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Item R4 R4 BOARD OF COUNTY COMMISSIONERS COUNTY of MONROE �� i Mayor Holly Merrill Raschein,District 5 The Florida Keys Mayor Pro Tern James K.Scholl,District 3 Craig Cates,District 1 Michelle Lincoln,District 2 ' David Rice,District 4 Board of County Commissioners Meeting November 19, 2024 Agenda Item Number: R4 2023-3146 BULK ITEM: No DEPARTMENT: Administration TIME APPROXIMATE: STAFF CONTACT: Christine Hurley n/a AGENDA ITEM WORDING: Discussion of Monroe County Clerk of Circuit Court & Comptroller Internal Audit Report, Audit of Personal Use of County Owned Vehicles 2024-003. ITEM BACKGROUND: The County received a Draft Monroe County Clerk of Circuit Court& Comptroller Internal Audit Report, Audit of Personal Use of County Owned Vehicles 2024-003 on August 7, 2024. County staff worked to provide a response to the various questions/recommendations. Assistant County Attorney Nathalia M. Archer submitted the County's response on September 5, 2024. On September 9, 2024, the final audit was circulated to County staff and Commissioners. There are a variety of recommendations that will take time to implement, and we will keep the Board updated as we progress through development of a revised Administrative Instruction 4713.6, Use of County Vehicles. Because there are multiple findings and tax law implications, the policy will need substantial revision. Once finalized, we will begin implementation of the new policy changes to address the recommendations. Further, the County Administrator met with the Clerk's office to determine whether the Clerk's Workday software would be useful to automate the processes County staff members follow to be compliant with the policy. Attached is a table demonstrating the findings from the audit, as well as a status report for each item, as of 11/4/24. PREVIOUS RELEVANT BOCC ACTION: n/a INSURANCE REQUIRED: No CONTRACT/AGREEMENT CHANGES: n/a 4412 STAFF RECOMMENDATION: n/a DOCUMENTATION: 2024-003 Audit of Personal Use of County-Owned Vehicles 4713.7 Use of County Vehicle Admin. Instruction.pdf Personal Use of County Owned Vehicles Audit Table 10.28.24.docx FINANCIAL IMPACT: n/a 4413 0 0 Monroe County Clerk of circuit Court & Comptroller Internal Report UA COOS 0 0 Audit of Personal Use of county-Owned Vehicles 2024-003 f ' 1 �f mom" �IIII�,'a�� Will B�B�NY4I�NI��U�� V�V�K��11V1�1��0�@ �6�4� �V�� uYN��tllulululululu��V@1�I��Itl��Nl d �110�1 tl110��tliNtliNtliNtliNtliNtliNtliNtliNtli�l��lu�➢�Iu��V@1�IN➢�lu��ltl�� H��@9N�N➢ H�u� H�u� H��\��Nr��1�� CIA W 500 Whitehead Street Key West FL 33040 305 292-3550 1 Monroe-Clerk.com 4414 Report 2024-003 September 2024 Monroe County Clerk of Circuit Court & Comptroller Kevin Madok, CPA Interim Internal Audit Director Pain Radloff Auditor Noah Browning About Monroe County Clerk's Internal Audit Department As part of the Clerk's constitutional responsibilities, the Monroe County Clerk's Internal Audit Department provides independent, accurate, and timely audits of Monroe County government's business activities, operations, financial systems, and internal controls. Internal Audit's audits and consulting services are designed to add value, increase efficiency of operations, advance accountability, and improve stewardship of public resources. Monroe County's Internal Audit Department accepts confidential tips about fraud, waste, and abuse in Monroe County government or programs through its hotline (305)292-5760 or at hl'tps://monroe-clerl<-.com/fraud-waste-abuse. 4415 Kevin Madok, cPA . r Clerk of the Circuit Court&Comptroller-Monroe County,Florida September 9, 2024 The Honorable Mayor Holly Raschein Monroe County Board of County Commissioners 102050 Overseas Highway, Suite 234 Key Largo, FL 33037 Email: boccdis5@monroecounty-fl.gov Dear Mayor Raschein: The Monroe County Clerk's Internal Audit Department completed an audit of personal use of county-owned vehicles by Monroe County Board of County Commissioner's(BOCC)staff for the three-year period October 1, 2020, through September 30, 2023. The audit reviewed adherence to Monroe County Administrative Instruction (MCAI) 4713.6, Use of County Vehicles. The administrative instruction requires that County vehicles may only be used for conducting county business. It also strictly prohibits an employee from using a county vehicle for personal convenience or gain. We reviewed compliance with MCAI 4713.6 and found that two County departments, Airports and Social Services, allowed staff to use assigned take-home vehicles for unauthorized and excessive personal use. We also found that, because there is no centralized oversight of County- owned vehicles, there is inconsistent application of the County's policy including inconsistent reporting by employees of their personal use of vehicle for payroll purposes. Our report includes recommendations for strengthening