42
y Auditor‐Controller‐Treasurer‐Tax Collector Sonoma Count CALCard Program Countywide Audit July 1, 2010 – June 30, 2012 The policies, procedures, and internal controls over the CALCard program are generally adequately designed to detect unauthorized transactions. However, internal controls such as management oversight, authorization and documentation need to be strengthened to reduce the rate of unauthorized purchases. Our audit also indicates that the County can realize significant savings through proactively managing the program. Audit No: 3108 December 2013 Audit Chief: Kanchan K. Charan, CPA, CGMA Audit Supervisor: Damian Gonshorowski, CPA Auditor: Christina Liu, CPA

CAL Card Program Countywide - Sonoma County, California · [Type text] Auditor‐Controller‐Treasurer‐Tax Collector y Sonoma Count CAL‐Card Program Countywide Audit July 1,

Embed Size (px)

Citation preview

[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

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 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

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

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

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

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

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

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

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 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 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

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 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