietyof risks
Recommendation No 1Purchasing should implement a framework for misuse of cards and assure consistent and prompt application of disciplinary and administrative penalties countywide A policy should be developed to include deactivating suspending or cancelling accounts of repeat violators
Recommendation No 2Purchasing should set clear expectations and establish accountability for AOs AOs shouldbe formally appointed through acknowledgment forms which outline their basicresponsibilitiesanddutiesand emphasizethecriticalfunctionthat they will be responsiblefor
Recommendation No 3Purchasing should provide resources and tools to AOs to identify and correct a variety ofissuesincludingunallowablepurchasesorothermisuseofcardsAchecklistfor identifying violationsofpoliciesand procedureswouldbeanexample
Recommendation No 4Purchasing and ACTTC should collaborate to execute periodic performance reviews of the CAL‐Card program The CAL‐Card policy violations identified relevant statistical data and otherinformationshouldbesummarized and reportedto management
CAL‐CardProgram CountywideAudit AuditNo3108 Page16
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Observation 2 Strengthen Controls over Meal Expenses
The Countyrsquo meals‐related expenses charged to the CAL‐Card program increased from $80000 in FY0910 to about $90000 in FY1011 and remained at $90000 in FY1112 InCounty meals account for approximately 62 of total meals charged to the CAL‐Card program
Source Auditor‐generated workpaper from data provided by US Bank
$70000$75000$80000$85000$90000$95000
FY0910 FY1011 FY1112
MEAL EXPENSES EATING PLACESFAST FOOD RESTAURANTS FY0910 THROUGH FY1112
Although the total meal expense is not material in comparison to the total CAL‐Cardpurchases (5 and 4 of the total CAL‐Card charges in FY1011 and FY1112 respectively) it is a cost category susceptible to wasteful spending and abuse Failure to clarify and communicate acceptable practice in this area increases the risk of wasteful or abusivespending
Theresults fromourreview indicatedthatcontrolsshouldbestrengthened inthe followingareas
A Control Weakness over DocumentationThe following shows the total CAL‐Card meal expenses charged through restaurantssupermarketsandmiscellaneous foodstoresbycityinFY1112
COUNTYWIDE MEAL EXPENSES BY CITY(FY1112) Location Amount of Trans of Total Meal Santa Rosa 47677 522 53Washington 3837 50 4RohnertPark 2895 21 3Windsor 2404 25 3Sacramento 2109 105 2Petaluma 1847 26 2Guerneville 1562 17 2Monterey 1482 50 2Seattle 1363 19 2LosAngeles 1278 30 1OtherLocations 24064 731 27 Total Meal Expenses $90518 1596 100
Source Auditor‐generated workpaper from data provided by US Bank
CAL‐CardProgram CountywideAudit AuditNo3108 Page17
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Based on the data presented above approximately $56000 in meal expenses were incurred within the County representing 62 of the total meal expenses To determine ifthe local meal expenses were necessary and reasonable we judgmentally sampled 50transactionsoccurring inSantaRosafromthe topfourdepartmentslistedbelow
TOP 4 DEPARTMENT OF LOCAL MEAL EXPENSES (FY1112) Department Amount of Trans of Total Amt WaterAgency 14673 174 31BoardofSupervisors 4686 43 10SheriffDepartment 3969 38 8HumanServices 3832 42 8OtherDepartments 20518 225 43
Total $47677 522 100 Source Auditor‐generated workpaper from data provided by US Bank
While our review of 50 out of 522 transactions showed that most transactions appeared reasonable we found some instances in which controls were not functioning effectively Specifically wefoundthat
SUMMARY OF ISSUES IDENTIFIED(FY1112) Concern of Trans Exception Total Amt Receiptswerenotalwaysitemized 4 8 $468
Supportingdocumentationwasprovidedsubsequenttotheclaimapprovalandpaymentbeingissued
7 14 $2388
Total of Transaction Reviewed 50 22 Source Auditor‐generated workpaper from data provided by US Bank
Thefollowingprovides afurtherexplanationoftheissuesshownabove
a) Four meal receipts ranging from $70 to $199 were not itemized As a result we wereunable to determine the reasonableness of such expenses and whether unauthorizeditemssuchasalcoholwerepurchased
b) Supporting documentation including the business purpose and list of participants wasnot provided to substantiate $2388 in meal expense at the time of payment The information was provided subsequent to the approval of claim and payment being issued
The practice of approving purchases without evidencing appropriate supportingdocumentsincreasestheriskofunauthorizedpayments
CAL‐CardProgram CountywideAudit AuditNo3108 Page18
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
B Re‐Evaluate the Current Meal Policy
Meal AllowanceThe Travel and Meal Reimbursement Policy allows a maximum of $90 per person per day for meals including gratuities for out‐of‐town or overnight business trips At the discretion of the DepartmentAgency HeadGeneral Manager or designee departments may elect toreimburse for meals utilizing rates equal to or less than the Federal per diem ratesestablished byTheUSGeneralServicesAdministration(GSA)
Subject MEAL EXPENSE POLICY COMPARISON
County Meal Reimbursement Policy GSA Federal Per Diem Rate
Meal Allowance
Maximum of $90eachday per employee
The mealampincidental expense(MampIE)tiersrangefrom$46‐$71per day based on datareceivedfrom anationwidemealsstudy
Destination Dailymaximum is$90 for alltravelsoutsidethegeographicalboundariesofSonomaCounty
Variesdependingonaveragecostofmealsatdestinations
First amp Last Travel Day
Norequirements Only75ofthetotalMampIErate
Source GSA Travel amp Relocation Policy Per Diem Rate Website
To determine if the meal expenses were reasonable and within Countyrsquos guidelines wesampled and reviewed nine out of 92 (10) out‐of‐town meal reimbursements greaterthan $90 in FY1112 The average per person meal cost ranged from $39 to $89 as listedin column c which in many of the cases is significantly higher than Federal per diem limits(column d) Column f g and h show the savings in out‐of‐town meal expenses if Federal rates had been used As shown in column h the County could have potential savings inmealexpensesrangingfrom17toasmuchas 54byadoptingtheFederalrates
ACTUAL MEAL EXPENSES VS FEDERAL PER DIEM
Tran
Actual Meal Expense
Location
a b c
Total Amt
of Attendee
Average Per Person (ab)
Federal Per Diem
d e
Per Person
Total for All Attendees (bc)
Actual Amount Exceeded Federal Per Diem
f g h
Per Person (c‐d)
Total (a‐e)
(ga)
123456789
Seattle $711 8 $89Washington $297 4 $74Washington $257 4 $64HuntingtonBe $117 2 $59Washington $546 10 $55Dixon $107 2 $54Washington $211 4 $53Washington $596 12 $50Anaheim $389 10 $39
$41 $328$41 $164 $41 $164 $28 $56 $41 $410 $34 $68 $41 $164 $41 $492 $28 $280
$48 $383 54$33 $133 45$23 $93 36$31 $61 52$14 $136 25$20 $39 36$12 $47 22$9 $104 17$11 $109 28
Total $3232 $2126 $1106 34 Source Auditor‐generated workpaper from data provided by US Bank ‐Allowance includes the meal amp incidental expenses ($5) per destinations corresponding with breakfast lunch and dinner
CAL‐CardProgram CountywideAudit AuditNo3108 Page19
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
The County could identify more saving opportunities from revising the meal reimbursement policy if a thorough analysis which includes these meal expenses outside theCAL‐Card programisbeingconducted