oversight of employees' vehicle usage and required reporting. We appreciate the courtesy and cooperation extended to the Clerk's Office by BOCC departments and staff during the audit. Sincerely, Kevin Madok, CPA Monroe County Clerk of Circuit Court& Comptroller Cc: Board of County Commissioners Kevin Wilson, Acting County Administrator Bob Shillinger, County Attorney Internal Audit KEY WEST MARATHON PLANTATION KEY 500 Whitehead Street 3117 Overseas Highway 88770 Overseas Highway Key West, Florida 33040 Marathon, Florida 33050 Plantation Key, Florida 33070 4416 Table of Contents Audit of Personal Use of County-Owned Vehicles Executive Summary..................................................................................... I Policies Governing Personal Use of County-Owned Vehicles...................2 Purpose and Scope of Internal Audit.........................................................4 No Centralized Management of County-Owned Vehicles .........................5 Unauthorized and Excessive Personal Use ................................................................................. 5 Inconsistent Application of Policy.............................................................................................. 9 Improving Compliance with Internal Revenue Service Regulations ........ 11 Inappropriate and Insufficient Quarterly Reporting.................................................................. 11 Unnecessary Tax Liability for Fire and Rescue Employees ..................................................... 12 Applying Appropriate Valuation Rule for Personal Use........................................................... 13 Appendix I Monroe County Administrative Instruction 4713.6............. 16 Appendix II Memo on KWIA and Fleet Services ...................................20 4417 Executive Summary The Monroe County Clerk's Internal Audit Department recently completed an audit of the personal use of County-owned vehicles. The audit reviewed adherence to Monroe County Administrative Instruction 4713.6, Use of County Vehicles. This administrative instruction was created to standardize procedures for all Monroe County Board of County Commissioners' employees to follow when they are assigned or use a County-owned vehicle. Specifically, employees are instructed that County vehicles will only be used for conducting county business and use of any County vehicle for personal convenience or gain is strictly prohibited. Our audit work included reviewing departmental compliance with the established policies and procedures. We sampled data to evaluate whether employees used their assigned County vehicles for personal purposes beyond the authorized daily commute. We also verified compliance with Internal Revenue Service (IRS) regulations which recognizes incidental personal use of County vehicles as a taxable fringe benefit to employees. While we found that most employees complied with the policy, our sample did identify some employees violated the policy with no consequence.For example,we provide detail of Airport and Social Services staff who regularly used their assigned County-owned vehicles for unauthorized personal reasons. We identified repeated instances where Airport and Social Services staff go to grocery and retail stores, schools,restaurants, and relatives' residences. We also discovered during our testing that the County's vehicles assigned to the Key West International Airport are not equipped, like other County vehicles, with Global Positioning System devices. Therefore, it was not possible to track specifically where and when Airport vehicles were in use. Consequently, our audit testing was limited but still showed evidence that Airport vehicles assigned to staff appeared to be used excessively for personal purposes. Our audit also found that there is no centralized oversight of County-owned vehicles. This has led to inconsistent application of the County's policies. Individual department managers have been delegated the responsibility to ensure compliance with the administrative instruction and it appears that department managers interpret and apply the instructions differently. We made recommendations to provide for a central authority to be tasked with ensuring there are periodic reviews and evaluations to verify staff assigned take-home vehicles continue to meet the established criterion for needing a take-home vehicle. Finally, recommendations were made to improve compliance with IRS regulations. This includes improving quarterly reporting by employees to capture their allowable personal use of vehicles (e.g., commuting as allowed per County policy) so appropriate taxes can be withheld. 