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10/31/2002 Audit t- • AUDIT REPORT . • r -� • MONROE COUNTY BICYCLE AND PEDESTRIAN COORDINATOR/PLANNER GRANT October 31, 2002 - �OOUNTy �-• 4r 0 �C M UIQ OG +� 'A ; 00 o•''• ' -=_-- :.per° •'`•••t IP .....- OFCOUNT ,i\o a' yam • Prepared by: Internal Audit Department Clerk of the Circuit Court -- Danny L. Kolhage, Clerk Monroe County, Florida aS.y< • ,V: (. ffimFH 7 M _ ;Danny IL. 1&ortjage BRANCH OFFICE CLERK OF THE CIRCUIT COURT BRANCH OFFICE 3117 OVERSEAS HIGHWAY MONROE COUNTY 88820 OVERSEAS HIGHWAY MARATHON,FLORIDA 33050 500 WHITEHEAD STREET PLANTATION KEY,FLORIDA 33070 TEL.(305)289-6027 KEY WEST,FLORIDA 33040 TEL.(305)852-7145 FAX(305)289-1745 TEL.(305)292-3550 FAX(305)852-7146 FAX(305)295-3660 1 October 31, 2002 The Honorable Danny L. Kolhage Clerk of the Circuit Court • RE: Audit of Bicycle and Pedestrian Coordinator/Planner Grant Dear Mr. Kolhage: The Clerk's.Internal Audit Department has completed the audit of the Bicycle and Pedestrian Coordinator/Planner Grant. The purpose of the audit was to assess compliance with the applicable chapters of the Florida Statutes and the Monroe County Board of County Commissioners' policies, procedures, resolutions, ordinances and grant agreements. • We would like to thank the Growth Management Division for their cooperation while conducting g p the audit. Almost all local governments receive financial assistance from their state government and from the federal government. Federal and state grants of approximately$17,788,000 were received for. Monroe County residents during fiscal year 2001. Strong financial and internal controls are needed for the administration of all grant funding. Documentation should be prepared and maintained, such that all individuals involved have sufficient information and instructions with which to perform their respective functions. • -. The major risk to Monroe County is that once a grant is procured the potential for losing the funding is significantly increased without adequate monitoring and compliance with the agreed upon terms and conditions of the individual contract. The audit report and audit were completed with the assistance of Amy Heavilin. The accompanying audit report is provided for your information. Additional copies of the report will be provided upon your request. Sincerely, Sandra L. Mathena, CFE, CPA Director of Internal Audit Cc: Board of County Commissioners (5) James Roberts, County Administrator Timothy McGarry, Division Director of Growth Management Sheila Barker, Director of Administrative Services Sandee Carlile, Clerk's Finance Director Marva Green, External Auditor TABLE OF CONTENTS PAGE Objectives and Scope 1 II. Methodology 1-2 III. Background 3-5 IV. Conclusions 6 V. Audit Findings 7-14 A. Progress Report Filings 7 B. Reimbursement Requests 8 C. Official County Records 8-10 D. Timely Deposits 10 E. Close Out Grants 11 F. Forfeiture of Grants 12 G. Reconciliation and Monitoring 12 H. Initial Training of Grant Procedures 13-14 VI. Exhibits A. Memo from County Administrator to Clerk of Circuit Courts dated July 18, 1994 (four pages) B. Rejection Letters from the State (Contract#1 —Invoice#1 and Contract#2— Invoices #2 and#3) C. Monroe County Administrative Instruction#1013.1 (two pages) D. Memo from Growth Management to Finance dated January 13, 2002 (one page) E. Monroe County Administrative Instruction#4301.4 (three pages) F. Sample Data Entry Form for Grants—similar sheet currently used by Finance Department Only(one page) G. Summary of past 15 years of Management Comments received by external auditors (thirteen pages) VII. Auditee Responses =' AUDIT REPORT OF MONROE COUNTY BICYCLE AND PEDESTRIAN COORDINATOR/PLANNER GRANT _I I. OBJECTIVES AND SCOPE At the request of the Monroe County Clerk of the Circuit Court, the Internal Audit Department conducted an audit of the processes used in Grants Management Programs. As part of that audit, the auditor's discovered issues with two contracts under the Growth Management Division and began looking into the discrepancies. The audit objectives were: 1. to determine compliance with state and local laws, ordinances and contracts 2. to determine that policies and procedures properly document the system 3. to determine whether internal controls have been established and are being followed 4. to determine whether the results accomplish the goal of securing economy in expenditure of county funds II. METHODOLOGY A. The audit was conducted based on the Standards for the Professional Practice of Internal Auditing issued by the Institute of Internal Auditors. During the audit, the following personnel were interviewed to obtain information about the Policies and Procedures used in Grants Management: 1. Director of Administrative Services 2. OMB Budget Director 3. Growth Management's Coordinator Budget and Personnel 4. Growth Management's Bicycle and Pedestrian Coordinator/Planner 5. Clerk's Finance Director 6. Clerk's Finance Personnel (Grants Accountant) 7. F.D.O.T. Representative, Phil Steinmiller B. The Internal Audit Department examined the following documents: 1. Executed copy of the JPA/Contract(s) for the Bicycle and Pedestrian Coordinator/Planner Position (AG-851 and AI-931) between Monroe County and F. D.O.T. 2. Official County Records and supporting documentation 3. State Rules for Reimbursement of Class C Meals 4. PAF's (Payroll Adjustment Forms) 5. Monroe County "CAFR" and Single Audit Reports for Fiscal years ending September 30, 2000 and September 30, 2001 6. Monroe County Exhibit C "Sample Grants Application" 7. Monroe County Administrative Instruction#4301.4 8. Monroe County Administrative Instruction#1013.1 9. July 28, 1994 Memo from County Administrator to Clerk of Courts 1 10. All five (5) Reimbursement Requests (two under Contract AG-851 and three under Contract AI-931) 11. OMB Circular No. A-87 Attachment A and B 12. Memos/Correspondence between Growth Management, OMB and Finance 13. ACH/EFT (electronic fund transfers) policy and procedures for both State and Federal Agencies 14. Past 15 years of Management Comments and Responses from Annual Audit (CAFR)—specifically"grant management" comments 15. Data Entry Face Sheets used by Monroe County Finance Department and a sample face sheet used by Hernando County, Florida(Samples) 16. Hernando County Florida Procedures for Grant Activities (Sample) 17. Job Description for Bicycle and Pedestrian Coordinator/Planner 18. Florida Keys Overseas Heritage Trail Master Plan 19. Budget Transfer Requests 20. Monroe County BOCC Administrative Procedures 21. Preliminary Audit Report Monroe County — Grants Management Department issued on February 22, 1994 22. Monroe County Contract Review Sheets 23. Management Concepts Website and Materials issued at Seminars C. The Internal Audit Department reviewed contracts to ensure that all terms and conditions were being complied with as documented within the agreement. D. Monroe County Administrative Instructions #1013.1 and 4301.4 were reviewed to understand the Policy and Procedures to be followed by County Personnel for Cash Management and Grant Management. E. All five requests for reimbursement were analyzed to ensure that each has received appropriate supervisory approval and were submitted according to the terms and conditions outlined in the agreement. The auditor's verified that all supporting documentation was presented to ensure quick receipt of funds. In addition, the internal audit staff verified the requests for reimbursement matched the County's official report "Project Audit Trail" to ensure the data was complete, accurate and authorized. F. Memo(s) from Growth Management were reviewed to gain a better understanding of the procedures followed in the management of the two contracts (AG-851 and AI-931). They were reviewed to determine if any problems exist or have been reconciled. G. Management Comments for the past 15 years were reviewed to understand previous grant issues and to ensure policies and procedures were being implemented once adopted by the County. H. Memo(s) from the County Administrator were reviewed to gain an understanding of the County's position on the management comments on the annual financial statements. 2 III. BACKGROUND INFORMATION The audit team closely reviewed two contracts awarded and executed between Monroe County and the Florida Department of Transportation (F.D.O.T.) for the hiring and funding of a Bicycle and Pedestrian Coordinator/Planner for Monroe County. These two contracts fell under the supervision of the Growth Management Division. The Bicycle and Pedestrian Coordinator/Planner position has the key responsibilities to act as the Project Manager for the Overseas Heritage Trail Master Plan. The Overseas Heritage Trail is the first vision for a continuous trail the entire length of the Florida Keys. The concept was presented at the 1993 Florida Rails to Trails Conference in Dunedin, Florida and later a public workshop was held as part of an eco-tourism session at Hawk's Cay in Monroe County. The Monroe County Public Works Department was consistently providing bicycle paths and lanes throughout the Keys communities. In the year 2000, the Florida Department of Environmental Protection agreed to construct and manage the trail at the request of the Monroe County BOCC, in coordination with the F.D.O.T., District 6. The contracts entered into between the two parties are summarized below as Contract #1 and Contract#2. Contract#1: Joint Participation Agreement (JPA) between Monroe County and the F.D.O.T. was approved by the BOCC in April 1999 and executed on June 2, 1999. This contract is also known to County personnel as Contract #AG-851/GW9910. The purpose of the Contract was to create and fund a position known as the "Bicycle and Pedestrian Coordinator/Planner". i The original cost of the Project totaled $71,000; detailed as follows: $64,000 Salary and Benefits 1,500 Travel Expenses 5,500 General/Other Expenses The State's maximum participation is 80% or $57,000 with the County responsible for the difference. No front end funding is available. PAYMENTS: Payments will be made for actual costs incurred as of the date the invoice is submitted with the final payment due upon receipt of a final invoice. All costs shall be supported by properly executed payrolls, time records, invoices, contracts or vouchers. FINAL INVOICE: County will submit final invoice within 120 days after expiration of the agreement. Invoices submitted after 120 days WILL NOT BE PAID. Contract agreement terminates June 30, 2001 (120 days equates to October 31, 2001). EXPIRATIONS: County agrees to complete on or before June 30, 2001 unless a written extension of time period is requested by the County and approved by the District Secretary of District 6. 3 OTHER REQUIREMENTS: Exhibit A requires that the reports should be submitted quarterly along with supporting documentation to the State, which are acceptable. The submitted report will describe the work accomplished, which will adequately justify and support payment requested. Contract#2: Joint Participation Agreement (JPA) between Monroe County and the Florida D.O.T. was approved by the BOCC in October 2000 and effective on September 19, 2000. This contract was then amended and approved by the BOCC on June 21, 2001. The amendment authorized the County to encumber an additional $68,563. This Agreement is also known to personnel as Contract #AI-931/GW0101. The purpose of the Contract was to fund the second year for the position known as the "Bicycle and Pedestrian Coordinator/Planner". Amended Cost of the Project totaled$138,563; detailed as follows: $135,000 Salary and Benefits (original was $67,500) 3,563 Travel Expenses (original was $ 2,500) State's maximum participation is 100% or$138,563. No front end funding is available. PAYMENTS: Payments will be made for actual costs incurred as of the date the invoice is submitted with the final payment due upon receipt of a final invoice. All costs shall be supported by properly executed payrolls, time records, invoices, contracts or vouchers. FINAL INVOICE: County will submit final invoice within 120 days after expiration of 1 agreement. Invoices submitted after 120 days WILL NOT BE PAID. Contract agreement terminates September 30, 2002 (120 days equates to January 31, 2003). EXPIRATIONS: County agrees to complete on or before September 30, 2002 unless a written extension of time period is requested by the County and approved by the District Secretary of District 6. OTHER REQUIREMENTS: Exhibit C requires that the reports should be submitted quarterly along with supporting documentation to the State, which are acceptable. The report will describe work accomplished, which will adequately justify and support payment requested. 4 Monroe County Administrative Instruction#4301.4 (Exhibit E) details the procedures to follow when applying and receiving grants. Below is a summary outlining the process to be used by County personnel once a resolution is passed by the BOCC: o Submit a properly executed grant application and resolution to the grantor. o Upon notification that a grant has been awarded to the County, the requesting department will receive a contract outlining the contract requirements and any special conditions. The contract shall be reviewed by the County Attorney, Risk Management, Office of Management and Budget and the Division Director. o A resolution authorizing the acceptance of the grant and the execution of the grant agreement shall be reviewed by the County Attorney and then attached to the contract. The resolution and contract shall be scheduled on a subsequent BOCC agenda. o Once a contract is fully executed by both parties, a copy of the grant agreement is forwarded to the Office of Management and Budget for distribution to the Finance Department and to the Clerk of Courts. Included will be a project control sheet with the packet for OMB to assign an account number and prepare a Resolution for Unanticipated Funds. If matching funds are involved, a transfer of those funds are reflected on a Transfer Resolution. Those departments that receive ongoing grant awards and are familiar with setting up their accounts, shall continue to do so including OMB in the process. o Project implementation shall be the responsibility of the project manager. The project file shall be established and maintained in a clear and well organized manner, with records and supporting data in detail sufficient for pre-audit and post- audit review. The expenditures should be reconciled monthly with the detailed distribution list. A record keeping and project monitoring system shall be established and maintained by OMB to insure that reports and reimbursement requests are completed and filed in a timely manner, in compliance with grant requirements. o Closeout of the project shall include a final status report which will be forwarded to the BOCC, all grant invoices shall be reconciled with project expenditures and grant revenues, and all project reports and claims shall be filed with the granting agency. o OMB will provide assistance in each phase of grant proposal development and administration. The Grants Manager will monitor all County grants for program compliance. Coordination and communication with the offices and departments as discussed will insure improvement in grant accountability. 