Justification of Business MealsThe current in County meal policy requires that 1) the need to schedule such meetings during meal time to be clearly supported and 2) the business purpose achieved to be documentedindetail
Based on our review we noted a number of the CAL‐Card charges were for breakfast for events such as management team and combined fund drive kickoff meetings and other mealsasshownbelow
MEAL CLAIMS Purpose AmountCombinedFundKickoff BreakfastCombinedFundKickoff BreakfastNewEmployeesLunchMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingManagersampSupervisors BreakfastMeetingTotal
1089583928521965167501358013500
$214038 Source Auditor‐generated workpaper from files scanned in Softfile
Although the business purpose was indicated we were unable to determine why it neededto be conducted over a meal In consultation with Purchasing and ACTTC staff morespecific guidelines should be established for determining allowable business purposes formeals
Documentation required should be sufficient to support the need for the business to be conducted over a meal As evidenced by high percentage of in County meal (63 of totalmealexpenses)thepolicycanbefurtherstrengthenedtobettermanagemealexpenses
Recommendation No 5The County should re‐assess its employee meal reimbursements policies and better defineallowable practices and documentation standards (eg itemized receipts) A review shouldbe performed periodically and reimbursement rates adjusted as necessary to better align with the actual costCAL‐Cardmeal purchasesthatdo not meettheCountyrsquosrequirementsshould be considered unallowable after adequate training has been provided to the CAL‐Cardusers andAOs
CAL‐CardProgram CountywideAudit AuditNo3108 Page20
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Observation 3 Adopt A Risk Based Approach of Selecting and Auditing the CAL‐Card Transactions
The ACTTC AP section performs detailed reviews for 100 of the CAL‐Card transactionsexpending approximately 80 hours of staff time in a month These reviews are essentialbecause they operate as detective controls to 1) detect errors and violations of policies and 2) measure the effectiveness of preventive controls such as authorizations However a100 review should not be necessary to meet control objectives if preventative controlssuch as CAL‐Card usersrsquo awareness and AOsrsquo reviews can be relied upon and appropriate sanctionsareapplied whenviolationsare noted
Between February 2013 and July 2013 $281 personal expenses were identified andreimbursed from responsible employees However there were no consequences on the cardholders or the departments for other violations noted such as work performed on premisesor splitpurchasestransactions
Adopting a risk‐based audit approach together with appropriate policies and procedures addressing misuse of cards (Recommendation 1) could significantly reduce the cost and improvetheoveralleffectiveness oftheinternalcontrol system
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of audit sample criteria are listed belowbutnotlimitedto
Target Group The Nature of Risk Department Head TheApprovingOfficialisunder hishersupervision First‐TimeUser TheCardholder maynotfullyunderstandtheprocedures TopSpender TheCardholdermaypotentiallybe misusing thecard RepeatViolators TheCardholder mayhavethetendencytoviolatetheprocedures High Risk Items Itemseasilyconvertibletoprivateusesuchas in town meals
Auditing a sample of transactions selected based on risk and coupled with a policy to deactivate suspend or cancel accounts of repeat violators would be a more cost effective alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page21
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Observation 4 Consider Deactivating Infrequently Used Cards
Based on their credit limits cardholders could charge as much $26 million in a month As such each credit card issued poses significant inherent risks which have to be managed by appropriate internal control activities The business purpose of issuing a card shouldthereforejustifytheaddedrisksandthecost tomanage them
TheCounty couldreduceitspotentialfinancialriskandbetter manageandcontroltheCAL‐Card program by limiting the number of cardholders and related credit limits to the levelsnecessarytomeetoperationalrequirements
The County currently does not have any procedures in place to identify infrequent card users and assess their continued need for the cards In FY1112 292 cardholders charged about $22 million While some cardholders had several thousand dollars in purchases othersrarelyusedtheircards
Our review of 292 cardholdersrsquo 12 monthly statements showed that 92 out of 292 (32)cardholders had minimal use These cards accounted for about $91000 or four percent ofthe annual total CAL‐Card purchases Inaddition 31 outof these92cardholders used theircardslessthanfivetimesannuallyspendinglessthan$500in total
Each active card increases administration costs and the risk to the County of potentialunauthorized purchases As such policies and procedure should require periodicassessmentanddeactivation ofcardsthatno longerhaveajustifiablebusinesspurpose
The Audit Guide (The Auditing amp Investigating the Internal Control of Government Purchase Card Programs) issued by the US General Accounting Office recommends that purchasecards should be issued in controlled limited quantities and only to employees with legitimate needs to have the cards Single purchase and monthly credit limits should be established basedonthe expected monthlypurchasesofthecardholder
Recommendation No 7Purchasing should monitor card usage and in consultation with the user departments deactivate infrequently used cards that no longer have a business purpose Individual and monthlyspendlimitsshouldalso bereviewedandadjustedbased onneed
CAL‐CardProgram CountywideAudit AuditNo3108 Page22
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Observation 5 Establish Proper Spend Limits and Commodity Ranges
A The CAL‐Card Program Expansion One of the most critical steps in establishing a successful purchasing card program is toestablishwell‐thought‐outparameterssuchasallowablecommodityandspendlimitsTheobjective is to maximize the benefits of purchasing cards such as expedient procurementandreducedtransactioncostwhilemaintainingrisksatanacceptablelevel
The cardholder single transaction limit of $2500 has not been changed since 2000 whenthe CAL‐Card program was first implemented Given that thirteen years have elapsed this limitshould bere‐evaluated
The increase of the CAL‐Card single transaction limit to $5000 will result in approximately300 additional transactions per year with the total dollar value of approximately $11million eligible for the CAL‐Card program Our analysis is based on the eight expense types listedbelow thatweconsidered mostsuitedforuseoftheCAL‐Card
EXPENSES ($2501 ‐$5000) QUALIFY FOR CAL‐CARD USAGE (FY1112) Expense Type Total Amount of Trans Utilities 570242 160SmallToolsInstruments 205666 56OfficeSupplies 128225 35RentLeaseEquipment 57924 16BooksPeriodicals 24861 8Equipment 22057 6Membership 31215 9MedicalSupplies 21083 7
Total Expenses May Qualify for CAL‐Card $1061274 297 Source Auditor‐generated workpaper from data recorded in EZFAMIS
Spend limits and commodity‐type allowance ranges should be reviewed and adjusted on a periodic basis to ensure that the purchasing parameters are set to most closely align with theneedsof theuserdepartmentsandthe County