4418 Policies Governing Personal Use of County-Owned Vehicles The Monroe County Board of County Commissioners (BOCC)has over 250 passenger cars/trucks that are used by employees to conduct county-related business. Most of these passenger vehicles are equipped with a Global Positioning System (GPS) device that monitors a vehicle's location and start/stop times. The GPS connects with the token to identify the driver. In total, 316 driver tokens are issued to BOCC employees. To govern the use of the BOCC's county-owned vehicles, the County Administrator issued Monroe County Administrative Instruction (MCAI) 4713.6, Use of County Vehicles A endix I) in March 2020. The purpose of MCAI 4713.6 was ". . . to establish standardized procedures for all employees to follow when assigning and/or utilizing County vehicles." MCAI 4713.6 provides specific instruction to BOCC employees regarding the use of county vehicles including: • County vehicles will be permanently assigned to only those employees whose responsibilities routinely take them from their normal workplace. • County vehicles will be used only for conducting county business. • Use of any county vehicle for the personal convenience or gain of a county employee is prohibited. • Authority for an employee to use a county vehicle to commute to/from the employee's home to the work site, shall only be granted when such a use is deemed essential to protect the health, safety, and/or welfare of the public. • The criteria for determining whether an employee is entitled to take-home a vehicle is whether the delay resulting from the employee having to first proceed to the workplace to access a county vehicle would be such that the health, safety, or public's welfare could be jeopardized. Moreover,to ensure compliance with Internal Revenue Service(IRS)requirements,MCAI 4713.6 directs BOCC employees to report on a quarterly basis the number of days they were authorized to take home a county vehicle. The IRS requires employers to prove that vehicles used by employees are being used for business purposes. If an employer cannot provide supporting records showing business use of take-home vehicles, then the IRS assumes that employees are using their take-home vehicles solely for personal reasons. In other words, if the BOCC does not have documentation to differentiate business use from personal use of the county's vehicle, the IRS — 2 - 4419 assumes all use of an employee's assigned take-home vehicle is a fringe benefit and subject to taxation as income. Finally, even though its stated purpose is to standardize procedures, MCAI 4713.6 does not assign a specific department the responsibility for overseeing compliance with the administrative instruction. It appears that each department manager has been delegated the responsibility to ensure compliance. MCAI 4713.6 does require BOCC employees to be alert for employee misuse of county vehicles and directs employees to immediately report such activity to the respective department and the County Administrator. However, there are no stated consequences if an employee violates this policy. After we completed our audit fieldwork, the Acting County Administrator issued an updated administrative instruction, MCAI 4713.7, on May 7, 2024, which replaced MCAI 4713.6. The updated instruction revised the policy to allow any person participating in County-sponsored recreational events,pre-approved by the County Administrator, to ride in any County vehicle. — 3 4420 Purpose and Scope of Internal Audit The Monroe County Clerk's (Clerk)Internal Audit Department completed an audit of the personal use of County owned vehicles. Our audit procedures included examining adherence to MCAI 4713.6 which governs the use of county vehicles, a review of GPS data for a sample of employees, a review quarterly use forms, and compliance with IRS regulations. The audited period was FY 2019 through FY 2023. Because of audit findings, the Internal Audit Department expanded the audit's scope to conduct an additional review through April 2024 of certain employee's use of vehicles and their compliance with policy. The scope of the audit included: • Reviewing departmental compliance with MCAI 4713.6; • Sampling GPS data for Monroe County employees (review limited to the seven-month period due to limited availability of data); and • Verifying compliance with IRS regulations regarding the tax liability associated with the personal use of a county owned vehicle. — 4 - 4421 No Centralized Management of County-Owned Vehicles The BOCC does not have centralized oversight over the use of take-home vehicles. Rather,county- owned passenger vehicles are assigned to BOCC departments and each department manager is responsible for vehicle assignments, usage, and compliance with MCAI 4713.6. Our audit found not only inconsistent and improper application of the BOCC's policies and procedures but also unauthorized and excessive personal use of county-owned vehicles by some employees. The lack of centralized management oversight appeared to also contribute to inappropriate and insufficient reporting