5 IV. Audit Conclusions: A. Progress reports need to be submitted quarterly according to the terms and conditions of the contracts. B. Request for reimbursements should be filed quarterly according to the terms and conditions of the contracts. C. Official county records should be used as part of each reimbursement request according to County's Administrative Instructions. D. Reimbursements should be deposited according to County's Administrative Instructions. E. Grants should be formally closed out according to County's Administrative Instructions. F. Forfeiture of grants should be the decision of the County Administrator or the BOCC. G. Monitoring and reconciliation of grants should be routine. H. Training should be provided for all employees responsible for grants. - 6 V. Audit Findings A. Progress Report Filings Finding: Progress reports are required by contract to be submitted on a quarterly basis. Expenses under Contract #1/AG-851 began to appear in the general ledger in October 1999 which means the first report should have been submitted on or before December 31, 1999 and then again on or before March 31, 2000, June 30, 2000 and September 30, 2000. Only two Reports were filed. The first was submitted on May 1, 2000 and the second was filed on September 6, 2000. Seven months elapsed before the first report and then four months for the filing of Report #2. To date, a final reporting has not been submitted to the State. Verbal communications with the State's representative have confirmed that no final reporting has been submitted (See Finding E). Expenses under Contract AI-931 began to appear in the general ledger in May, 2001 (however, these expenses were recorded to the wrong account which were posted as early as November 2000 (See Finding E). Reports should have been filed on or before January, April, July and October 2001 and January, April, July and September 2002 when the contract expires. Actual reports were submitted on May 23, 2001,November 6, 2001 and May 22, 2002, respectively. According to the Bicycle and Pedestrian Coordinator/Planner, the State representative verbally requested the Coordinator/Planner to submit the reports on a six-month basis. It is reasonable to comply with a grantor's requests when practicable; however, staff should consider the impact on the County. Reporting should be submitted on a routine basis according to the terms and conditions of the contract to avoid the risk of non-compliance. Both parties must agree in writing to modify any contract. Non-compliance could result in delaying the receipt of grant funds as well as other risks should either agency have personnel turnover. Recommendation(s): 1. Progress reports should be submitted according to the terms of the grants. 2. If it appears that compliance with the terms is not reasonably possible, a formal written extension of due dates should be requested and obtained. 3. All agreements should be modified in writing. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations. Review of Recommendations: 1. The Administrator agrees that progress reports should be submitted according to the terms of the grants. 2. The Administrator agrees that any time it appears that compliance with the terms of the grants is not reasonably possible, a formal written extension of due dates should be requested and obtained. 3. The Administrator agrees that all modifications to agreements will be done in writing. 7 • B. Reimbursement Requests Finding: According to the agreements, requests for reimbursement should be filed quarterly. Reimbursement requests for grant funds for the Bicycle and Pedestrian Coordinator/Planner position have not been consistent with those terms. According to the Bicycle and Pedestrian Coordinator/Planner, the grantor had asked her to request the funds on a six-month basis. It is reasonable to comply with a grantor's requests when practicable. However, staff should consider the impact on the County. Reimbursement requests should be submitted on a routine basis, at least quarterly, in order that the County has access to all available funds. Responsibility for this should be assigned such that management control is maintained over revenues, all reimbursable costs are claimed and cash flow is maximized. Turnover in the Bike and Pedestrian Coordinator/Planner position precipitated the late filing of reimbursement request. Recommendation(s): 1. Reimbursement requests should be submitted according to the terms of the agreement. 2. All agreements should be modified in writing. 3. The appropriate level of management should review all reimbursement requests to ensure compliance with the grant contract. This procedure may assist in consistency in the event of turnover, vacations or other leaves of absences within the Departments. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations. Review of Recommendations: 1. The Administrator agrees that reimbursement requests should be submitted according to the terms of the agreement. 2. The Administrator agrees that any modification to the agreement should be made in writing. 3. The Administrator agrees that the appropriate level of management should review all reimbursement requests to ensure compliance with the grant contact. The Administrative Instruction will be modified to include this recommendation. C. Official County Records Finding: Official County records should be used to reconcile and prepare reimbursement requests to the State (See Exhibit A). Five requests were submitted for reimbursement to the State; the auditor's reviewed all of them. There were no official records submitted as part of any of the five requests. Items submitted as supporting documents were expenses paid through accounts payable. Items such 8 as salary/wages, worker's compensation, insurance benefits and taxes, had no evidence supporting those expenses although the County was requesting reimbursement for those expenditures. Two invoices were submitted under the first Contract (AG-851/GW9910). Invoice #1 was submitted on 4/10/00 and rejected for non-compliance. It was corrected, resubmitted and approved and paid by the State on 4/26/00. On 9/6/00, five months after the Bicycle and Pedestrian Coordinator/Planner resigned, management submitted the second invoice. A different State representative reviewed the second invoice and approved as submitted even though official county records were not submitted as supporting documentation. On 10/27/00 a replacement was hired for the Bicycle and Pedestrian Coordinator/Planner position. Invoices under the second contract were submitted by the new coordinator beginning on March 23, 2001. The second invoice submitted under Contract #2 was submitted and rejected by the State for non-compliance. Official County records were not reconciled or used as supporting documentation as required by the agreement. As a result, ten months of expenses were posted to the wrong project number from September 2000 through June 2001. The mistake was not discovered until it appeared the County forfeited $29,228.10 in reimbursement funds due to the expiration of the contract. Another issue arising from this mistake was that Finance personnel made improper accruals at the end of the fiscal year 2001 which resulted in that same amount being recognized on the year end financial statements and single audit report. Due to lack of reconciling and submitting the official county records as part of the reimbursement request, the County under billed the state by$3,083.60. The third invoice submitted under Contract#2 was submitted and rejected by the State for non- compliance. After correcting the $29,228.10 error, total expenses through March 2002 totaled $91,358.37; however, by using internally prepared documents instead of the County's official records, the County has over billed the State by$2,020.12. Although three of the five invoices were rejected, they were not all rejected for the same reason (See Exhibit B). The State does not review the submitted invoices on a consistent basis. For example, under Contract #1 the invoice was rejected because a completed invoice summary was not provided, the lack of acceptable number of copies with sufficient supporting documents, the lack of a progress report and the lack of a completed invoice summary. Under Contract #2, invoice #2 was rejected for requesting reimbursement on Class C Meals not reimbursable by the State in fiscal year 2002. Invoice #3 was rejected because the Program Manager signed the request. According to the State, the request should be signed by a Supervisor or Department Head. A second reason given was that each invoice should send supporting documentation such as the County's official records. Four of the five invoices were signed and submitted by the Project Manager; only one was rejected for the lack of a Supervisor or Department head signature. If the over billing is not corrected before the end of the fiscal year, the financial statements and single audit reports issued by the County will be in error and the County could be found in breach of its agreement with the State for non-compliance of the teens and conditions. 9 Recommendation(s): 1. Official County records should be used as part of the required supporting documents. 2. Internally generated documents should be used as a monthly reconciling tool and not used in lieu of the official county records. 3. County policies should be followed when requesting reimbursement. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations except where noted below. Review of Recommendations: 1. Official county records should be used as part of the required supporting documentation. Although it can be surmised what constitutes "Official County" records, it would have been helpful to identify specifically some examples in the "Findings". In addition, the statement in Paragraph 4 of the findings, it is asserted that the County forfeited funds is misleading. It is true that the County did not spend all the grant funds; however, the County did not have any expenses for which it was not reimbursed. 2. Internally generated documents are helpful on routine items, but reimbursement requests will be tied to official county records in the future. 3. County policies will be followed when requesting reimbursement. D. Timely Deposits Finding: A check in the amount of $18,038.87 was deposited seven (7) months after receipt. Reimbursements should be deposited as quickly as possible, but in any event, not later than three (3) business days from receipt according to Administrative Instruction #1013.1 (See Exhibit C). The time lag between filing for reimbursement and the deposit of funds to the County's bank account should be kept to a minimum. Invoice #1 was submitted to the State for reimbursement on 05/23/01. The state issued and dated the check on June 27, 2001. Finance received the check from Growth Management on February 5, 2002 and immediately deposited the same. The check was obtained due to a third party agency contacting the Finance Department of an $18,038.87 receivable owed to the County. For a fee, this agency offered to collect and submit the monies on behalf of the County. As a result of this notification, the Finance Department enlisted the help of the Internal Audit Department. The Internal Audit Department immediately began steps to identify those same funds. After several inquiries into the matter, the internal audit department determined which Department was expecting the funds (See Exhibit D). As a result, the County lost interest on those funds and ran the risk of the check 10 being voided after a certain number of months without being cashed (12 months for the specific check in question). Recommendation(s): 1. Reimbursements should be deposited as quickly as possible, but in any event, not later than three (3) business days from receipt according to Administrative Instruction No. 1013.1 —Cash Management Procedures. 2. When filing a grant application with any agency, the County should encourage all Departments to request their grant(s) reimbursements to be paid by ACH/EFT (Electronic Fund Transfers). County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations. Review of Recommendations: 1. The Administrator agrees to remind employees of Administrative Instruction 1013. Funds should be deposited within three (3)business days. 2. The administrator agrees that all funds should be transferred by Electronic Funds Transfer. The Growth Management Division advises the Administrator that they requested EFT be used by the Grantor but was told that it was not available for this program. E. Close Out Grant(s) Finding: Due to turnover at the department responsible for the grant, the Finance Department was not properly notified of the closing of Contract #1; AG-851/GW9910. As a result, grant receivables were accrued at the end of the year. In addition, these amounts were posted to the wrong grant and project. During the course of this audit, the Finance and Audit Departments discovered the discrepancies. These expenses were not reclassified to the proper project number until June 2002; two years after the last activity. According to Monroe County Administrative Instruction 4301.4 - Basic Procedures for Filing Grant Applications (See Exhibit E) revised 10/01/2000 has an instruction related to project close-outs. (4) Instructions: J) The project close-out shall be handled in the following manner: a final status report shall be forwarded to the Board of County Commissioners, all grant invoices shall be reconciled with project expenditures and grant revenues, and all project reports and claims shall be filed with the granting agency. 11 As of June 26, 2002, no final report has been submitted to OMB or to the State Department of Transportation according to the terms of the contract to finalize Grant/Contract Number AG- 851/GW9910. This lack of reporting resulted in expenditures being accrued at the end of Fiscal Year September 30, 2001. It also resulted in $29,228.10 of expenditures being improperly coded to the wrong project and grant which were not properly identified until June 2002 during the course of the internal audit. A final status report to the BOCC as required under Administrative Instruction#4301.4 (J) should have been completed. Recommendation(s): 1. County Administrative Instruction #4301.4 (J) Project Close-Out procedures should be followed. 2. Monthly reconciliation of expenditures to the County's official records and continuous monitoring of grants by appropriate department supervisors. 3. Implementation of a Standard Data Sheet (See Exhibit F) may help facilitate necessary communication between OMB, Finance and the department receiving the grant funds. 4. A final status report forwarded to the BOCC. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations. Review of Recommendations: 1. The Administrator agrees that County Administrative Instruction #4301.4 (J) Project close-out procedures will be followed. 2. The Administrator agrees that reconciliation of expenditures should be based on Official County Records and be reviewed at an appropriate management level. 3. The Administrator will have staff review the possibility of using a standard data sheet. 4. The Administrator agrees that we should comply with the Administrative Instruction and furnish a final status report to the BOCC. F. Forfeiture of a Grant Finding: With Contract#1, the State committed 80% of the total grant amount or $57,000 to the County for the Bicycle and Pedestrian Coordinator/Planner position. The County used $32,786.90 of the available funds before switching to the next available Grant. The lack of reconciliation and monitoring of the County's official records and turnover within the position forced this result to occur. The effect upon the County was the loss of State Funding in the amount of $24,213.10. Recommendation(s): 1. Decisions to forfeit a grant should be the decision of the County Administrator or the BOCC. 12 �-J County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations, except that forfeiture did not occur, only not being able to use all the fund in the time allocated. Review of Recommendations: 1. The Administrator agrees that it should be the decision of the Administrator and/or the BOCC on forfeiting a grant, should that ever occur. G. Reconciliations /Monitoring Grants Finding: Reimbursement requests have been calculated and submitted using internal documentation. The requests are not prepared from financial infoiiiiation reported in the general ledger. Such requests are not consistently compared to the general ledger before they are submitted for reimbursement. As a result, the amounts being requested do not tie to the County's official records. Reimbursement requests are not presently reviewed or monitored prior to submission nor are copies of the reimbursement requests sent to the Financial Department for the accounting records. The reimbursements requested to date for two Bicycle and Pedestrian Coordinator/Planner grants through March 31, 2002 exceed the actual expenditures by $2,020.12. The County's financial statements are in error due to the filing of incorrect reimbursement amounts. Recommendations); 1. Reimbursement requests should be reconciled, reviewed and approved by a supervisor or department head before they are submitted to ensure that all eligible costs are requested and that the reports are in agreement with the County's official books and records with a timely copy submitted to the Finance Department. 2. Consideration should be given for any and all differences discovered by the reconciliation and monitoring process to allow for timely identification and correction of errors. 3. Monitoring of Grants by a Department Head or Supervisor should be done on a routine basis to insure they are in compliance with all the teiius and conditions set forth in each contract. This may prevent future issues from occurring in the event the Project Manger or other personnel take vacations, turnover or other leaves of absences. 1. Reconciliations should be regularly performed to ensure that postings are corrected and adjustments have been properly processed. 2. Controls should be established to ensure all transactions are updated accurately. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations. Review of Recommendations: 1. The Administrator agrees that the reimbursement requests should be reconciled, reviewed and approved by the appropriate level of management utilizing the County's official records. 13 2. The Administrator agrees that all differences discovered during the reconciliation process should be corrected. 3. The Administrator agrees that the grants should be monitored by an appropriate level of management. 4. The Administrator agrees that reconciliation should occur on a routine basis and certainly on the frequency required by the grant. 5. The Administrator agrees that transactions should be updated accurately and with the appropriate level of managerial review, believes they will be. H. Initial Training—Grant Procedures Finding: All employees responsible for the administration of grant funds should receive sufficient training of the County's Grant Procedures. These employees should be educated on the terms and conditions of the grant, become familiar with the funding agency's rules governing expenditures, reimbursement request policies. Employees should also be educated on the use of the County's official records and how to read and interpret them. The replacement - Coordinator hired in October 2001 was considered the new "Project Manager" responsible for the two outstanding grants. The new employee did not receive any instruction or training regarding the two grants. According to conversations with the replacement, she understood that she was hired strictly under the funding of Contract#2. She was under the impression that Contract#1 was closed prior to her start date. Issues resulting from the lack of training and monitoring by the project monitoring system detailed in Administrative Instruction#4301.4 (I) are: 1. Expenses totaling $29,228.10 were improperly coded to the wrong project and grant. 2. The County forfeited $24,213.10 in reimbursable State funds. 3. Year-end Financial Statements and Single Audit Reports for years 2000 and 2001 included the above errors. (The errors have been corrected in Year-End 2002) 4. Three of the five invoices were rejected by the State and delayed the receipt of County funds. 5. A check in the amount of $18,038.87 went uncollected for more than seven months even though the County requested the reimbursement. 6. Request for reimbursements include non-refundable expenses. Established internal controls for centralization of Grant Management are inadequate and ineffective. In practice, the majority of County Departments are not in compliance with the established administrative instructions. On paper, the County has established an adequate system for monitoring all grant programs for compliance with federal, state and local general and specific grants requirements; however, according to management personnel, it is not practiced or enforced. OMB personnel informed the internal auditors that the lack of personnel, time and funding were the main reasons why the County cannot enforce its own Administrative Instruction#4301.4. 14 The major risk to the County will be that once a grant is procured, the potential for loosing the funding is significantly increased due to lack of monitoring and non-compliance with the agreed upon terms and conditions of individual contracts. It may benefit the County to have part of the Grants Management team receive monitoring certification as part of their responsibilities and to then train other Department supervisors or a representative responsible for maintaining their own departmental grants. By implementing a continuous training and education for personnel directly responsible for a grant, it may help eliminate the continuous year end management comments on the independent audit. For the past 15 years, the County has had one or more grant related issues at each year-end (See Exhibit G). Recommendation(s): 1. County should consider appointing a position responsible for monitoring grants. 2. Training and education should be implemented for new hires and other personnel responsible for grants management. 3. Department heads should review Administrative Instruction #4301.4 with appropriate personnel with enforcement being emphasized and encouraged. 4. Written communication between Departments should be encouraged. This may help prevent errors from being made and not discovered timely. 5. Documentation should be prepared and maintained such that all individuals involved have sufficient information and instructions with which to perform their respective functions. County Administrator's Response: The Administrator concurs that there is room for vast improvement for the manner in which grants are handled. The comment attributed to the OMB that there was not time, personnel or funding to enforce their own policies was a recap of the history of the department. The focus on grants has differed greatly over the past decade. The BOCC established a separate Grants Department in 1992. The department was made up of 3 people. However, the BOCC reorganized Management Services in 1994 and the Grants Department was downgraded from department status to a section of the Office of Management and Budget. It was comprised of one staff position. In the future there will be additional training for those who handle grant reporting. Review of Recommendations: 1. The Administrator agrees there should be a position responsible for monitoring grants. Budget pressures and downsizing have precluded the establishment of such a position. Training as identified above will be utilized until a grant's accountant position can be established. 2. The Grants Administrator should have a copy of all grant agreements approved by the Board. This will enable the Grant Administrator to contact grant monitor with information regarding Administrative Instruction #4301. Training of specific grant handling is the responsibility of the department securing the grant. 3. Administrative Instruction #4301 should be followed by all grant monitors, but especially reviewed by Department Heads with enforcement and signature responsibility. 15 4. Written communication will be encouraged where appropriate. 5. Grant monitors will maintain sufficient documentation of grant activity. County Administrator's General Comments: Exhibit G, Summary of the past 15 years of Management Comments, contains comments from audits of grants secured and administered by the Sheriff's Office. The County Administrator has no control over these grants and are therefore irrelevant to this audit. Auditor's Response: Exhibit G, Summary of the 15 years of Management Comments contains 10 comments related to Monroe County and 4 related to the Sheriff's Office. 16 VI. Exhibits Exhibit A Memo from County Administrator to Clerk of Circuit Courts Dated July 18, 1994 (four pages) BOARD OF COUNTY COMMISSIONERS ,,��_ MAYOR,Jack London,Distict 2 0 U N TY ofFLORIDAIR 0 E '" Mayor Pro Tem,A Earl Cheat,District 4 r` F Wilhelmina Harvey,Diclricl 1 KEY WEST FOD 33040 ,� la. Shirley Freeman,District 3 (305)294-4641 �� '_lk j• 1y it •I.i ,1^ Mary Kay Reich,District 5 i)•1 '..in;t2J11 '0 . \;, lim II i;F -- MEMORANDUM TO: Danny Kolhage i!,,. '" Clerk of Court ) : r FROM: James L. Roberts i County Administrator >' I...r - SUBJECT: Annual Audit for the year ended r 1; `ir.•'-•IN;•" September 30, 1993 Li I: DATE: July 28, 1994 f The Administration has reviewed the comments by Kemp and Green, P.A. , in reference to the annual audit for the year ending September 30, 1993 . The following are . our comments in reference to that report: 1 PRIOR YEAR' S FINDINGS The report indicates that there were some items not -- implemented subsequent to comments made in the audit for the year ended September 1992. The following are the responses: • GRANTS Overall, grants functions continue to be somewhat decentralized due to the history of the handling of grants and the difficulty of establishing a Grants Management Department with limi.td resources . Recent- ly, an internal audit was requested of the Clerk of the Court' s office and such a draft audit has been completed. Responses to that performance audit are being prepared and will be submitted shortly to the Clerk of the Court so that a final audit document can be prepared. Similar comments were made in reference to the grants function there. IIMII j - - - - - - . _, h 4. 1 I., <° The computerization of the Grants Monitoring System has greatly aided in the monitoring of the grants over ,. which the Grants Management Department has direct . u(_ _ ' control. There has been improvement in compliance v. reporting and cash flow management in reference to iu those •grants. 1 However, the unique nature of many of the major grant I', functions including Airports, Growth Management and i'`: Social Services, and 'the large amounts of work in- _ volved with the monitoring and management of those 'a• grants require that they be handled within the respec- � tive divisions charged in those subject areas . This ; ; means that there are staff available who are familiar ':? with the grants, and who are available to provide _ information, compliance, etc. It is not possible for the collection of grants of that size to be the gener- 'fi al responsibility of a two to three person Grants u ' Department. There will be efforts in the future to assure that all grants are managed and monitored to .'I the highest- standards. ,_ If the auditor has specifics which need to be ad- ; dressed it would be appreciated if they would be L:.,, forwarded to the County Administrator. ?. PURCHASING PROCEDURES :.ax: In reference to appropriate sole source vendors, in May of 1994, the Monroe County Board of County Commis- ,: sioners adopted Revised Procurement Policies which };t include requirements for the utilization of sole '- source purchases. There are seven conditions which 'j must be met in order for a sole source purchase to be .' made. Within the next few months, the Administrator and Purchasing Department will be developing an Admin- .- istrative Instruction to implement the new Procurements. Policies which will also include the conditions for '1 the sole source purchase. h kq BUDGETARY COMPLIANCE ut- The auditor' s comments should take into consideration `e that normal bud etas ''` g y procedures were followed in =G���; M FE, conjunction with appropriate legal requirements. In the future, there will be ongoing reviews to be sure that contingency funds at the Marathon Airport do not ', exceed 10% of the total fund budget. - L / • DUE TO CUSTOMERS In reference to the auditor' s comments, a procedure r ._ will be established to review the status of accounts to determine whether credits are refundable to Munici- pal Service District customers. In the event that 1 such refundable credits are determined, action will be taken to have the 'refunds implemented. CURRENT YEAR FINDINGS CASH MANAGEMENT PROCEDURES The Administration recognizes the importance of funds being deposited in a timely manner. All departments • will be advised in writing that funds received should be deposited as quickly as possible, but in any event, no later than three ( 3) business days. CARD SOUND BRIDGE REVENUE During this past year, the Administration has been aware that there might be some difficulties in refer- ence to the issues raised by the auditor. An internal • audit from the office of the Clerk of the Court was completed and recommendations were developed. In order to resolve the issues raised, including the issues in this auditor' s report, a number of actions are being taken. First, the computer system will be :a upgraded to be sure that the capacity for reporting an analysis is there. Second, there will be a fiscal change to the treadle gear mechanisms so that there is :? a more exact accounting. Third,' the formula as it ;4, 7 pertains to the treadle count, and the ultimate deter- mination of the number of vehicles is being reviewed for greater accuracy. These should all be accom- '' plished during this current fiscal year. The report identified by the auditor will also be modified to be '_ sure to reflect greater accuracy. GRANTS 1. It is the policy of the Administration that Y single audit funds will ultimately be responded to and resolved by the County Administrator. Once those findings have been made known to the Administrator, they will be reviewed by the appropriate staff with recommendations and proposed responses to the Adminis- - - { 3 �_. e , eft.. -- 7 ti . . trator. Any formal responses required will then be submitted. • 2 . It is the Count 's grant reimbursements in conjunction policy h the officialt County records;'"-- With each Division/Department dealing with ti the grants, there is, an individual identified who is grant ,M � responsible for the maintenance of theft in conjunction .