B Effective Use of ResourcesBuyers play a critical role in the purchasing process They provide assurance that theproducts or services acquired meet the user departmentsrsquo needs at the lowest possiblecost They are responsible for processing purchase requisitions following up on purchase orders to ensure that items are delivered as ordered and resolving problems in billing and payment According to Purchasing it takes on average four hours per purchase for the Buyertoprovidethislevelofsupport
By shifting low dollar value transactions where the Buyers are least likely to add value from the purchase order process to alternatives such as delegated purchasing or use of the CAL‐Card it allows Buyers to focus on higher dollar value transactions analysis and other activitiesthatwouldaddgreater value
CAL‐CardProgram CountywideAudit AuditNo3108 Page23
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
If the current CAL‐Card spend limit is increased the volume of purchase orders would be reduced allowing Buyers to focus more of their effort on critical areas such as contract negotiation reviewofbidsandpreparationof specifications
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card parameters to better address the Countyrsquoscurrent needs in consultation with the user departments The user departments should be encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
CAL‐CardProgram CountywideAudit AuditNo3108 Page24
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Observation 6 Proactively Manage the CAL‐Card Program to Achieve Cost Savings
While our primary focus was to determine if the CAL‐Card purchases were in compliance with the proceduresweanalyzedinformation such asthe CAL‐Cardpurchaseactivitiesand vendor payment history and conducted best practices research to identify ways to increase processefficiencies
A Perform Spend Analysis to Support Countywide Purchasing StrategiesTo develop an effective purchasing strategy it is important to understand the organizationrsquos spending profile The services and supplies purchases the frequency anddollar value of such purchases and the vendors utilized are the primary data necessary toestablishthespending profile
Using the information listed above Purchasing can better negotiate discounts and other terms explore potential purchasing partners and refine other areas of its overall purchasingstrategy
We gathered and assessed the CAL‐Card transactions from FY1011 to FY1112 to identifytop vendors(exceptforairlinesand hotels) who currently do not have agreements with the County
TOP VENDORS (NO CURRENT AGREEMENT WITH COUNTY) Vendor Name Category FY1112 FY1011 Current Status Amazon BookStore 69735 42322 NoAgreement YSIIncorporated IndustrialSupplies 18548 13306 NoAgreement HelenaChemicalCompany IndustrialSupplies 18104 7737 NoAgreement Wal‐MartWalmartcom DiscountStore 13827 8889 LimitedtoHealth Services SonicNet Inc ComputerSolutions 11056 10555 Agreement Expired Ulias Delicatessen Food 10806 10084 NoAgreement BasicChemicalSolutions IndustrialSupplies 8905 18957 AgreementExpired AirGas Fuel 8797 7750 NoAgreement OfficeDepot OfficeSupplies 8548 8768 Agreement Expired American HighwayProducts Industrial Supplies 8230 9402 NoAgreement DW Pumps LLC Equipment and Tool 7327 6782 Agreement Expired DiscountOfficeItem OfficeSupplies 5374 8169 NoAgreement
Total $189257 $152721 Total CAL‐Card Charges $2249016 $1924820
8 8 Source Auditor‐generated workpaper from data provided by US Bank
We also identified airline and hotel vendors that make up a material portion of travelexpense
CAL‐CardProgram CountywideAudit AuditNo3108 Page25
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
TOP AIRLINES amp HOTELS (FY1112) Vendor Amount
Southwest 53126 UnitedAirlines 40456 Alaska Airlines 24133 Delta 19467 Hilton 31053 Hyatt 29898 Marriott 14375 HolidayInns 12527 Sheraton 12479 Portola HotelandSPA 11689 DoubletreeHotels 10736
Total $259939 Total CAL‐Card Charges $2249016
12 Source Auditor‐generated workpaper from data provided by US Bank
A spend analysis such as above should be periodically performed to be incorporated with theoverallpurchasingstrategy
B Require Departments to Purchase through BPO or Group Buying Contracts Where Appropriate
TheCounty hasentered into several blanketpurchaseorder(BPO)agreementswhereprice and other terms have been pre‐negotiated The County also participates in the Western State Contracting Alliance (WSCA) agreement formed in 1993 which allows participating government entities to join together in cooperative multi‐State contracting BPOs are established by Purchasing to cover commonly used items Examples of items covered by BPOagreementinclude
OfficeSupplies ElectricalandIndustrialSupplies HardwareandSmallTools EquipmentRental
Currently the County does not have a process in place to ensure that potential BPO and WSCA eligible CAL‐Card transactions are identified and purchased under the terms of appropriatecontracts
Thefollowingprovides afurther explanation oftheobservation shownabove
BPO Transactions Charged to the CAL‐Card Program We found several instances where BPO eligible items were charged to the CAL‐Card program For example the user departments used the CAL‐Card to pay for office supplies of $9899 that could have been purchased online under the terms of an existing BPO agreement with discounted price According to Purchasing office supplies purchasedonline aredeliveredwithin1‐2businessdays
CAL‐CardProgram CountywideAudit AuditNo3108 Page26
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
ThefollowingshowstheBPOvendorswiththemostCAL‐Cardchargesin FY1112
CAL‐CARD CHARGES BY BPO VENDOR (FY1112)
BPO Vendor Authorized Dept BPO Effective Date CAL‐Card Charges Staples UmbrellaMasterControl 12109‐113013 HomeDepot UmbrellaMasterControl 22811‐ 22814 TropeGroup UmbrellaMasterControl 111811‐111713 USABlueBook WaterAgency 3112‐ 22814 Jim‐In‐IRentalsInc WaterAgency 121009‐ 12913 MaltbyElectronicSupply SheriffsOffice 4111‐ 33114
989978987596637024841824
Total $36070 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
WSCA Transactions Charged to CAL‐Card ProgramWe noted CAL‐Card purchases totaling $70202 from vendors who are covered under the WSCA agreement These vendors are obligated to abide by the terms of the State negotiated masterpriceagreement
WSCA AGREEMENT (FY1112) Vendor CAL‐Card Charges DMIDELL K‐12GOVTTotal 40948 DMIDELL BUSONLINETotal 14517 DMIDELL SMBUSTotal 2400DELL SALESampSERVICETotal 1739
DELL Total $59604 CDW Government Total $10598
Grand Total $70202 Source Auditor‐generated workpaper from data provided by US Bank amp Purchasing
C Maximize the Use of the CAL‐Card to Achieve High Level of Efficiency To maximize the benefits of a purchasing card program it is necessary to monitor and increase the rate of small dollar value transactions that are processed through the purchasingcardsThe Countycurrentlydoes notperform suchanalysisandfollow‐ups
To determine the potential for increasing the use of the CAL‐Card we captured all expenseitems under $500 processed by AP during FY1112 and estimated the cost savings thatwouldhaveresultediftheCAL‐Cardwasused
Our analysis indicates that 1275 purchase transactions could have been potentially paidthrough the CAL‐Card program We estimate approximately $20000 would have beensavedinwarrantproductioncost andapproximately$1500earnedinrebatefrom theCAL‐Cardprogram