of personal use by staff. Unauthorized and Excessive Personal Use MCAI 4713.6 states that county vehicles are to be used only for conducting county business. Use of any county vehicle for the personal convenience or gain of a BOCC employee is prohibited. As part of our audit procedures,we selected a sample of BOCC employees with GPS tokens to review their vehicle usage. While we found that most BOCC employees generally complied with the policy, our sample did identify that some employees violated the policy by using the county's vehicles for their personal benefit. It should be noted that our review of GPS data is limited to October 2023 through April 2024. This is because the BOCC's Fleet Management department was unable to provide GPS data prior to this date due to a changeover of vendors. Given the substantial issues identified even with the limited data available, it is likely a more robust review would have found additional issues. We sampled BOCC employees to determine whether they adhered to the policy. The sample was limited only to employees with assigned take-home vehicles. Our sample of GPS records found that most employees assigned take-home vehicles used them to commute between home and work as allowed by policy. However, we found that employees of two departments regularly used their assigned take-home vehicles for unauthorized personal reasons: Airports and Social Services. Airports The BOCC's Airports department, managed by the Executive Director of Airports (Executive Director), includes both the Florida Keys Marathon International Airport (Marathon Airport) and the Key West International Airport (KWIA). The Executive Director has delegated his responsibility for vehicle management to the on-site manager of each airport. Our audit testing found that the Airports department's practices did not comply with county policy and had lax management oversight over county-owned vehicles. — 5 - 4422 Marathon Airport. Our sample of GPS data included vehicles assigned to two Marathon Airport employees. The sampled GPS data showed the county vehicles assigned to them were regularly used for personal reasons such as stops at grocery stores, home improvement stores, schools, restaurants, and relatives' residences. By analyzing available GPS data, we estimate that 5 1% of the mileage for the Marathon Airport Supervisor of Airport Facilities and Maintenance and 75% of the mileage for the Marathon Airport Manager were for personal use. KWIA.In March 2021,the Executive Director requested the County Administrator exempt KWIA from MCAI 6402.6. This request was made when Fleet Services moved its operations away from Key West airfield location to Rockland Key. The exemption allowed KWIA to hire its own mechanic to ensure the airfield's emergency response vehicles are always kept in working order. The exemption also allows KWIA to use a mobile vehicle service company to repair and maintain the airport's non-emergency vehicles (see Appendix II). However, KWIA appears to have extended their exemption from MCAI 6402.6 beyond what was originally approved as evidence by KWIA removing GPS units from its vehicles. GPS units were initially installed in all county vehicles primarily as a management oversight tool. Removing GPS from the airport vehicles inhibits KWIA management from providing needed oversight. Like the Marathon Airport, KWIA appears to have limited oversight to ensure employees comply with MCAI 4713.6. During the audit period, twelve KWIA employees were assigned take-home vehicles. Our review of odometer readings found mileage significantly higher than would be expected for certain KWIA employees. The excessive mileage suggests that the vehicles were being used for personal purposes beyond the employees' daily commute. KWIA was unable to provide supporting documentation or justification to substantiate employees' excess mileage which, in turn, causes tax problems. According to the IRS, the employer must have some way to prove that the vehicles are being used for business purposes. If there are no supporting records,the IRS assumes that employees are using their take-home vehicles solely for personal reasons. As defined by policy, an employee is only authorized to drive a county vehicle for the employee's daily commute when it is deemed essential to protect the health, safety, or welfare of the public. The policy further defines the criteria that department managers must apply for determining whether an employee may be assigned a take-home vehicle: ". . . whether the delay resulting from the effected employee having to first proceed to the workplace to access a County vehicle would be such that the health, safety, or public's welfare could be jeopardized." When we spoke to the Airport management,we asked how their staff(primarily maintenance staff)qualify for using their county vehicles for their daily