•with the 'official records of the records ty• „.,-'. All Division/Departments will be advised byL(a , :',:Administrator that their grant reimbursement request .must.• be in conjunction with the official County x .,,.records and that an appropriate audit trail be• avail- 1 `able. r . ;tit These comments are provided by way of explanation in �t reference to the annual audit for the r; September 30, 1993 . ny year ending clarification is. needed, the Administration will bfurther information e pleased to supply it, be w4 / �t J yy i it tly 1 • ti 1 7 r • r• 1 Y i • • , 4 . Exhibit B Rejection Letters from the F.D.O.T. Representatives Contract #1 — Invoice #1 Rejection Contract #2 - Invoice #2 Rejection Contract #2 —Invoice #3 Rejection County of Monroe Planning Department T • Board of County Commissioners 2798 Overseas Highway y�, ,, Mayor Shirley Freeman,Dist.3 Suite 400 ; '' ' ' Mayor Pro Tem George Neugent,Dist.2 Marathon,Florida 33050 Commissioner Wilhelmina Harvey,Dist.l Voice:(305)289-2500 Commissioner Nora Williams,Dist.4 FAX: (305)289-2536 - Commissioner Mary Kay Reich,Dist.5 • April 20,2000 Marie S.Ladouceur Transportation Planner Florida Department of Transportation,District 6 602 South Miami Avenue Miami,Florida 33130 Re: JPA/Monroe County Bicycle/Pedestrian Coordinator Position-Revised Invoice#1 FM#252077-1-14-01 , Contract#: AG-851 Dear Ms. Ladouceur: Please find enclosed a revised invoice for the above referenced JPA agreement. Monroe County has submitted numerous invoices for various JPA agreements and was surprised to see this invoice rejected as it followed the same format as previous submittals. At your request, the following revisions have been made to this invoice: 1) A completed invoice summary is provided; 2) One original and four copies of the entire package are enclosed along with sufficient supporting documentation; 3) This letter serves as the project progress report. As the bicycle/pedestrian planner for Monroe County, I have coordinated very closely with Gus Pego, Gary Donn, and Chris Dube for bicycle/pedestrian issues. Additional progress reports beyond the one contained in this letter can be obtained from these District 6 individuals. 4) Total reimbursable amounts,travel expenses, etc. are in line with the agreement contract. Progress Report: Monroe County hired a bicycle/pedestrian coordinator in September 1999 to manage the Overseas Heritage Trail Master Planning Process. Other duties include coordination with DOT for programmed enhancement projects. Since September, the bicycle/pedestrian coordinator has worked to bridge communication gaps between participating agencies and to develop a successful implementation plan for the Overseas Heritage Trail. Future plans include administration of programmed enhancement funds along the US 1 corridor by the Florida Department of Environmental Protection (DEP). As a LAP certified organization, the DEP has agreed to work in partnership with DOT to design and construct the trail. The DEP will also maintain the trail through a maintenance agreement with the DOT. If you need any additional information to process this invoice, please contact me at (305) 289- 2521. Thank you in advance for you timely review of the invoice. Sincerely, .2400447 Trish Stratton,AICP Bicycle/Pedestrian Planner c: Chris Dube,District 6 Kim Ogren, Monroe County Mayra Tezanos, Monroe County • INVOICE SUMMARY NO. 1 . Department of Transportation,District ATTN: nee UC-PUV District Public Transportation Manages In accordance with Chapt�-�"1'I ��.( . S.,(it J0' t Participation Agreement and dated� l.t�►'t� D- Q any Supplemental Agreements r 1 between the Florida De• partment of Transportation and n at ( rd . The Agency incurred the indebtedness listed below between 4 1 22.):1,3___and /?S 0 v This invoice(is)(is not)for costs incurred on a prequalified Joint Participation Agreement (Documentation of indebtedness or coati attar TOTAL ESTIMATED PROJECT COST: FRONT END FUNDED PROJECT:YES( )NO( $- t 0�0 MAXIMUM FDOT PARTICIPATION PER AGR�• $ �r TOTAL ELIGIBLE PROJECT COSTS INCURRED TO DATE: Y S FDOT PARTICIPATION INELIGIBLE COSTS INCURREDS = CO�f� PREVIOUSLY BILLED: TO DATE: S • I THIS BILLING:(FDOT participation in eligible oats incurred S /' to date minus amount previously trilled.) g 61-10 • r 1 NET REQUEST FOR PAYMENT: S $ I terrify that 16e aforesaid listing it true and correct. . r certify,ender penalties of Perjury,that the agency has oomp6ed with the APPROVED provisions of this Agreement District Public Trans.Manager BY Is/ • • Agency Head or Authorized Rep. (Date) et . " itle) I1-rl eT 1 ��� APPROVED AS MEETING TERMS OF CONTRACT L O (Date) District Project Manager WPI# �o. G�7 0 Job# — (Date) Contract# 6 T -Sr / J • June 1995 1 _J • fl Florida Department of Transportation ru OFFICE OF PLANNING-DISTRICT SIX THOMAS F.BARRY,JR. 45 602 SOUTH MIAMI AVENUE,MIAMI,FLORIDA 33130 SECRETARY PHONE:305.377.5910 (SC)452.5910 FAX:305.377.5684 (SC)452.5684 November 19, 2001 Elizabeth Holloway Monroe County 2798 Overseas Highway, Suite 410 Marathon, FL 33050 SUBJECT: Invoice Summary No. 2 FM #: 25207711401 Contract: AI-931 Dear Ms. Ho'fi gar I am returning Invoice No. 2, for correction for the following: 1. "Class C"meals are no longer reimbursable; this came into effect on Julyl, 2001; 2. Travel has to cover a radius of at least 80 miles to qualify for meals. If you have additional questions,please contact me at 305.377.5683. Thank you. Kenneth Jeffries Transportation Planner www.dot.state.fl.us ®RECYCLED PAPER 305-209-2536 PLANNING DEPT PAGE 04 • J 3. i 71 fM r "•: " Florida Department of Transportation• n OFFICE OP PLANNING-D18TRIei'srx , JEB BUSH 602 SOUTH MIAMI AVENUE,MIAMI,FLORIDA 33130 THOMAS F.HARRY,M. • • , GOVERNOR PHONE:(305)377-5910 (SC)452-5910 SECRETARY FAX: (305)377-5684 (SC)452-5684 • tft ' }'.r June 6, 2002 Ms. Elizabeth Holloway -- j Bicycle and Pedestrian Planner • . :; Monroe County Planning Department • 2798 Overseas Highway, Suite 400 Marathon,Florida 33)50 Dear Ms. Holloway: SUBJECT: REJECTION OF INVOICE#3 A Centre et No.: AI-931 -- • FM No: ,- 25207711401 - The referenced invoice has been rejected for the reasons we discussed in our phone conversation earlier today. invoice summary ,, Y page must be signed by the Agency Director, or authorized ; .- representative, such tus Tim McGarry, or Marlene Conaway. I have attached an example of an i invoice summary page that I have used in the past. As we discussed, one copy of the accounting - ledger printout is acceptable, however, we need to receive an original and four(4) copies of any invoice (including expense forms) submitted for payment. Also included, for your files, are tw • o k copies of the current F DOT travel reimbursement form. Please use this form when documenting all future travel-expenses. Please make the necessary revisions and resubmit for payment. Do not hesitate to contact me if'yqu have t.r ally questions. Thank you. :,: • - Sincerely, .; Phil Steinmill , MCI:P i; Planning Project Manager i ;,. • I', , cc: Financial Services t; • 14 wwW.dot stet ;.PLUS 0 RECYCLED PAPER # t I 305-289-2536 PLANNING DEPT ' PAGE 02 FDOT INVOICE NO. 3 .� Florida Department of Transportation 602 South Miami Avenue Miami,Florida 3:t 130 ATTN: Mr: Gary Donn District Director ofPlanning and Programs . In accordance with JPA dated June 25, 2001 between the Florida Department of Transportation and Monroe County, Florida,represented by the Monroe County Growth Management located at 2798 Overseas Highway, Marathon,Florida,33050, the Public 1 Body has-incurred the indebtedness listed below from September 19, 2000 until 31, 2002. Support documentation is attached. March Total Project Cos': $138,563.00 Maximum D.O.T Participation per Agreement $138,563.00 Total eligible Prc ject Costs to date $ 93, 378.49 D.O.T Participation-in Eligible Costs Incurred to Date .4 Less Previous Billings $ 93,3789 Amount Due this Billing Pay $ 56,684,$9 $ 36,693.60 Balance $ 45,274.51 - I certify that the aforesaid listing is true and correct oruoe cow_ _ix_ By 1I -/ Public Body , I�, K. Marlene Conaway Director of Pla n and Environmental Resources Title FM No. 25207711401 Approved as Meeting - Terms of Contract Cont act No T-931 . - i • a_-- �� cjed c,. .n 1� Jry°Pi-CO (tcs.n" / 't- y-f) sLaias ALJti INVOICE SUMNIaOWNO. 3 / lament orTransportaGoo,District 6, • /Arfl.x: Mr. Kenneth Jeffrien � District Public Transportation Manager In accordance wick Chydcr 334.044(21$.5.,the Joint Participation Agreement and any Supplcmcntitl Agreements dated__Junt. 25 t11, 29 01 between the F1ot•:da Department of Transportation and • tIonroq CSiunty, 2;'99 Overdeao 114:zhway, Stiite 410 jlarattuj Florida,33050 . .The Agency itl:tured the bide:blarnn+s listed below between September 19, 20021d March.31,2002 tuwvt nx uw�-— ttaar- This invoice(iii)(is not)for costs incurred on a prequalificd Joint Participation Agreement. (beettmagaliao of tntla6uda44 a lade Fak ad) TOTAL ESTIbIATEDPRDJECTCOST: • S 1.38.563.00 FRONT END FUNDED P ROJECT:YES( )NO(y) MAXIMUM F.JOTPARTICIPATIONPIItAO' ei• I ;_ion y. • S TOTAL ELIGIBLE PROM ECT COSTS INCURRED TO DA"E: S 93.512.39 FDOT PARTICIPATION:N MOBILE COSTS INCURRED TO DATE: S g3.512-39. / PREVIOUSLY BILLED: • S 5[L fill G,E19. THIS BIL INC I:(2 DOT Judi alp'don is eligible twa metaled ro date min W mount previa.lybilled.) S 16.827,50 NET REQUEST FORPA!PtvtENT: S, 16.827.50 I certify that the afa;oaid Hating le true end meat. t Ds*terktpaulua of pgjvey,nue the agcnay}aa cempliod will,the APPROVED pcovii o a at thin Agreome3L t.-14 District Public Trans.Mac lager Agee I I d or Authorize R p. (Date) Bicycle and Pedestriat Pl.ainfr APPROVED A5 MEETIN a TERMS OF CONTRACT May 22,2002 ' ate) WPI# 25207711401 District Proji:ct Manager Job it • _(Date) Contract# AI 931 • • • Jana 19f S • Exhibit C Monroe County Administrative Instruction 1013.1 Cash Management Procedures ,l , -�� • tit �.. � '�' I BOA,.,,#)FCOtw fY COMMISSIONERS -" MAYOR Wilhelmina Harvey,District I t I. �t`�' Mayor Pro tem Shirleyreeman District 3 • • OUNTY o MONROE ';liri' '• ,• .';;��,"� y y Freeman, KEY WEST FLORIDA 33tM0 011A George Neugent,District 2 1305)244.4641 iPita ^ ,•; Nora Williams,District4 �,•�. � ; Mary,Kay Reich,District S • 4 40: JW 'ti OFFICE OF THE COUNTY ADMINISTRATOR Key West, Florida MONROE COUNTY ADMINISTRATIVE INSTRUCTION 1013.1 Date: August 9, 1999 Subject: Cash Management Procedures Reference: (A) Annual Audit Report— 1993 Enclosure: N/A Effective Date: Upon Receipt (1) Background: An independent audit was conducted on the general purpose financial statements of the • Board of County Commissioners on Monroe County for the year ending September 30, 1993. A report was issued by the Auditors and specifically addressed a deficiency found in the County's cash management procedures. (2) Purpose: To establish a standardized cash management procedure that will eliminate the risk of loss or misappropriation of funds. (3) Cancellation: This instruction is to remain continuously in effect unless specifically revised or canceled. - (4) Instruction: A. All Divisions/Departments will have in effect a policy for all cash funds received to be deposited as quickly as possible,but in any event, not later than three(3) business days from receipt. B. Advise appropriate employee(s) from your Division/Department who will be responsible for the cash deposits of the policy. Administrative le 1P" 1 • August 9,1999 • Page 2 • C. Periodically review the cash management procedure to ensure efficiency and compliance with the policy. (5) Action: All Divisions/Departments are to implement this policy immediately upon receipt and periodically review the efficiency of this system. James L. Roberts County Administrator Distribution: List III Originator: CAD Review: August,2001 • • ' 2 Exhibit D Memo from Growth Management to Finance Dated January 13, 2002 A 4 v Biter r p=i. �; 1 t �� � LD FEB 0 e ,�L u i yk,�;:. 2 l'i�� , refs C0. 4 £ ;z' MEMORANDUM 4 'w xr , 1 / Tina Bo an ' . " ' Finance Department •,,,, ,,,-*:r:6,,* -,:,i.,;.,i-: 4: 'x,kiv . FROM: Mayra Tezanos i ivii.`, Coordinator, Budget& Personnel ed Growth Management Division ,� ' SUBJECT: Check from FDOT-Bicycle Pedestrian Grant AI-931 DATE: January 31, 2002 v Hi Tina, Enclosed please find a check for$18,038.87 for the above referenced grant. Please deposit it into account 125-50106-GW0101. 