CAL‐CardProgram CountywideAudit AuditNo3108 Page27
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
SNAPSHOT OF POTENTIAL AREAS FOR CAL‐CARD PROGRAM EXPANSION a b c d e
Vendor Expense Type of Trans
Total Expense
Aver Exp Per Trans (ba)
of Warrant Issued
Cost of Producing Warrant (d x $2717)
f ^Potential Rebate
Earned via CAL‐Card
ATampT Telephone 175 27407 157 138 3749 Amazoncom Office Supplies 140 19972 143 16 435 FederalExpress Postage 320 19548 61 225 6113 GoodToGo Military Uniform 74 18083 244 27 734 EnPointe SmallTools 95 16110 170 43 1168 VerizonWireless Telephone 155 15582 101 136 3695 SaveMart FoodHousehold 98 14828 151 72 1956 Safeway Inc FoodHousehold 97 9706 100 34 924 Sebastopol Hardware Equipment 121 5676 47 39 1060
22518512325419014721325257
Total 1275 $146911 $115 730 $19834 $1457 Source Auditor‐generated workpaper from data recorded in EZFAMIS Per Controllers Office the average cost of producing County warrant is $2717 ^ Per Service Agreement with US Bank rebates are earned from both of transactions (a) and volume of sales (b)
D Explore the Possibilities of Partnering with Other Card ProvidersCurrently cardholders prepare and submit the Monthly CAL‐Card Purchase Report to AOrsquosfor review After AOrsquos approval the ACTTC AP section manually enters the data to theaccounting system to update the Countyrsquos accounting records and process payments These procedures are labor intensive error prone and result in generation and maintenanceofnumerouspaperrecords
Purchase card providers in the current market can fully integrate their system with an organizationrsquos existing general ledger or accounting system to automate mapping oftransactions to cost center The system also allows online access for review and approvalfunctionsCurrentlyUSBank doesnotprovidethesefeaturestotheCounty
The County has utilized the services of US Bank through the State negotiated Master Services Agreement since 2006 Partnership with other providers should be explored forbettertermsconditionsandfeaturessuchasabove
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County could potentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing should identify items covered under BPO and WSCA agreements to provide the user departments with such information BPO and WSCA eligible transactions charged totheCAL‐Cardprogramshouldbemonitored andreportedtodepartmentmanagement
CAL‐CardProgram CountywideAudit AuditNo3108 Page28
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Opportunities for Improvement Observations and Recommendations
Recommendation No 11Purchasing should explore means for obtaining discounts for CAL‐Card purchases coveredunder the County BPO and WSCA agreements Arrangements could be made with respective vendors to allow users to identify appropriate agreements at the time of the purchases to receive discounts An easy to use method for identifying items covered under these agreements should be provided to the users An ongoing monitoring of BPO and WSCA eligible transactions will ensure continued effectiveness of the procedures listed above
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactions processed throughAP and work with the user departments to expand the CAL‐Card use where appropriateOpportunities for process efficiencies such as ldquoghostrdquo card usage for the payment ofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payable andgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to combine compliancediscounts and strategic buying that balance efficiency with control to optimize operations(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page29
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Appendix A Best Practices for Purchase Card Program Management
The US General Services Administration (GSA) developed a guide to best practices forpurchase program management implemented by other agencies The purpose of the guideis to promote and enhance the purchase program management by establishing policies andprocedures providing responsible oversight and ensuring enforcement when there areviolationsofcarduserulesThefollowingarebestpractices suggestedbyGAS
Pre‐Issuance Perform a risk assessment toidentify and address the risk the agency facesin managing
itscharge cardprogram
Develop appropriate policies and procedures for the charge card program anddisseminate those policies and control procedures to program officials and users in the mosteffectivemanner
Selectappropriatepersonneltomanageand administertheprogram
Create and implement an appropriate training program for program managers and users
Issuance and Maintenance Set reasonable single purchase and monthly limits and apply merchant category code
restrictions
Provide instruction on user and approver responsibilities and written acknowledgementssigned byusersandapprovers
Establishclearguidelinesontheappropriateuseofpurchasecards
Develop procedures for AOs who can determine proper transactions and act independently
Performregularreviewsofusagetoascertainifcardis needed
Deactivate cardsthat areusedinfrequently
Usedatawarehousing toidentify purchasingtrends
Enforcement Involveagencymanagersandsupervisorwhenproblemsarise
Deactivate suspend or cancel accounts that are under review for questionable activities
CAL‐CardProgram CountywideAudit AuditNo3108 Page30
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Appendix B Best Practices for Selecting a Purchase Card Provider
Research 1The Government Finance Officers Association (GFOA) a group with the mission ofenhancing and promoting the professional management of government develops bestpractices for government GFOA recommends a competitive process should be used toselect a purchase card provider Consideration should be given to vendors who can provide
Automated approval and reconciliation software that provides for the ability to integrateto theentityrsquos accounting recordsin a timelyfashion
Abroadselectionof reportsoradhocreportingability
Provisionsforhanding questioned itemsandchargeback
Training programs to facilitate usersrsquo understanding of policies and procedures to assuremaximumusagewithinproperguidelines
Guidance useful tools and resources enabling administrators to effectively manage and controlthe program
Favorablerebaterateswhenthechargesare paidonan expeditedbasis
Research 2The GSA SmartPay program is the largest charge card program in the world serving more than 350 federal agencies organizations and Native American tribal governments During the annual GSA SmartPay conference purchase card best practices were presented The followingarekeyservices offered byitsprovider
Performindependent validationoftopvendor analysis
Identifyprospective strategicbuyingpartners
Identify vendorsreceivingcheckswhoacceptcardsforpayment
AutomateaccountspayableandGLinterface
Develop communication plan to shift payments from paper checks to purchase cards whereappropriate
Investigate opportunitiesforprogramexpansion
CAL‐CardProgram CountywideAudit AuditNo3108 Page31
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
TargetGroup
TheNatureofRisk
Appendix C List of Recommendations
Recommendation No 1General Services Accounting shouldimplementaframeworkformisuseofcardsandassureconsistent and prompt application of disciplinary and administ ive penalties countywide A policy should be developed to include deactivating suspendin