commute, especially since they are not considered first responders to an emergency. Management stated that it was easier for employees who need to respond to an afterhours call, such as a maintenance issue, if they are assigned a take-home county vehicle. — 6 - 4423 Airport management also explained that the take-home vehicles are equipped with the staff's tools and a radio. Therefore, allowing Airport personnel to take home a vehicle enables them to immediately drive straight to the airfield to respond to an afterhours call. Airport management stated that if an employee had to drive their personal vehicle, there would be a delay as the employee would need to park their vehicle and then proceed to the County's vehicle parked at the airport to have the appropriate tools for the maintenance/repair work. Based on the explanations provided, it does not appear Airport staff meet the criteria for a take- home vehicle. The delay in driving a personal vehicle to the airport versus driving a county-owned vehicle is negligible. If there is an emergency,the staff would arrive at the same time to the airfield whether they travel in their personal vehicle or the county-assigned vehicle. In addition, like the staff at the Marathon Airport, we found that certain KWIA staff appear to be using their vehicles primarily for personal use which is prohibited by MCAI 4713.6. During our review of KWIA vehicles,we also found that, consistent with the County's policy, the Executive Director also is personally assigned a vehicle because he is expected to routinely travel as part of his job responsibilities. When County staff are expected to travel extensively for their job, an assigned vehicle has proven to be the most efficient and cost-effective means of travel and, in turn, being in the best interest of the County's taxpayers. However, according to Airport staff and a review of the odometer readings, the Executive Director's vehicle is rarely driven. Rather than use his assigned County vehicle, the Executive Director regularly uses his personal vehicle for work travel and seeks reimbursement for his mileage. From October 2020 through April 2024, the Executive Director used his personal vehicle to attend BOCC meetings and travel out-of-county for conferences. In total, the Director received $15,616 in mileage reimbursement during this period for driving is his personal vehicle. It is an inappropriate use of public funds for a department manager to refuse to use his assigned County vehicle to conduct County business so he can be personally reimbursed for mileage. Moreover, using a personal vehicle in lieu of a county-owned vehicle is in direct violation of Florida statutes and Monroe County Code which require employees to travel the most economical and practicable method available. Social Services Out of 24 vehicles assigned to Social Services, the department manager authorizes only one employee to take home a vehicle, the Senior Coordinator Special Projects (Senior Coordinator). The Senior Coordinator also works a second position after the end of the normal workday as an On-Call Personal Care Worker/Homemaker. In this on-call role, the employee assists elderly and/or disabled clients with household duties, homemaking, light chores, and/or personal care tasks. — 7 - 4424 When asked how the Senior Coordinator qualifies for a take-home vehicle, the department manager stated that, in addition to working odd hours, the employee delivers meals as well as brings items to the department manager's home upon request. We asked the department manager how these job duties fall within criteria set by MCAI 4713.6 for qualifying an employee to be entitled to take home a vehicle: "whether the delay resulting from the employee having to first proceed to the workplace to access a county vehicle would be such that the health safety, or public's welfare could be jeopardized." The department manager did not provide us a response. Given that no other On-Call Personal Care Worker/Homemaker have assigned vehicles, we can only conclude that this individual does not meet the criteria for being assigned atake-home vehicle. Based on GPS data, we estimate that almost 45% of the Senior Coordinator's mileage was for personal use. It appears that the Senior Coordinator routinely used her assigned vehicle to visit family, travel out-of-county, and run personal errands. The GPS data showed that this vehicle was regularly driven by the employee during holidays and weekends when she was not on the clock. We also found instances where she used the County's vehicle to travel around the Miami area for unknown reasons. We found that despite the significant personal mileage the GPS data showed, the Senior Coordinator historically has not been reporting the number of days she used the vehicle for personal use as required by MCAI 4713.6. When we brought this employee's personal use of a