5050 7 Ms. Mathena from your office had called me looking for a check that was outstanding for the amount of money referenced above. I went looking through our grant files and found this check in the Bicycle Pedestrian Grant file. Apparently, it had been misplaced. Please let her know I found it and that now you have it. I have tried reaching her all last week but was unsuccessful. Thanks. Exhibit E Monroe County Administrative Instruction 4301.4 Basic Procedures for Filing Grant Applications • t 'l BOARD OF COUNTY COMMISSIONERS �� MAYOR Shirley Freeman.District 3 O U N TY M O N R O E � �'M Mayor Pro tem Jack London.District 2 � 4. KEY WEST FLORIDA33040 ti. vq•;• •• •• •�' t Wilhelmina Harvey,District I (303)294-4641 i4.44 i 1'0�/1 ' r• ,; ��� ► it Keith Douglass,District 4 onikav'� '•y'' Mary Kay Reich.District 5 • Office of the County Administrator __ • Key West,Florida MONROE COUNTY ADMINISTRATION INSTRUCTION 4301.4 Date: October 1, 1998 • Jubject: Basic Procedure for Filing Grant Applications leference: (A)Monroe County Purchasing Policy Procedures nclosure: (1)Resolution authorizing grant application (2) Grant Summary Data Sheet (3)Proposed Budget . . (4) Resolution accepting grant award • (5)Project Control Sheet • • affective Date: Upon Receipt • • (1) Background: In order to insure standard procedures are followed in procuring grants, grant administration, Ind final grant close-out,the Office of Management and Budget(OMB) oversees and coordinates the --development of grant proposals, grant administration,and final grant close-out. OMB also serves to coordinate between the various county departments, granting agencies, and Finance. - (25 Purpose: The purpose of this instruction is to set forth the procedures that each department shall follow in -submitting grant applications,in accounting for the use of federal and state funds, and in maintaining records for I pre-audit and post-audit review. • —(3) Cancellation: This instruction hereby replaces M.C.A. 4301.3 and is to remain in effect until revised or (canceled. (4) Instructions: A. The feasibility of submitting a grant application on behalf of Monroe County shall be determined by the Department I-Iead, OMB,the County Administrator,and the Monroe County Board of A. Inst.4301.4 ------ -- .ober 1, 1998. age 2 Commissioners. The relationship of project costs to benefits and any underlying or ongoing costs should k be considered in that determination. B. The first step in developing a grant proposal is to thoroughly research the law which governs the program.grant ro . Consider: the grant period timelines;contract/agreement provisions, budgetp o o the sal requirements,project feasibility, and who will serve as project director. All grant projects require proposal identify the person who will serve as project director. This person shall be responsible for all aspects of project implementation which includes,but is not limited to, the following: grant proposal preparation, execution of grant agreement,creation of grant account,filing project reports and financial claims,and accompanying close-out documentation. In cases where the grant program crosses fiscal years,the project director shall insure that grant funds are rolled over into the following fiscal year. • C. The Board of County Commissioners shall review the grant application or a project narrative at a regularly scheduled meeting with a resolution authorizing the submission of the grant application (reference enclosure 1). The resolution shall specifically name the granting agency,the proposed use of funds,the amount of matching funds and their source,and.the purpose of the proposed grant arySheet ect. The resolution must be reviewed by the County Attorney for legal sufficiency. A grant (reference enclosure#2) is to be incorporated into the agenda packet with signatures of the Department Head,Division Director,Project Director,and the Grants Manager. Submit the number of original grant applications required by the granting agency for execution to the County Attorney's office for processing. Be sure to allow enough time for the Board's execution. �= D. Once approval has been secured from the Board of County Commissioners, submit a properly executed grant application and resolution to the grantor. The grant rules governing grant programs vary widely among funding departments and agencies,and therefore cannot be detailed in this instruction. B. Upon notification that a grant award is to be made to Monroe County, the requesting department will receive a contract outlining the contract requirements and any'special conditions attached thereto. The contract shall be reviewed by the County Attorney, Risk Management,the Office of Management and Budget, and the Division Director. F. A resolution(prepared by the project director,referenceshall be reviewed by the County • acceptance of the grant and the execution of the grant agreement Attorney,and then attached to the contract. The resolution and contract shall be scheduled on a subsequent Board of County Commissioners agenda. • G. Once a contract has been fully executed by both parties,a copy of the grant agreement is to be forwarded to the Office of Management and Budget for distribution to the Finance Department and the Clerk of Courts. Include a project control sheet(reference enclosure#5) with the packet for OMB to assign an account number and prepare a Resolution for Unanticipated esolut Resods.lution. deptching artments that receive ds are involved, a transfer of those funds is reflected on a Transfer ongoing grant awards and are familiar with setting up their accounts, shall continue to do so including OMB in the process. • 1 --- - - /I.C.A.Inst. 4301.4 October 1, 1998 Page 3 • H. As each funding agency has its own rules governing applications, each also has different governing expenditures. These standards will be outlined in the contract tra t accompanying advanced,different i standards gov g P grant. In general, grants are awarded on a reimbursement basis. If the gran money is i ure procedures are followed. Both methods require close ce° enttofund it I0MBfun to s hawse to tbehe time gated, ly • drawdown of funds and appropriate expenditure ofg° coordination with OMB is critical. le I. Project implementation shall be the responsibility of the project manager. The project data in shall - be established and maintained in a clear and well organizedSupporting rt�a manner,with documentation of phone detail sufficient for pre-audit and post-audit revte pp and all correspondence relative to the grant program. The record ecd d of expenditures pent monitoringiissystem calls,meetings, be reconciled with the detailed di by ution list OMB to monthly. tha,r Ports and reimbursement requests are shall be established and maintained completed and filed in a timely manner,in compliance with grant requirements. J. The project close-out shall be handled in the following manner:all venalrec status report with phallje be t forwarded to the Board of County Commissioners,all grant invoices expenditures and grant revenue,and all project reports and claims shall be filed with the granting agency. K. OMB will provide assistance in•each phase of grant proposal development and grant project administration. The Grants Manager will monitor all County grants for program compliance. Coordinati on and communication with the offices and departments as discussed in this document will insure improvement in grant accountability. (5) Action: • complywith the above instructions by insuring timely A. All affected Divisions/Departments shall proper Board of County placement of all resolutions, grant applic filingsdandeadhnestrand to avoid the possible loss of grant funds. acts on the-- Commissioners agenda in order to meet i ✓�(- James L.Roberts County Administrator Distribution List: III Originator: DGT -- Review: 10/01/2000 • l_ 1 Exhibit F Sample Data Entry Form for Grants JlATUS: 1. APPROVED Funding for County Fiscal Year: / 2. UPDATE: Department Name/Number: . CLOSE: Grant Name/Number: Project Administrator/Phone Number: Funding Agency: Funding Agency Address: Funding Agency Contact(s): Funding Agency Phone/Fax: FAX: E-mail: Purpose of Grant/Funding: CFDA#(if applicable)Federal Grant: CSFA#(if applicable)State Grant: Federal Grant YES/NO(Circle One) State Grant YES/NO(Circle One) Federal/State Pass-Through Grantor Name&Number: Record Retention Period(begins date project is closed) Funding Amount: Match Amount(if applicable) TOTAL Match Type/Source&Account Number: Term of Grant/Project(Start/End Dates) Request for Reimbursement Schedule Revenue Account Number Date of Application Date Returned`;by Grantor with Approval = Date Budget Resolution approved by BOCC Budget Information; Capital: CAFR Mailing: CAFR Due Date: • (CAFR Information for Finance Personnel to complete.) MISC Information: NOTES/COMMENTS: Completed by: Approved by: Project Administrator/Manager Supervisor of Project Adm. COPY TO FINANCE DEPARTMENT& COPY TO OMB ATTACH COPY OF EXECUTED RESOLUTION 1_i Exhibit G Management Comment Summaries On Internal Controls from External Audits For Monroe County 1989 through 2001 L__� "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) MEMO FROM COUNTY ADMINISTRATOR TO CLERK OF COURTS DATED 6/14/90 IN REFERENCE TO ANNUAL AUDIT YEAR ENDING 9/30/89 Prior Year Comments: DCA Grants: While timely reporting is the issue at hand, it should be noted that the instant case is different than that reported in the previous year. Procedures are being formulated by staff in conjunction with our grants consultant to assure that compliance with the terms and conditions of grant contracts is maintained. Current Year Comments: Grants The fiscal management of Grants is an issue that is being addressed at the present time. The role of the Grants Manager has been redefined to better address the fiscal issues of grants management, rather than the project management. The County's grants consultant, in conjunction with OMB, is developing procedures that will -- assure compliance with grant contracts. Should further information regarding any of the above mentioned issues be desired,please do not hesitate to contact me at your convenience. MANAGEMENT COMMENTS BYKEMP AND GREEN FOR YEAR ENDING 9/30/89 Not implemented as of 9/30/89: Reports pursuant to State of Florida, Department of Community Affairs Grants held by the Planning,Building and Zoning Department were not submitted with the time specified by the grant contracts, thereby causing lack of compliance with the terms of the grant and delaying the receipt of grants funds. Reports should be submitted in a timely manner according to the terms of the grants. If it appears that compliance with the terms is not reasonable possible, a formal extension of due dates should be requested and obtained. Grants: Grant funds for airport projects have not been requested on a timely basis, whether reimbursement is obtained by wire transfer or the filing of reimbursement requests. "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) Responsibility for this are should be assigned such that management control is maintained over revenues, all reimbursable costs are claimed and cash flow is maximized. Grants budgets were not recorded in the accounting records to conform to the grant contract. Matching funds were not reported correctly in airport and planning grants line item expenditures were not appropriately amended for a social services grant. All budgets should be reviewed by the appropriate level of management to insurance compliance with the grant contract. Grants appear to be under the direction of the recipient department. We have noted wide variation in the quality of management, compliance procedures, reporting procedures and cash flow management. Grants management should be centralized to the extent practicable to insure consistency with County policies and contract requirements. MEMO FROM COUNTY ADMINISTRATOR TO CLERK OF COURTS DATED JULY30, 1991 IN REFERENCE TO FY1990 ANNUAL AUDIT REPORT RESPONSE: Grants Management: Problems noted in audit report included: 1. Untimely submittal of grant reports and reimbursement requests 2. Non compliance between grant programs and grant contracts 3. Variation in the quality of management, compliance procedures, reporting procedures and cash flow management 4. Improper accounting and recording of the grant budgets Action Taken: OMB, Grants Management, has taken a pro active role in monitoring all grants. This is a new direction for this department from project management to grant monitoring. The transition period has proved to be timely and will continue to show progress. Grants Management has established a tickler file to alert the project managers of report and reimbursement request deadlines. The grants manager will continue to review grant program(s) to assure compliance with the grant agreement(s) on a random basis. The variation in the management of grants continues to be a concern due to the wide range of county grant programs and efforts are underway to streamline department efforts. Social Services and Airport grants are currently reviewed by the OMB Director. They are numerous and specific in nature and it has been determined to be more effective to be handled in this manner. Although the airport grants have continued to be an area of audit comments, an effort is being made to correct all problems. Airport projects include grants from FAA and FDOT and are complicated in budget structure. The budgets are being established with "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) L consideration to all the grants associated with the project. Research is being conducted to resolve all reimbursement errors made in the past and to define the procedure for filing those requests. Additional Action Needed: 1. An administrative procedure will be established to provide specific direction for grants and project managers. This procedure will include all phases of the grant process from authorization to apply to the closing reports. 2. Coordination between all departments with the Grants Manager needs to be stressed from all levels of management. MEMO FROM COUNTY ADMINISTRATOR TO SANDRA CARLILE FINANCE DIRECTOR DATED JULY24, 1992 IN REFERENCE TO INDEPENDENT AUDITORS REPORT ON INTERNAL CONTROL STRUCTURE AND MANAGEMENT COMMENTS FOR YEAR ENDING 9/30/91 GRANTS: To insure that standard procedures are followed in grant procurement, administration and final grant close-out, on 7/21/92 the MCBOCC approved establishment of a separate County Grants Department which is headed by the new position of Director, Grants Acquisition and Management Programs. The responsibilities of this depaitiiient include coordinating the fiscal and management oversight of all on-going grants to insure compliance with Federal, State and local regulations and with the terms and conditions of the grants. Monroe County Administrative Instruction 4301.2 has been drafted which provides for the procedures that each department shall follow in submitting grant applications, in accounting for the use of federal and state funds, and in maintaining records for pre-audit and post-audit review INDEPENDENT AUDITORS'REPORT ON INTERNAL CONTROL STRUCTURE BASED ONANAUDIT OF THE FINANCIAL STATEMENTS AND MANAGEMENT COMMENTS DIRECTED TO CLERK OF COURTS AND BOCC FROM KEMP AND GREEN DATED 2/26/93 FOR YEAR ENDING 9/30/92: MANAGEMENT COMMENTS REPORTED IN PRIOR YEAR'S REPORT AND NOT IMPLEMENTED AS OF 9/30/92: GRANTS: Observation: Grants appear to be under the direction of the recipient department and monitored to some degree by the grants management department. We have noted wide variation in the quality of management, compliance procedures,reporting procedures and cash flow management. Further, there seems to be some confusion as to the areas of responsibility between the recipient department and grants management department. "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) Recommendation: Grants management should be centralized to the extent practicable to insure consistency with County policies, contract requirements and financial reporting requirements. In addition, it should also provide review procedures relative to the preparation of reports,budget set up and contract compliance independent of the recipient department. A point of contact should be designated to respond to requests for information. MEMO FROM COUNTY ADMINISTRATOR TO CLERK OF COURTS DATED JUNE 24, 1993 IN REFERENCE TO THE ANNUAL AUDIT REPORT FOR YEAR ENDED 1992 PRIOR YEAR FINDINGS: GRANTS: The grant's management department has drafted an amendment to Monroe County Administration Instruction 4301.2 which redefines the standard procedures for the administration and oversight of the County's Grants. Additionally, liaison was conducted with the Finance Director in an attempt to obtain a firm definition of what is desired by the auditors regarding exactly what is meant by"... Centralize (grants) to the extent practicable". The Grants Depattiiient has acquired a computerized Grants Monitoring System which alerts that coordinator to upcoming deadlines. The Department also receives bimonthly trial balance reviews which are used to reconcile grant expenditures and revenue receipts for comparison with the reimbursement requests and support documentation. A monthly report is accordingly prepared for review and analysis by the Grants Management Director and County Administrator. All grants over which the Grants Department has authority or oversight are in the proper order, If the auditors believe otherwise, please provide the specifics. On May 13, 1993, a request was originated for a copies of all grant contracts, financial reports and related items held by the individual departments. This information will be incorporated into the computerized grants monitoring system and appropriately utilized. The grants management department is the point of contact designated to respond to requests for information regarding grant programs. However, the Airport and Social Services programs, due to their uniqueness, have their own staff who serve as additional points of contact. The grants department areas of responsibility are clearly defined as reflected in the Strategic Plan for Grants Procurement and in the respective position descriptions of the Grants Department employees. It is therefore requested the Auditors provide specifics as to where there appears to be"...some confusion as to the areas of responsibility between the recipient department and grants management department. "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) MEMO FROM COUNTY ADMINISTRATOR TO CLERK OF COURTS dated July 28, 1994: IN REGARDS TO ANNUAL AUDIT FOR YEAR ENDING 9/30/93 GRANTS: Overall, grants functions continue to be somewhat decentralized due to the history of the handling of grants and the difficulty of establishing a Grants Management Depailruent with limited resources. Recently, an internal audit was requested of the Clerk of the Court's office and such a draft audit has been completed. Responses to that performance audit are being prepared and will be submitted shortly to the Clerk of the Court so that a final audit document can be prepared. Similar comments were made in reference to the grants function there. • The computerization of the Grants Monitoring System has greatly aided in the monitoring of the grants over which the Grants Management Department has direct control. There has been improvement in compliance reporting and cash flow management in reference to those grants. However, the unique nature of many of the major grant functions including Airports, Growth Management and Social Services, and the large amounts of work involved with the monitoring and management of those grants required that they be handled within the respective divisions charged in those subject areas. This means that there are staff available who are familia with the grants, and who are available to provide information, compliance, et. It is not possible for the collection of grants of that size to be the general responsibility of a two to three person Grants Department. There will be efforts in the future to assure that all grants are managed and • monitored to the highest standards. If the auditor has specifics which need to be addressed, it would be appreciated if they would be forwarded to the County Administrator. Grants 1. It is the policy of the Administration that single audit funds will ultimately be responded to and resolved by the County Administrator. Once those findings have been made known to the Administrator, they will be reviewed by the appropriate staff with recommendations and proposed responses to the Administrator. Any formal responses required will then be submitted. 2. It is the County's policy to request grant reimbursements in conjunction with the official County records. With each Division/Department dealing with the grants, there is an individual identified who is responsible for the maintenance of the grant records in conjunction with the official records of the County. All Division/Departments will be advised by the Administrator that their grant reimbursement request must be in conjunction with the official County records and that an appropriate audit trail be available. "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) INDEPENDENT AUDITORS'REPORT ON THE INTERNAL CONTROL STRUCTURE AND MANAGEMENT COMMENTS BASED ON AN AUDIT OF THE GENERAL PURPOSE FINANCIAL STATEMENTS BYKEMP& GREEN FOR YEAR ENDING 9/30/93 DATED 2/28/94 Management comments reported in prior years reports but not implemented as of 9/30/93: GRANTS: Observation: Grants appear to be under the direction of the recipient department and monitored to some degree by the grants management department. We have noted wide variation in the quality of management, compliance procedures, reporting procedures and cash flow management. Further, there seems to be some confusion as to the areas of responsibility between the recipient department and grants management department. Recommendation: Grants management should be centralized to the extent practicable to insure consistency with County policies, contract requirements and financial reporting requirements. In addition, it should also provide review procedures relative to the preparation of reports, budget set up and contract compliance independent of the recipient department. A point of contact should be designated to respond to requests for information. Grants: Observation: Two Single Audit findings have recurred for a number of years. It appears that there is no procedure in place for designating the responsibility for resolving single audit findings. Recommendation: A policy should be developed which designates the responsibility for resolution of these findings. Observations: The county received a major reimbursement grant which was allocated between two funds. Cost centers could not be readily located which supported the allocation of the grant between the funds or which supported the amount of funds reimbursed. The reimbursement request submitted to the grantor consisted of copies of original invoices and was prepared without reference to the official books and records of the County. Although further research determined that the expenditures requested were appropriate, there was not an adequate audit trail between the funds received and expended for a portion of the grant. Recommendation: Requests for grant reimbursements should never be developed independently of the County's official financial records. County procedures require that cost centers and budgets be created for all grant funds received. The appropriate level of management should be responsible for the coordination of the grant contract with the financial records to provide the necessary accountability. "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) MEMO FROM MARY CLEVENGER, FINANCE DIRECTOR TO SHERIFF RICHARD D. ROTH DATED JUNE 14, 1994 RE INTERNAL ACCOUNTING CONTROL MEMO RESPONSES FOR YEAR ENDING 9/30/93 ANNUAL AUDIT Grant Accounting: As a result of procedures perfoiiued as part of the BOCC Single Audit, we reviewed the State Crime Lab grant and the Federal DARE grant. These grants provide some of the funding for the Sheriff's budget. There is not a clear audit trail between expenditures per the Sheriff's financial records and expenditures per grant reports The monies received from the grants are received by the County. The expenditures are budgeted and expended by the Sheriff's Office. We maintain a separate manual file system for all disbursements and reports and will be changing to a computerized system in October, 1992. The money for the State Crime Lab Grant is received by the County on a quarterly basis and there is no reimbursement request required to receive the money which is based on a calculation by FDLE The expenditures for the Crime Lab are maintained on Lotus spreadsheets. The County has copies of all records necessary for the DARE grant. The State Auditor who has reviewed the records which we maintain here has, for the last two years, commended the Finance Assistant responsible on her record keeping. GRANTS COORDINATOR: The Sheriff is receiving a significant amount of federal and state funds from various sources. As a result, numerous compliance and reporting requirements must be met. Presently, no single person is responsible for monitoring the Sheriff's compliance with the general and specific requirements associated with these federal funds. In addition, documentation of grant agreements and requirements does not appear to be accumulated in such a way as to make such monitoring easily accomplished. The Sheriff has designated one individual to act as Grants Coordinator and Finance has designated one person to be responsible for the financial compliance and documentation. GRANT ACCOUNTING: Four instances were noted where the Sheriff requested reimbursement from FEMA under the Hurricane Andrew grant for repairs and supplies using prices from purchase orders. Actual expenditures should have been used to request reimbursement under this grant agreement. The FEMA grants was audited by both the State and Federal auditors and they were provided with all necessary documentation required and fully reimbursed all claims except for damages and repairs on two vehicles which were minor. The items addressed were for Fix a Flat and tires which were of an immaterial amount to the overall claim and to which a specific invoice could not be identified as these were items from the Supply Store. The situation was an emergency and "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) procedures for such an event had not been planned for. In the event of another such emergency, we will be better equipped to handle the claims submitted. INDEPENDENT AUDITORS'REPORT ON THE INTERNAL CONTROL STRUCTURE AND MANAGEMENT COMMENTS FOR YEAR ENDING 9/30/94-NO COMMENTS IN REGARDS TO GRANTS. MEMO FROM COUNTY ADMINISTRATOR TO CLERK OF COURTS dated June 10, 1996 IN REFERENCE TO MANAGEMENT COMMENT LETTER FROM INDEPENDENT AUDITOR FOR YEAR ENDING 9/30/95 GRANTS Observation: A single audit finding relative to vendor contracts funded by Federal Grants has recurred for a number of years. It appears that there is no procedure in place for designating the responsibility for resolving single audit findings." ANSWER: The administrative instruction that governs the grant application and monitoring process will be amended to indicate that OMB Grants section will be responsible for determining, through the County Administrator, how single audit findings are to be resolved. MEMO TO CHARLES LESTER, STATE AUDITOR GENERAL FROM EVA LIMBERT, FINANCE DIRECTOR OF SHERIFF'S DEPARTMENT DATED JUNE 13, 1996 IN RESPONSE TO INDEPENDENT AUDITOR'S MANAGEMENT LETTER: SUBMISSION OF GRANT REPORT The standard HIDTA grant agreement requires the submission of a semiannual reports. The Sheriff grants coordinator received a verbal waiver of these reports from the HIDTA contract manager. We were able to obtain confirmation of compliance in this area from HIDTA. However the Sheriff had no documentation of a change in the terms of any HIDTA contracts. The grant coordinator is helping to make sure that all future waivers a re documented and sent to our legal division so that the grant contract can be properly amended. YEAR ENDING 9/30/96--KEMP& GREEN NO COMMENTS RELATED TO GRANTS "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) MEMO FROM COUNTY ADMINISTRATOR TO CLERK OF COURTS DATED AUGUST 17, 1998 IN RESPONSE TO MANAGEMENT COMMENT LETTER FROM INDEPENDENT AUDITOR OF YEAR END 9/30/97 ANSWER TO AIRPORT GRANT REVENUES OBSERVATION: Airport management has reviewed the recommendations and is making efforts to comply. ANSWER TO SOCIAL SERVICES OBSERVATION: Social Services management has reviewed the recommendations and is making efforts to comply. KEMP& GREEN LETTER TO CLERK/BOCC for YEAR ENDING 9/30/97 CURRENT YEAR FINDINGS: dated 2/7/98 Airport Grant Revenues: Observation: Significant grant receivables were recorded based on the amounts expended on a project and the portion of the expenditures available for grant funding. Significant amounts of these receivables have not been collected to date because reimbursement requests had not been filed by the airport accountant. According to the airport accountant, the grantor had asked her to not request the funds until the amounts became "significant." Although the amount for each grant might not to considered significant, the aggregate unrequested amount was significant. Recommendation: it is reasonable to comply with grantor requests when practicable. However, staff should consider the impact on the County. Reimbursement requests should be submitted on a routine basis, at least quarterly, in order that the County has access to all available funds. Observation: It appears that the reimbursement requests prepared and filed by the airport accountant are not prepared from financial information reported in the general ledger and such requests are not consistently compared to the general ledger before they are submitted for reimbursement. There were eligible expenses which had not been requested for reimbursement. Reimbursement requests are not presently reviewed prior to submission nor are copies of the reimbursement requests sent to the Financial Department for the accounting records. Recommendation: Reimbursement requests should be reviewed before they are submitted to insure that all eligible costs are requested and that the reports are in agreement with the County's official books and records. Federal Grants Payroll: Observation: Employees whose salaries are funded by federal grants are not completing time certifications as required by the Common Rule. The amount of payroll is not significant to the federal grant. County staff has not been able to agree as to whose duty it is to implement the new requirement. r "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) Recommendation: Responsibility should be determined for designing procedures to insure compliance. Payroll certification procedures should be implemented to meet federal funding requirements. MEMO FROM THOMAS FAVENEL, FINANCE DIRECTOR OF SHERIFF'S OFFICE TO CHARLES LESTER, STATE AUDITOR GENERAL dated May 25, 2000 in response to Independent Auditor's Management Letter FOR YEAR ENDING 9/30/99 Grant Revenues: "The Sheriff received two small grants. Once was recorded as miscellaneous income; the other was netted against expenditures. Sheriff staff did not know if the grants were from federal or state sources or if there