ratg or cancelling accounts of
repeat violators Policy is currently beingdevelopedthatwould address misuse of cards per individual
Recommendation No 2General Services Accounting should set
als expecta s and establish accountability forclear tion
approving officials Approving offici should be formally appointed through acknowledgment forms which outline their basic responsibilities and duties and emphasizethecriticalfunctiontheywillberesponsiblefor
Recommendation No 3Ge eral Services Accounting should provide resources and tools to approving officials to idenntify and correct a variety of issues including unallowable purchases or other misuse of
cards A checklist for identifying violations of policies and procedures would be an example
Recommendation No 4General Servi
hces A
AcLcoCunting and ACTTC should
Lc llaborate to execute periodic performanc
reviews o t e C ‐ h ard poli iolations identf ard program T e CA ‐Co
cy v ified relevante
statisticaldataandotherinformationshould besummarizedand reportedtomanagement
Recommendation 5The County should
No re‐assess its employee meal reimbursements policies and better define
allowable practices and documentation ndards (eg itemized receipts) A review should be per ormed per i i all i sem ent rates ad usted as necessary to better f od c y and re mbur
sta j align
with thebactual cost CAL‐Card me al purchases that do not meet the County uirements
dedreq
should e considered unallowable after adequate training has been provi to the CAL‐Cardusers andapprovingofficials
Recommendation No 6ACTTC should develop a risk‐based audit approach for the CAL‐Card review process to effectively target potential problem areas Examples of au dit sample criteria are listed below butnotlimitedto
First‐TimeUserDepartment Head
TopSpender
HigRepeatViolators
h Risk Items
TheCardholderTheApprovingO
maynotfufficialisunder
llyunderstandtheprohishersupervision
TheCardholdermaypotentia cedures
llybe misusing thecard
ITtemseaheCardholder
silyconvertibletoprivatmayhavetheten
eusesuchadencytoviolat
sintownmealsetheprocedures
Auditing a sample of selected ansactions based on risk anddco pled with a policy to
deactivate suspend or cancel actrcounts of repeat violators woul b
ue a more cost effective
alternative tothecurrentpractice
CAL‐CardProgram CountywideAudit AuditNo3108 Page32
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
RecommendationNo7
Appendix C List of Recommendations
General Services Accountin hould onitor card usage and in c nsulta ion with the user departments deactivate equently
m sed cards that no longer h
o v a b
t usi p s infr
g s u a e ness pur o e
Individualandmonthlyspendlimitsshouldalsobereviewedand adjustedbased onneed
Recommendation No 8Purchasing should re‐evaluate the CAL‐Card arameters to better address the Countyrsquos current needs in consultation with the user dep
partments The user departments should be
encouraged tousethe CAL‐Card forpurchasesthatmeet theCAL‐Cardrequirements
Recommendation No 9Purchasing should utilize CAL‐Card purchase data to identify areas where County couldpotentiallynegotiate discountresultingfromroutineandorlargevolumeofacquisition
Recommendation No 10Purchasing hould identify items covered under Blanket Purchase Order (BPO) and Western States Contr
sacting Alliance (WSCA) agreements to provide the er departments with such
information BPO a nd W ligibl i c e CAL‐Card program should SCA e e transact ons harged to thus
bemonitoredand reportedtodepartmentmanagement
Recommendation No 11Purchasing should exploremeans for obtaining discounts for CAL‐Card purchases covered under the County BPO and WSCA agreements Arrangements could be made with respective vendors allow users identify appropriate agreements at th t me oe i f
A to the pur chases
receive dtoiscounts easy to use method for identifying items covered under thes
toe
agreements should benprovided to the users An ongoing monitoring of BPO and WSCA
eligibletransactionswillensure continued effectiveness oftheprocedureslistedabove
Recommendation No 12Purchasing should periodically identify CAL‐Card eligible transactio processed through Accounts Payable and wo k with the user departments to xpand the
nsCAL‐Card use where
appropriate Opportunitr
f ies suche
ldquog ost rdquo card usage ies or process efficienc as h for the paymentofmonthlyorperiodicchargesshouldbeinvestigated
Recommendation No 13Purchasingshould explore features such as automated accounts payableandgeneral ledger interface that purchasing card vendors currently provide Purchasing should establish standards of evaluating and selecting a provider who is able to ombine compliance discounts and strategic buying that balance efficiency with control t
co optimize operations
(SeeAppendixBforexamplesofbestpractices)
CAL‐CardProgram CountywideAudit AuditNo3108 Page33
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
Page 34
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 36
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
APPENDIX DCOUNTYCOUNTY OFOF SONOMASONOMA
PURCHASINGPURCHASING DIVISIONDIVISION GENERA CESGENERA LL SERVSERV IICESDEPARTMENTDEPARTMENT
DRIVE SUI23002300 COUNCOUN TTYY CENCENTTERER DRIVE SUITETE A208A208 LIFORNIASANTASANTA ROSAROSA CACALI FORNIA 9540395403
(707)(707) 565-2433565-2433
JOSEJOSE OBREGONOBREGON LINDALI NDA RODECAPROD ECAP CPPBCPPB GENERALGENERAL SERVSERVIICESCES DIRECTORDIRECTOR PUPURRCCHHASAS IINGNG AGENTAGENT
(707) S6S-2977(707)565-2977
Date Date AprilApril 2323 20142014
TToo KKanchaanchan n CharanCharan Audit Audit ManageManagerr yen yenFrom From eneraleneral ServicesServices andand DonnDonnaa DunkDunk AssistantAssistant AuditorAuditor ControllerController
ReRe RespoRespo ee toto AuditAudit ofof CountyCounty ofof SonomaSonoma CAL-CardCAL-Card ProgramProgram
WeWe would would likelike toto thankthank thethe OfficeOffice ofof thethe AuditorAuditor for for aa veryvery thoroughthorough auditaudit ofof thethe CAL-CardCAL-Card ProgramProgram TheThe auditaudit waswas conductedconducted professionallyprofessionally andand willwill bebe aa usefuluseful documentdocument forfor continuouscontinuous
improvementimprovement
GeneralGeneral Services Services hashas reviewedreviewed andand evaluatedevaluated thethe auditsaudits recommendationsrecommendations andand wewe areare pleasedpleased toto
provideprovide youyou withwith ourour formal formal responsresponse e Where Where thethe responseresponse incorporatesincorporates commentscomments fromfrom multiple multipledepartmentsdepartments thosethose departmentsdepartments areare identifiedidentified
WithWith respect respect toto the the AuditAudit RecommendationsRecommendations
RecoRecommmendationmendation No1No1 GeneGeneral ral ServicesServices AccountingAccounting shouldshould implementimplement aa framework framework forfor misusemisuse ofof cardscards andand assureassure consiconsisstenttent Jnd Jnd promptprompt applicationapplication ofof disciplinarydisciplinary andand administrativeadministrative penalties penalties countywidecountywide A A policypolicy shouldshould bebe developeddeveloped toto includeinclude deactivating deactivating suspending suspending oror cancellingcancelling accountsaccounts ofof repeatrepeat violators violators PolicyPolicy isis currentlycurrently beingbeing developeddeveloped thatthat wouldwould addressaddress misusemisuse ofof cardscardsperper individualindividual