County vehicle to the attention of the Acting County Administrator and the County Attorney, the employee subsequently submitted a report claiming personal mileage for the first quarter of 2024. Given the serious nature of the policy violations identified, the risk exposure to the County, and the disparity of management oversight among the BOCC's departments, we recommend the BOCC and/or the County Administrator to: • Install GPS in all county-owned vehicles, including KWIA vehicles, and require all departments to maintain a vehicle usage log documenting business use of the County's vehicles; • Require department managers to review quarterly their department's vehicles usage log for thoroughness, completeness, and reasonableness; • Prohibit an employee from using a personal vehicle to conduct County business if the employee is assigned a County vehicle; • Review and update MCAI 4713.6 so there are explicit consequences when employees use county vehicles for personal gain. . g - 4425 County's Response: The County agrees about the need for central oversight. The County will review its vehicle use policy and amend accordingly. Additionally, the County will reinforce its oversight practices and work closely with department heads to maintain compliance. Lastly,the County will review F.S. 112.061(7)and Monroe County Code of Ordinance Sec. 2-111 to ensure that its vehicle use policy is in compliance with state and County law. Upon receiving a draft copy of this Audit report, Monroe County's Director of Social Services removed the employee's use of the take-home vehicle pending clarification and review of the use of the vehicle. Additionally, the Executive Director of Airports explained that the vehicle initially purchased for his use in March 2021 was repurposed in May 2021 to be available to Operations and Maintenance staff to meet the operations and security needs of the Airport. During the period cited, the vehicle was used on-site for various projects and assignments by airport staff. The County recently entered into a new contract with Samsara which includes new GPS units and employee fobs. The new system allows the County to more adequately track its vehicles and monitor the vehicle users. The Key West International Airport(KWIA) is in the process of having the new Samsara GPS units installed in all of its vehicles. Monroe County is taking additional steps to ensure compliance with the County's vehicle policy and ensuring that all County-owned vehicles have the new GPS units installed. Lastly, the County always reserves the right to take immediate action for violation of any of its policies. Inconsistent Application of Policy The County's current policies and procedures for personally assigning county vehicles to employees provides no centralized oversight. Each department manager determines who, within their department, is to receive a take-home vehicle without documented justification and without a formal review and approval process. Further, there are no periodic reviews to determine if staff continue to qualify for a take-home vehicle. MCAI 4713.6 does not require any department to re- evaluate vehicle usage to assure public assets are not misused. Best practices recommend that entities develop a formal process that provides centralized oversight including a vetting process to ensure that only staff who should be personally assigned a county vehicle are assigned a vehicle. Monroe County's current procedures follow a more decentralized approach by allowing department managers to apply the policy with no need to justify their decision. — 9 - 4426 More detailed guidance to department managers would ensure that the County's policy is applied consistently by all departments. Department managers should be expected to document a business case for assigning an employee a take-home vehicle by providing: • A description of the tasks that the individual operating the vehicle is expected to perform (including a description of any required equipment or vehicle modifications)and why other forms of transportation are not suitable to accomplish those tasks; • A justification that assesses the relative importance to the department's mission of authorizing the use of take-home vehicle versus other forms of transportation; and • An explanation as to why it is critical to the department's mission that performance of duties begins at the employee's residence rather than the employee's official work location. We reviewed the audits conducted by other Florida counties to determine how other counties manage the use of personal use of county vehicles. Other Florida counties also emphasized that it was important that a personally assigned vehicle be justifiable based on job demands and/or cost savings, and that a regular review of the need for a take-home vehicle is needed. We recommend the County Administrator: • Conduct a review of