was a related Catalogue of Federal Domestic Assistance Number required for Single Audit reporting. This accounting treatment was inconsistent and did not permit compliance with grantor reporting requirements for the Sheriff's financial statements." Response: Appropriate revenue accounts have been established in the general ledger to record grant revenue. Finance staff has been trained on the appropriate recording of grant revenue. In addition, a procedure has been established to identify the source of all grants, as well as the CFDA Number. Page 28 of the Single Audit Report Management's Comments: Grant Revenues Recommendation to the above: At the time the grant is recorded, Sheriff staff should have the information necessary for Single Audit reporting requirements. All grants should be recorded as intergovernmental revenue. March 10, 2000 letter from KEMP& GREEN to the CLERK/BOCC REGARDING YEAR ENDING 9/30/99 Social Service Grants Payroll Observation: Employees whose salaries are funded by federal grants are not completing time certifications as required by the Federal Office of Management and Budget Circular A-87, Cost Principles for State, Local and Indian Tribal Governments. The amount of payroll is not significant to the federal grant. Recommendation: The procedure should be implemented to meet federal funding requirements. County's Response was "Administration will request that Finance review provisions in OMB Circular A-87 for possible substitutions of equivalent documentation, i.e. Allocation of costs based on random moment statistical sampling, to replace the more costly, time-consuming daily time reports. Pending such review, the Administration will request that Finance provide the appropriate sampling or payroll forms and written procedures for grant employees, including Social Services grant employees. "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) MEMORANDUM FROM SHERIFF TO CHARLES LESTER, STATE AUDITOR GENERAL dated July 13, 2001 in REFERENCE TO ANNUAL AUDIT YEAR ENDING 9/30/00 Grant Revenues: "The Sheriff received a small grant which was recorded as miscellaneous income. This accounting treatment is inconsistent with other grant revenues received and does not permit compliance with grantor reporting requirements for the Sheriff's financial statements." RESPONSE: The appropriate persons have been educated on differentiating grant revenues from miscellaneous income, and the proper recording thereof. MEMORANDUM FROM COUNTY ADMINISTRATOR TO CLERK OF COURT dated April 26, 2001 IN REFERENCE TO MANAGEMENT COMMENT LETTER FROM INDEPENDENT AUDITOR FOR YEAR ENDING 9/30/00 "Grant Reports for FEMA and airport improvements were prepared and submitted based on estimates or accounting records maintained by the department preparing the grant revenue request. The reports did not agree to the general ledger. In some instances, the department will identify differences but not resolve them. Accordingly, because of the lack of reconciliation procedures, some grant revenues were deferred until the reports could be reconciled. Answer: Airport Management has reviewed the recommendations and is making efforts to comply. INDEPENDENT AUDITORS'MANAGEMENT LETTER DATED 3/13/02 BYMARVA GREEN FOR FYENDING 9/30/01 ADDRESSED TO CLERK AND BOCC: NOT IMPLEMENTED AS OF 9/30/01 REPORTED IN PRIOR YEAR'S MANAGEMENT REPORT Interdepartmental Communication Observation: Several service units for the Community Care for the Elderly grant (CCE)were disallowed pursuant to the grantor's programmatic monitoring. The amount of the related refund was not significant to the grant. The County staff was notified of the refund in early January, 2000. The refund had not been paid nor has the refund been recorded as a payable, although the County staff did not dispute the grantor findings. There is some dispute within the depaitiiient as to who is responsible for resolving the dispute. "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) Recommendation: any monitoring results that have a financial impact should be communicated to the Finance Depaitiiient on a timely basis for entry into the financial records. Management should designate a staff member to resolve the disputes. Observation: Grant reports for FEMA and airport improvements were prepared and submitted based on estimates or accounting records maintained by the depaitiuent preparing the grant revenue request. The reports did not agree to the general ledger. In some instances, the department will identify differences but not resolve them because of the lack of reconciliation procedures. Some grant revenues were deferred until the reports could be reconciled because of the lack of reconciliation procedures. Reconciliation's were still in process at March 13, 2002 causing delays in the year-end closing procedures, financial statement preparation and Single Audit reporting. Recommendation: Before these grant reports are submitted to any grantor, a reconciliation to the general ledger should be documented. Differences identified should be resolved before the reports are submitted. Reports should not be submitted without approval from the finance department to insure that a report was successfully reconciled to the general ledger. Outstanding reconciliation's should be given priority. Observation: FEMA receivables relative to the period immediately following Hurricane George have not been collected to date. Recommendation: The appropriate level of management should assign responsibility for the prompt collection of these amounts. CURRENT YEAR FINDINGS: GRANTS RECEIVABLE: Observation: A FEMA receivable from the year 2000 is still outstanding. There was no documentation provided to us as to whether the funds have been requested. Most of the 2001 FEMA receivables have not been collected to date because funds have not been requested. Staff claims that the requests for 2001 have not been made because the projects are not complete or the contract is being renegotiated. It appears that staff is not focused on collecting funds to recover Board expenditures. Recommendation: The present accounting system provides "project reports" on each grant which can include expenditures and cash collected to date. The appropriate level of management should review these reports to determine that collection efforts are adequate. "EXHIBIT G" Management Comments on Internal Controls from Annual External Audits - (Grants Only) MEMO FROM COUNTY ADMINISTRATOR TO CLERK OF COURT DATED JUNE 28, 2002 IN RESPONSE TO MANAGEMENT COMMENTS FROM INDEPENDENT AUDITOR FOR YEAR ENDING 9/30/01 Interdepartmental Communication: Observation: Several service units for the Community Care for the Elderly grant(CCE) were disallowed pursuant to the grantor's programmatic monitoring. The amount of the related refund was not significant to the grant. The County staff was notified of the refund in early January 2000. The refund had not been paid nor has the refund recorded as a payable, although the County staff did not dispute the grantor findings. There is some dispute within the department as to who is responsible for resolving the dispute. Answer: Management will direct the Senior Director Social Services to review grant and prepare paperwork necessary to issue refund. Observation: Grant reports for FEMA and airport improvements were prepared and submitted based on estimates or accounting records maintained by the department preparing the grant revenue request. The reports did not agree to the general ledger. In some instances, the department will identify differences but not resolve them because of the lace of reconciliation procedures. Some grant revenue was deferred until reports could be reconciled because of the lack of reconciliation procedures. Reconciliations were still in process at March 13, 2002, causing delays in the year-end closing procedures, financial statement preparation and Single Audit reporting. Answer: Management recognizes the improtance of these issues. Management is looking at ways to improve the compliance of all grants. Grants Receivable Observation: A FEMA receivable from the year 2000 is still outstanding. There is no documentation provided to us as to whether the funds have been requested. Most of the 2001 FEMA receivables have not been collected to date because funds have not been requested. Staff claims that requests for 2001 have not been made because the projects are not complete or the contract is being renegotiated. It appears that staff is not focused on collecting funds to cover Board expenditures. Answer: Management is very focused on collecting funds due to the Board. During 1992 the BOCC created a Grants Department with 3 employees. After reorganization in 1994 this department has been reduced to 1 employee. We believe that with the addition of a Grants Acquisition Administrator there is a real need for additional support function to adequately monitor all grants received by the County. VII. Auditee Response , ;; €� e�� BOARD OF COUNTY COMMISSIONERS _—.it, .i ,er MAYOR Charles"Sonny"McCoy,District 3 O U N TY o fM 0 N R 0 E —f� ��'r Mayor Pro tem Dixie Spehar,District 1 KEY WEST FLORIDA 33040 �• �`7/. 4• i; George Neugent,District 2 (305)294-4641 .,;.;`• , , ,.;.,'• Bert Jimenez,District 4 4, 'r.;• : ,z . ..I„S, Murray E.Nelson,District 5 Monroe County Administrative Services 1-7 , ,., 1100 Simonton Street } �, Key West, FL 33040 = ,; ff'� (305) 292-4470 MEMORANDUM • -- To: Danny Kolhage Clerk of Court - From: James L. Roberts County Administrator • Subject: Bike Path Coordinator Grant Internal Audit—Letter of July 18, 2002 Date: October 21, 2002 The Administration has reviewed the comments by the Internal Audit Department regarding internal controls of Grant Management. The following are our comments in reference to that report: General Comments There is confusion on the titles of the personnel interviewed. - OMB Senior Director: That position was eliminated in 2002. I believe you mead __ Director of Administrative Services if you are referencing conversations with Sheila A. Barker. . Growth Management's Personnel Director. We have no such title. I believe you mean Coordinator Budget and Personnel if you are referencing conversation with Mayra Tezanos. Bicycle Path Coordinator should be changed to Bicycle and Pedestrian -- Coordinator/Planner in all references. Exhibit G, Summary of past 15 years of Management Comments, contains comments from audits of grants secured and administered by the Sheriff's Office. The County Administrator has no control over these grants and are therefore irrelevant to this audit. 1 . A. Progress Report Filings Findings Progress reports are required by contract to be submitted on a quarterly basis. Expenses under Contract #1/AG-851 began to appear in the general ledger in October, 1999 which means the first report should have been submitted on or before December 31, 1999 and then again on or before March 31, 2002, June 30, 2000 and the second was filed on September 6, 2000. Seven months elapsed before the first report and then four months for the filing of Report number 2. To date a final reporting has not been submitted to the State. Verbal communications with the State's representative have confirmed that no final reporting has been submitted. (See Finding E). Expenses under Contract AI-931 began to appear in the general ledger in May, 2001 (however, these expenses were recorded to the wrong account which were posted as early as November, 2000. (See Finding E). Reports should have been filed on or before January, April, July and October 2001 and January, April, July and September 2002 when the contract expires. Actual reports were submitted on May 23, 2001, November 6, 2001, and May 22, 2002 respectively. According to the Bicycle Path Coordinator, the State representative verbally requested the Coordinator to submit the reports on a six-month basis. It is reasonable to comply with a grantor's request when practicable; however, staff should consider the impact on the County. Reporting should be submitted on a routine basis according to the terms and conditions of the contract to avoid the risk of non-compliance. Both parties must agree in writing to modify any contract. Non-compliance could result in delaying the receipt of grant funds as well as other risks should either agency have personnel turnover. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations. Review of Recommendations: , • 1. The Administrator agrees that progress reports should be submitted according to the terms of the grants. 2. The Administrator agrees that any time it appears that compliance with the terms of the grants is not reasonably possible, a formal written extension of due dates should be requested and obtained. 3. The Administrator agrees that all modifications to agreements will be done in writing. 2 B. Reimbursement Requests Findings: According to the agreements, requests for reimbursement should be filed quarterly. Reimbursement requests for grant funds for bicycle path coordinator position have not been consistent with those terms. According to Bicycle Path Coordinator, the grantor had asked her to request the funds on a six-month basis. It is reasonable to comply with a grantor's requests when practicable. However, staff should consider the impact on the County. Reimbursement requests should be submitted on a routine basis, at least quarterly, in order that the County has access to all available funds. Responsibility for this should be assigned such that management control is maintained over revenue, all reimbursable costs are claimed and cash flow is maximized. Turnover in the Bike Path Coordinator position precipitated the late filing of reimbursement requests. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations. Review of Recommendations: 1. The Administrator agrees that reimbursement requests should be submitted according to the terms of the agreement. 2. The Administrator agrees that any modification to the agreement should be made in writing. 