General General ServServices ices ResponseResponse No No1 1
GeneralGeneral ServicesServices AccountingAccounting andand PurchasingPurchasing withwith inputinput fromfrom AuditorAuditor ControllerController TreasurerTreasurer TaxTax CollectorCollector (ACTTC)(ACTTC) areare reviewingreviewing thethe currentcurrent CAL-CardCAL-Card guidelinesguidelines forfor areasareas toto strengthenstrengthen thethe programprogram perper youryour recommendationrecommendation TheThe currentcurrent administrativeadministrative PolicyPolicy forfor PurchasingPurchasing isis alsoalso beingbeing reviewedreviewed toto determinedetermine whatwhat updatesupdates areare requiredrequired toto addressaddress thethe itemsitems recommendedrecommended aboveabove AllAll proposedproposed actionsactions relativerelative toto applicationapplication ofof disciplinediscipline andorandor administrativeadministrative sanctionssanctions willwill be be vettedvetted throughthrough HumanHuman ResourcesResources andand thethe CountyCounty Administrators Administrators OfficeOffice accordinglyaccordingly
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
Page 35
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
APPENDIX D
RecommendationRecommendation No No2 2GGeneenerralal SerServvices ices AAcccoun countt inging sshhooululdd sset et clcleear ar eexpxpecta ectatiotionsns and and eestastablish blish accountabaccountability ility forfo r
approvingapproving officials officials ApprovingApproving offiofficialcials s shouldshould bbee formallyformally appointedappointed throughthrough acknowledgmentacknowledgment formsforms whichwhich outlineoutline theirtheir basicbasic responsibilitiesresponsibilities andand dutiesduties andand
emphasizeemphasize thethe criticalcritical functionfunction thatthat theythey willwill bebe responsibleresponsible forfor
GeneralGeneral ServicesServices ResponseResponse No No2 2
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC isis developingdeveloping expectationsexpectations whichwhich willwill bbe e clearclearly ly communcommunicated icated to to approvingapproving offiofficicialalss and and anan acknowledgmentacknowledgment formform willwill bebe
crcreeatateed d andand ddiiststrriibbuutedted pperer thethe rrecommecommeenndatidatioon n aaboboveve GeGenenerraall Service Servicess AAcccounticountinngg willwillapplyapply thethe newnew acknowledgement acknowledgement form form reretroactivelytroactively andand toto newlynewly assignedassigned approvingapproving
officialsofficials (See(See draftdraft approapprovingving officialofficial acknowledgementacknowledgement formform attached)attached)
RecomRecommmendationendation NoNo 33
GeneralGeneral ServicesServices AccountingAccounting shouldshould provideprovide resourcesresources andand toolstools toto approvingapproving officialsofficials toto
identifyidentify andand correctcorrect aa varietyvariety ofof issuesissues includingincluding unallowableunallowable purchasespurchases oror otherother misusemisuse ofof cardscards AA checklistchecklist forfor identifyingidentifying violationsviolations ofof policiespolicies andand proceduresprocedures wouldwould bebe anan exampleexample
GGeneneerral al SeSerrvivices ces RRespoesponnsese NNoo 33
GeneralGeneral ServicesServices AccountingAccounting withwith inputinput fromfrom ACTTCACTTC willwill developdevelop aa checkcheck listlist perper thethe recommendationrecommendation aboveabove TheThe checklistchecklist willwill notnot onlyonly bebe mademade availableavailable toto approvingapproving officialsofficials butbut willwill bebe mademade partpart ofof thethe CALCAL--CardCard useruser trainingtraining programprogram materialmaterial (See(See samplesample checklistchecklist attached)attached)
RecoRecommemmenndatdation ion No No4 4
GeneralGeneral ServicesServices AccountingAccounting andand ACTTCACTTC shouldshould collaboratecollaborate toto executeexecute periodicperiodic performanceperformance reviewsreviews ofof thethe CAL-CardCAL-Card programprogram TheThe CAL-CardCAL-Card policypolicy violationsviolations identifiedidentified relevantrelevant statisticalstatistical datadata andand otherother informationinformation shouldshould bebe summarizedsummarized andand reportedreported toto
managementmanagement
GeGenneraerall ServicesServices RespoResponnsese NoNo 44
GeneralGeneral ServicesServices AccountingAccounting willwill partnerpartner withwith thethe ACTTCACTTC andand useuse reportingreporting toolstools fromfrom thethe newnew EFSEFS SystemSystem toto provideprovide performanceperformance reviewsreviews thatthat willwill bebe communicatedcommunicated annuallyannually toto DepartmentDepartment HeadsHeads TheThe County County AdministratorsAdministrators officeoffice willwill bebe askedasked toto establishestablish thethe annualannual
listlist ofof departmentsdepartments thatthat willwill bebe performanceperformance reviewedreviewed inin anyany setset yearyear
CAL-Card Program Countywide Audits Audit No 3108
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Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
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APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
Recommeendation ndation NoNo5 5
TThhe e CoCouunty nty sshouhoulld d re-are-asssseesss s iitts s ememppllooyeyee e mmeaeal l reimbursreimburseementments s polipolicies cies aand nd bebettetter r ddefinefine e allowable allowable practices practices and and documentation documentation standards standards (eg (eg itemized itemized receipts) receipts) A A review review should should be be performed performed periodically periodically and and reimbursement reimbursement rates rates adjusted adjusted as as necessary necessary to to better better align align with with the the actual actual cost cost CAL-Card CAL-Card meal meal purchases purchases that that do do not not meet meet the the Countys Countys requirements requirements should should be be considered considered unallowable unallowable after after adequate adequate training training has has been been provided provided to to the the CALCALshyshyCard Card users users and and approving approving officials officials
General General Services Services Response Response No5 No 5
General General Services Services will will partner partner with with the the CAO CAO to to determine determine the the process process to to develop develop recommended recommended changes changes to to the the meal meal reimbursement reimbursement polpolicy icy to to adjust adjust allowable allowable reimbursement reimbursement to to reflect reflect current current costs costs and and submit submit revisions revisions to to the the County County Administrators Administrators office office for for review review and and approval approval Relevant Relevant data data will will be be included included to to support support recommendations recommendations
Current Current monitoring monitoring and and review review process process includes includes potential potential rejection rejection of of submitted submitted reimbursement reimbursement requests requests if if county county requirements requirements are are not not met met
Recommendation Recommendation No No6 6
ACTTC ACTTC should should develop develop a a risk-based risk-based audit audit approach approach for for the the CAL-Card CAL-Card review review process process to to effectively effectively target target potential potential problem problem areas areas Examples Examples of of audit audit sample sample criteria criteria are are listed listed below below but but not not limited limited to to
Target Target Group Group The The Nature Nature of of Risk Risk
Department Department Head Head The The Approving Approving official official is is under under hisher hisher supervision supervision
First-Time First-Time User User The The Cardholder Cardholder may may not not fully fully understand understand the the procedures procedures
Top Top Spender Spender The The Cardholder Cardholder may may potentially potentially be be misusing misusing the the card card
Repeat Repeat Violators Violators
High High Risk Risk Items Items
The The Cardholder Cardholder may may have have the the tendency tendency to to violate violate the the procedures procedures
Items easily convertible to private use such as in-town meals
Auditing Auditing a a sample sample of of transactions transactions selected selected based based on on risk risk and and coupled coupled with with a a policy policy to to deactivate deactivate suspend suspend or or cancel cancel accounts accounts of of repeat repeat violators violators would would be be a a more more cost cost effective effective alternative alternative to to the the current current practice
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
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APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
APPENDIX D
GeneralGeneral ServicesServices ResponseResponse No6 No 6
TheThe ACTTCACTTC agreesagrees withwith thisthis recommendationrecommendation andand willwill implementimplement aa risk-basedrisk-based auditaudit
approachapproach forfor thethe CAL-CardCAL-Card reviewreview processprocess effectiveeffective JulyJuly 11 20152015 providedprovided thethe recommendations recommendations notednoted inin thisthis report report areare implementedimplemented inin otherother areas areas SeeSee responseresponse totoRecommendationRecommendation NoNo 11
RecommendationRecommendation NoNo 7 7
GeneralGeneral ServicesServices AccountingAccounting shouldshould monitormonitor card card usageusage andand inin consultationconsultation withwith thethe useruser departmentsdepartments deactivatedeactivate infrequeninfrequentlytly usedused cardscards thatthat nono longerlonger havehave aa businessbusiness purposepurpose
IndIndividualividual andand monthlymonthly spendspend limitslimits should should alsoalso bebe reviewedreviewed andand adjustedadjusted basedbased onon needneed
GeneralGeneral ServicesServices ResponseResponse No7 No 7
GeneralGeneral ServicesServices AccountingAccounting willwill examineexamine thethe datadata toto determinedetermine thethe risksrisks ofof havinghaving infrequentlyinfrequently usedused cardscards WillWill provideprovide usageusage byby cardholdercardholder toto includeinclude spendspend limitslimits inin thethe periodicperiodic reportreport sentsent toto managementmanagement identifiedidentified inin GeneralGeneral ServicesServices Response Response No No4 4 InactiveInactive cardscards willwill bebe canceledcanceled uponupon notificationnotification toto holdingholding departmentdepartment andand addressedaddressed inin thethe CALCAL -shy
CardCard trainingtraining
RecommendationRecommendation No No8 8
Purchasing Purchasing shouldshould re-evare-evaluate luate thethe CAL-Card CAL-Card parametersparameters toto betterbetter addressaddress thethe CountysCountys current current needsneeds inin consultationconsultation with with thethe useruser departmentsdepartments TheThe useruser departmentsdepartments shouldshould bebe encouragedencouraged toto useuse thethe CAL-CardCAL-Card forfor purchasespurchases thatthat meetmeet thethe CAL-CardCAL-Card requirementsrequirements
GeneralGeneral ServicesServices ResponseResponse No8 No 8
GeneralGeneral ServicesServices Purchasing Purchasing isis currently currently reviewingreviewing thethe impactimpact ofof increasingincreasing thethe CAL-Card CAL-Cardlimitlimit toto betterbetter alignalign withwith departmentdepartment needsneeds PurchasingPurchasing isis movingmoving forwardforward withwith aa recommendationrecommendation toto increaseincrease thethe limitlimit asas aa meansmeans ofof pursuingpursuing betterbetter pricingpricing maximizingmaximizing
rebatesrebates andand streamlining streamlining procurement procurement effortsefforts
RecommendationRecommendation No9No 9
PurchasingPurchasing shouldshould utilizeutilize CALCAL--CardCard purchasepurchase datadata toto identifyidentify areasareas wherewhere CountyCounty couldcould potentiallypotentially negotiatenegotiate discountdiscount resultingresulting fromfrom routineroutine andorandor largelarge volumevolume ofof acquisitionacquisition
GeneralGeneral ServicesServices ResponseResponse No9 No 9
EffortsEfforts associatedassociated withwith responseresponse No No 99 willwill bebe linked linked withwith effortsefforts toto periodicallyperiodically reviewreview CAL-CardCAL-Card parametersparameters (recommendation(recommendation NoNo 8)8)
CAL-Card Program Countywide Audits Audit No 3108
Page 37
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
APPENDIX D
RecommendationRecommendation NoNo1010
PPuurrchaschasiing ng shoshouulldd identify identify itite emmss ccoovered vered undundeerr BlaBlankenket t PurchasePurchase OrdOrdeerr ((BBPO)PO) andand WesternWestern StatesStates ContractingContracting AllianceAlliance (WSCA)(WSCA) agreementsagreements toto provideprovide thethe useruser departmentsdepartments withwith suchsuch informationinformation BPO BPO andand WSCAWSCA eligibleeligible transactionstransactions chargedcharged toto thethe CAL-Card CAL-Card
programprogram shouldshould bebe monitoredmonitored andand reportedreported toto department department managementmanagement
GeneralGeneral ServicesServices ResponseResponse NoNo 1010
GeneraGeneral l Services Services AccountinAccounting g aand nd PurPurchasing chasing willwill partnpartner er wwith ith ACTTCACTTC toto provideprovide aannual nnualpeperrformance formance rerevvieiewws s asas per per rrecommendation ecommendation NoNo4 4 IIntrinsicntrinsic iinn ththat at re revvieieww aandnd rreepoportrt ww illill bebe datadata onon BPOBPO andand otherother mastermaster agreementagreement purchasespurchases
RecommendationRecommendation NoNo1111
PurchasingPurchasing shouldshould exploreexplore meansmeans forfor obtainingobtaining discountsdiscounts forfor CAL-CardCAL-Card purchasespurchases coveredcovered underunder the the CountyCounty BPOBPO andand WSCAWSCA agreementsagreements Arrangements Arrangements could could be be mademade withwith respectiverespective vendorsvendors toto allowallow usersusers toto identifyidentify appropriateappropriate agreementsagreements atat thethe timetime ofof thethe purchasespurchases toto receivereceive discountsdiscounts AnAn easyeasy toto useuse methodmethod for for identifyingidentifying itemsitems coveredcovered underunder thesethese agreementsagreements shouldshould bebe providedprovided toto thethe usersusers AnAn ongoingongoing monitoringmonitoring ofof BPOBPO andand WSCAWSCA eligibleeligible transactionstransactions willwill ensureensure continuedcontinued effectivenesseffectiveness ofof thethe proceduresprocedures listedlisted