3. The Administrator agrees that the appropriate level of management should review all reimbursement requests to ensure compliance with the grant contract. The Administrative Instruction will be modified to include this recommendation. C. Official County Records Finding: Official County records should be used to reconcile and prepare reimbursement requests to the State. Five requests were submitted for reimbursement to the State; the auditors reviewed all of them. There were no official records submitteiPas part of.any of the five requests. Items submitted as supporting documents were expenses paid through accounts payable. Items -such as salary/wages, workers' compensation, insurance benefits and taxes, had no evidence supporting those expenses although the County was requesting reimbursement for those expenditures. Two invoices were submitted under the first Contract (AG-851/GW9910). Invoice #1 was submitted on 4/10/00 and rejected for non-compliance. It was corrected, resubmitted, and approved and paid by the State of 4/26/00. On 9/6/00, five months after the Bicycle Path Coordinator resigned, management submitted the second invoice. A different State 3 representative reviewed the second invoice and approved as submitted even though official county records were not submitted as supporting documentation. On 10/27/00 a replacement was hired for the Bicycle Path Coordinator position. Invoices under the second contract were submitted by the new coordinator beginning on March 23, 2001. The second invoice submitted under Contract #2 was submitted and rejected by the State for non- compliance. Official County records were not reconciled or used as supporting documentation as required by the agreement. As a result, ten months of expenses were posted to the wrong project number from September 2000 through June 2001. The mistake was not discovered until it appeared the County forfeited $29,228.10 in reimbursement funds due to the expiration of the contract. Another issue arising from this mistake was that Finance personnel made improper accruals at the end of the fiscal year 2001 which resulted in that same amount being recognized on the year-end financial statements and single audit report. Due to lack of reconciling and submitting the official county records as part of the reimbursement request, the County under billed the sate by$3,083.60. The third invoice submitted under Contract #2 was submitted and rejected by the State for non- compliance. After correcting the $29,229.80 error, total expenses through March 2002 totaled $91,358.37; however, by using internally prepared documents instead of the County's official records; the County has over billed the state by$2,020.12. Although three of the five invoices were rejected, they were not all rejected for the same reason. The State does not review the submitted invoices on a consistent basis. For example, under Contract #1 the invoice was rejected because a completed invoice summary was not provided, the lack of acceptable number of copies with sufficient supporting documents, the lack of a progress report and the lack of a completed invoice summary. Under Contract #2, invoice #2 was rejected for requesting reimbursement on Class C Meals not reimbursable by the State in fiscal year 2002. Invoice #3 was rejected because the Program Manager signed the request. According to the State, the request should be signed by a Supervisor or Department Head. A second reason given was that each invoice should send supporting documentation such as the County's official records. Four of the five invoices were signed and submitted by the Project Manager; only one was rejected for the lack of a Supervisor or Department Head signature. If the over billings is not corrected before the end of the fiscal year, the financial statements and single audit reports issued by the County will be in error and the County could be found in breach of its agreements with the State for non-compliance of the terms and conditions. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations except where noted below. 4 Review of Recommendations: 1. Official county records should be used as part of the required supporting documentation. Although it can be surmised what constitutes "Official County" records, it would have been helpful to identify specifically some examples in the "Findings". In addition, the statement in Paragraph 4 of the findings, it is asserted that the County forfeited funds is misleading. It is true that the County did not spend all of the grant funds; however, the County did not have any expenses for which it was not reimbursed. 2. Internally generated documents are helpful on routine items, but reimbursement requests will be tied to official county records in the future. 3. County policies will be followed when requesting reimbursement. D. Timely Deposits Findings: A check in the amount of$18,038.97 was deposited seven (7) months after receipt. Reimbursements should be deposited as quickly as possible, but in any event, not later than three (3)business days from receipt according to Administrative Instruction#1013.1. The time lag between filing for reimbursement and the deposit of funds to the County's bank account should be kept to a minimum. Invoice#1 was submitted to the State for reimbursement on 5/23/01. The state issued and dated the check on June 27, 2001. Finance received the check from Growth Management on February 5, 2002 and immediately deposited the same. The check was obtained due to a third party agency contacting the Finance Department of an $18,038.87 receivable owed to the County. For a fee, this agency offered to collect and submit the moneys on behalf of the County. As a result of this notification, the Finance Department enlisted the help of the Internal Audit Department. The Internal Audit Department immediately began steps to identify those same funds. After several inquires into the matter, the internal audit department determined which Department was expecting the funds. As a result, the County lost interest on those funds and ran the risk of the check being voided after a certain number of months without being cashed(12 months for the specific check in question). County Administrator's Response: The Administrator concurs with-the Auditor's findings and recommendations Review of Recommendations: 1. The Administrator agrees to remind employees of Administrative Instruction 1013. Funds should be deposited within three (3)business days. 2. The Administrator agrees that all funds should be transferred by Electronic Funds Transfer. The Growth Management Division advises the Administrator that they requested EFT be used by the Grantor but was told that it was not available for this program. 5 • E. Close out Grant(s) Findings: Due to turnover at the department responsible for the grant, the Finance Department was not properly notified of the closing of Contract #1: AG-851/GW9910. As a result, grant receivables were accrued at the end of the year. In addition, these amounts were posted to the wrong grant and project. During the course of this audit, the Finance and Audit Departments discovered the discrepancies. These expenses were not reclassified to the proper project number until June 2002; two years after the last activity. According toe Monroe County Administrative Instruction #4301.4 —Basic Procedures for Filing Grant Applications revised 10/01/2000 has an instruction related to project close-outs (4) Instructions: J) The project close-out shall be handled in the following manner: a final status report shall be forwarded to the Board of County Commissioners, all grant invoices shall be reconciled with project expenditures and grant revenues, and all project reports and claims shall be filed with the granting agency. As of June 26, 2002, no final report has been submitted to OMB or to the State Department of Transportation according to the terms of the contract to finalized Grant/Contract Number AG- 851/GW9910. This lack of reporting resulted in expenditures being accrued at the end of Fiscal Year September 30, 2001. It also resulted in $29,228.10 of expenditures being improperly coded to the wrong project and grant which were not properly identified until June 2002 during the course of the internal audit. A final status report to the BOCC as required under Administrative Instruction 4301.4 (J) should have been completed. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations. Review of Recommendations: 1. The Administrator agrees that County Administrative Instruction #4301.4 (J) Project close- out procedures will be followed. 2. The Administrator agrees that reconciliation of expenditures should be based on Official County Records and be reviewed at an appropriate management level. 3. The Administrator will have staff review the possibility of using a standard data sheet. 4. The Administrator agrees that we should comply with the Administrative Instruction and furnish a final status report to the BOCC. 6 F. Forfeiture of Grant Findings: With Contract #1, the State committed 80% of the total grant amount or $57,000 to the County for the Bicycle Path Position. The County used $32,786.90 of the available funds before switching to the next available grant. The lack of reconciliation and monitoring of the County's official records and turnover within the position forced this result to occur. The effect upon the county was the loss of State Funding in the amount of$24,213.10. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations, except that a forfeiture did not occur, only not being able to use all the fund in the time allocated. Review of Recommendations: The Administrator agrees that it should be the decision of the Administrator and/or the BOCC on forfeiting a grant, should that ever occur. G. Reconciliations/Monitoring Grants Findings: Reimbursement request have been calculated and submitted using internal documentation. The requests are not prepared from financial information reported in the general ledger. Such requests are not consistently compared to the general ledger before they are submitted for reimbursement. As a result, the amounts being requested do not tie to the County's official reimbursement. Reimbursement requests are not presently reviewed or monitored prior to submission nor are copies of the reimbursement requests sent to the Financial Department for the accounting records. The reimbursements requested to date for two Bicycle Path Coordinator grants through March 31, 2002 exceed the actual expenditures by $2,020.12. The County's financial statements are in error due to the filing of incorrect reimbursement amounts. County Administrator's Response: The Administrator concurs with the Auditor's findings and recommendations Review of Recommendations: ti 1. The Administrator agrees that the reimbursement requests should be reconciled, reviewed and approved by the appropriate level of management utilizing the County's official records. 2. The Administrator agrees that all differences discovered during the reconciliation process should be corrected. 3. The Administrator agrees that the grants should be monitored by an appropriate level of management. 4. The Administrator agrees that reconciliation should occur on a routine basis and certainly on the frequency required by the grant. 7 5. The Administrator agrees that transactions should be updated accurately and with the appropriate level of managerial review, believes they will be. H. InitialTraining—Grant Procedures Findings: All employees responsible for the administration of grant funds should receive sufficient training of the County's Grant Procedures. These employees should be educated on the terms and conditions of the grant, become familiar with the funding agency's rules governing expenditures, reimbursement request policies. Employees should also be educated on the use of the County's official records and how to read and interpret them. The replacement Coordinator hired in October 2001 was considered the new "Project Manager" responsible for the two outstanding grants. According to conversations with the replacement, she understood that she was hired strictly under the funding of Contract#2. She was under the impression that Contract #1 was closed prior to her start date. Issues resulting from the lack of training and monitoring by the project monitoring system detailed in Administrative Instruction#4301.4 (I) are: 1. Expenses totaling $29,228.10 were improperly coded to the wrong project and grant. 2. The County forfeited$24,213.10 in reimbursable State funds. 3. Year-end Financial Statements and Single Audit Reports for years 2000 and 2001 included the above errors (The errors were corrected.) 4. Three of the five invoices were rejected by the State and delayed the receipt of County funds. 5. A check in the amount of $18,038.87 went uncollected for more than seven months even though the County requested the reimbursement. 6. Request for reimbursements are including non-refundable expenses. Established internal controls for centralization of Grant Management are inadequate and ineffective. In practice, the majority of County Departments is not in compliance with the established administrative instructions. On paper, the County has established an adequate system for monitoring all grant programs for compliance with federal, state, and local general and specific grants requirements; however, according to management personnel, it is not practiced or enforced. OMB personnel informed the internal auditors that the lack of personnel, time and funding were the main reasons why the County cannot enforce its own Administrative Instruction#4301.4. The major risk to the County will be that once a grant is procured, the potential for losing the funding is significantly increased due to lack of monitoring and non-compliance with the agreed upon terms and conditions of individual contracts. It may benefit the County to have part of the Grants Management team receive monitoring certification as part of their responsibilities and to then train other Department supervisors or a representative responsible for maintaining their own departmental grants. By implementing a continuous training and education for personnel directly responsible for a grant, it may help 8 eliminate the continuous year end management comments on the independent audit. For the past 15 years, the County has had one or more grant related issues at each year-end. County Administrator's Response: The Administrator concurs that there is room for vast improvement for the manner in which grants are handled. The comment attributed to OMB that there was not time, personnel or funding to enforce their own policies was a recap of the history of the department. The focus on grants has differed greatly over the past decade. The BOCC established a separate Grants Department in 1992. The department was made up of 3 people. However, the BOCC reorganized Management Services in 1994 and the Grants Department was downgraded from department status to a section of the Office of Management and Budget. It was comprised of one staff position. In the future there will be additional training for those who handle grant reporting. Review of Recommendations: 1. The Administrator agrees there should be a position responsible for monitoring grants. Budget pressures and downsizing have precluded the establishment of such a position. Training as identified above will be utilized until a grant's accountant position can be established. 2. The Grants Administrator should have a copy of all grant agreement approved by the Board. This will enable the Grant Administrator to contact grant monitor with information regarding Administrative Instruction #4301. Training of specific grant handling is the responsibility of the department securing the grant. 3. Administrative Instruction #4301 should be followed by all grant monitors, but especially reviewed by Department Heads with enforcement and signature responsibility. 4. Written communication will be encouraged where appropriate. 5. Grant monitors will maintain sufficient documentation of grant activity. 9