aboveabove
GeneralGeneral ServicesServices ResponseResponse NoNo 1111
SeeSee ResponseResponse No9 No 9 andand NoNo 10 10 GeneralGeneral ServicesServices willwill monitormonitor CAL-CardCAL-Card purchasespurchases coveredcovered underunder BPOBPO oror WSCAWSCA agreementsagreements andand workwork withwith vendorsvendors toto obtainobtain discountsdiscounts providedprovided thethe needsneeds ofof thethe departmentdepartment cancan bebe holisticallyholistically metmet throughthrough thethe CAL-CardCAL-Card processprocess
RecommendationRecommendation NoNo1212
PurchasingPurchasing shouldshould periodicallyperiodically identifyidentify CAL-Card CAL-Card eligible eligible transactions transactions processedprocessed throughthrough AccountsAccounts PayablePayable andand workwork withwith thethe useruser departmentsdepartments toto expand expand the the CAL-CardCAL-Card useuse wherewhere appropriateappropriate Opportunities Opportunities for for process process efficiencies efficiencies such such as as ghost ghost card card usage usage for for thethepaymentpayment ofof monthly monthly oror periodicperiodic chargescharges shouldshould bebe investigatedinvestigated
General General ServicesServices ResponseResponse NoNo 1212
SeeSee ResponseResponse No No9 9 NoNo 1010 andand No No 1111 WithWith thethe implementationimplementation ofof thethe EFSEFS systemsystem General General
Services Services isis reviewingreviewing potentialpotential areasareas toto expandexpand thethe CAL-CardCAL-Card usageusage suchsuch asas BPOBPO agreementsagreements OtherOther opportunitiesopportunities willwill alsoalso bebe exploredexplored toto maximizemaximize purchasingpurchasing efficiencyefficiency suchsuch asas increasedincreased useuse ofof CAL-CardCAL-Card byby thethe BuyersBuyers forfor higherhigher dollardollar purchasespurchases whenwhen feasiblefeasible TheThe overalloverall goalgoal isis toto increaseincrease thethe useuse ofof CAL-CardCAL-Card purchasespurchases whilewhile increasingincreasing oversightoversight
andand authorityauthority toto exerciseexercise correctivecorrective actionsactions
CAL-Card Program Countywide Audits Audit No 3108
Page 38
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 39
RecommendationRecommendation NoNo 1313
PurchasingPurchasing shouldshould explore explore features features such such asas automatedautomated accountsaccounts payablepayable andand genergeneral al ledgerledger interfaceinterface thatthat purchasingpurchasing cardcard vendorsvendors currentlycurrently provideprovide PurchasingPurchasing shouldshould establishestablish standardsstandards ofof evaluatingevaluating andand selectingselecting aa providerprovider whowho isis ableable to to combinecombine compliancecompliance discountsdiscounts andand strategicstrategic buyingbuying thatthat balancebalance efficiency efficiency with with control control to to optimize optimize operationsoperations (See (See Appendix Appendix B B for for examples examples of of bestbest practices)practices)
GeneralGeneral ServicesServices Response Response NoNo 1313
TheThe currentcurrent systemsystem doesdoes notnot givegive us us sufficientsufficient vendorvendor detaildetail toto determinedetermine ourour potentialpotential toto maximizemaximize discountsdiscounts etcetc thusthus itit wouldwould notnot bebe costcost effectiveeffective atat thisthis timetime GeneralGeneral ServicesServices willwill re-evaluatere-evaluate andand exploreexplore thethe potentialpotential valuevalue inin evaluatingevaluating andand ratingrating providersproviders toto enhanceenhance programprogram efficiencyefficiency whenwhen wewe have have historicalhistorical data data fromfrom aa moremore effectiveeffective systemsystem
afterafter EFSEFS implementationimplementation
GeneralGeneral ServicesServices withwith inputinput fromfrom thethe AuditorsAuditors officeoffice hashas establishedestablished thethe attachedattached timelinestimelines to to completecomplete closeclose thethe recommendationsrecommendations inin conjunctionconjunction withwith thethe AuditorsAuditors OfficeOffice
review review andand approvalapproval
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation
APPENDIX D
CAL-Card Program Countywide Audits Audit No 3108
Page 40
AttachmentAttachment 11 DeliverablesTimelineDeliverablesTimeline RecommendationRecommendation DeliverableDeliverable OwnerOwner StatusStatus DateDate NoNo
StartStart EndEnd 11 ReviewReview andand recommendrecommend changeschanges toto GeneralGeneral ServicesServices InIn progressprogress 33143314 7151571515
CurrentCurrent PolicyPolicy AccountingPurchasingAccountingPurchasing
ACTTCACTTC
1212 UpdateUpdate CAL-CardCAL-Card PolicyPolicy toto maximizemaximize GeneralGeneral ServicesServices WithWith EFSEFS 6301563015 71157115
PurchasingPurchasing efficiencyefficiency AcctAcct PurchasingPurchasing ImplementationImplementation
33 DevelopDevelop ChecklistChecklist forfor ApprovingApproving GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
OfficialsOfficials AccountingAccountingACTTCACTTC
22 DevelopDevelop AcknowledgmentAcknowledgment FormForm forfor GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
ApprovingApproving officialsofficials AccountingAccounting
77 MonitorMonitor cardcard usageusage ampamp spendingspending GeneralGeneral ServicesServices On-goingOn-going need-need- 33143314 On-goingOn-going
limits limits ReviewReview ampamp adjustadjust basedbased onon AccountingAccounting basedbased
need need
22 UpdateUpdate CAL-CardCAL-Card TrainingTraining basedbased onon GeneralGeneral ServicesServices InIn progressprogress 33143314 CompleteComplete
AuditAudit ReportReport RecommendationsRecommendations AccountingAccounting
410410 DevelopDevelop DepartmentDepartment PerformancePerformance GeneralGeneral ServicesServices WithWith EFSEFS 7151471514 7301573015
ReportReport AccountingPurchasingAccountingPurchasing ImplementationImplementation
ACTTCACTTC
55 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices ReviewingReviewing andand 6301563015 7301573015
MealMeal ReimbursementReimbursement PolicyPolicy toto HRHR AccountingCAOAccountingCAO evaluatingevaluating
andand CALCAL CardCard ApprovingApproving OfficialsOfficials currentcurrent policypolicy
88 ReviewReview andand recommendrecommend updatesupdates toto GeneralGeneral ServicesServices InIn progressprogress 33143314 8301483014
thethe DelegatedDelegated PurchasingPurchasing AuthorityAuthority PurchasingPurchasing
LimitsLimits
891011891011 DevelopDevelop spendspend analysisanalysis tooltool toto GeneralGeneral ServicesServices NeedNeed datadata 7151471514 7301573015
identifyidentify CAL-CardCAL-Card expendituresexpenditures thatthat PurchasingPurchasing providedprovided byby EFSEFS
cancan bebe betterbetter leveragedleveraged ImplementationImplementation
66 ImplementImplement RiskRisk BasedBased AuditAudit ACTTCACTTC ReviewingReviewing andand 71157115 7301573015
ApproachApproach evaluatingevaluating
currentcurrent policypolicy
1313 EvaluateEvaluate ValueValue inin pursuingpursuing otherother GeneralGeneral ServicesServices NeedNeed data provideddata provided 7151471514 7301573015
procurementprocurement cardcard providersproviders andand
provideprovide recommendationrecommendation
Purchasing PurchaSing byEFSbyEFS
ImplementationImplementation