all county vehicles that are personally assigned to employees to ensure that the employee meets the MCAI4713.6 criteria to take home a County vehicle; • Require a department manager to clearly document in writing the reason why an employee should be assigned a take-home vehicle for the County Administrator's approval and ensure that this reason adheres to MCAI4713.6; • Revoke any current take-home privileges granted to employees who do not meet the criteria as set forth in MCAI 4713.6; and • Require quarterly reviews of the county vehicles assigned as take-home vehicles to determine ongoing need. County's Response: The County agrees about the need for central oversight. The County will review its vehicle use policy and amend accordingly. The County will also conduct a review of vehicle assignments for compliance. 10 4427 Improving Compliance with Internal Revenue Service Regulations According to IRS regulations, "if an employer-provided vehicle is used for both business and personal purposes, substantiated business use is not taxable to the employee. Personal use is taxable to the employee as wages."' Generally, commuting is considered personal use. Consequently, MCAI 4713.6 states that the County Attorney's Risk Management Office requests information from each department on a quarterly basis as to which employees have commuted to work in a county-owned vehicle and how many days they commuted. This information is used to withhold the corresponding payroll taxes.Per MCAI 4713.6,the BOCC uses the IRS' Commuting Rule to determine the taxable value to be added to an employee's payroll. According to the Commuting Rule, the reported days of usage are multiplied by $3.00 ($1.50 for each commute), and the amount is added to the employee's payroll as taxable income. It is important to note the distinction between transportation and commuting. Commuting refers to travel between an employee's residence and the regular place of work. Conversely, transportation is defined as travel from one workplace to another. Commuting via use of an employer provided vehicle is a taxable fringe benefit. Inappropriate and Insufficient Quarterly Reporting As part of our audit, we reviewed the required quarterly reporting by BOCC staff of the number of days they used a county vehicle for their daily commute. Overall, we found that many staff are neither consistent nor accurate in their reporting. Mistakes identified in our review include overreporting, underreporting, and refusal to report. Notable instances of the errors found included staff pre-filling in the quarterly report for 20 days of usage per month regardless of the number of workdays or leave time used by the employee. This overreporting results in too much being withheld from the employee's paycheck. It also indicated a lack of attention to and respect for the policy. At the other extreme,we found that over a 60-month period, the majority of KWIA staff failed to submit any of the required quarterly reports of their personal use. In addition, of the 39 Public Works employees who use a county vehicle for their daily commute, only three submitted the required quarterly report. The remaining 36 employees did not submit the required reports because they park their vehicles at a close-by county facility and then walk home rather than park the vehicle at their residence.Because Public Works does not require its employees to track their business usage of these vehicles, the IRS considers their mileage as personal, and therefore taxable, no matter where the vehicle is parked while not in use. 'IRS Publication 5137, Office of Federal, State, &Local Governments Fringe Benefit Guide(Rev. 10-2022),Page 36. ^ 11 ^ 4428 We recommend departments be required to: • Track and document business and personal use of County vehicles; • Establish procedures to review and approve staffs quarterly reports ofpersonal use;and • Take immediate action when employees fail to comply with quarterly reporting requirements. County's Response: The County recently entered into a new gps software program contract. The new system allows the County to more adequately track its vehicles and monitor its vehicle users. The new program also allows for compilation of history logs for each user and/or each vehicle. The County will review its vehicle assignments and each vehicle's assigned location(s) for compliance with the Internal Revenue Code. Additionally, the County will review and consider the feasibility of adding a vehicle use component to the Clerk's WorkDay program to ensure compliance. The County's current written policy disallows personal use of County vehicles except for commuting and sustenance. Additionally, the County always reserves the right to take immediate action for violation of any of its policies Unnecessary Tax Liability for Fire and Rescue Employees BOCC take-home vehicles include Monroe County Fire Rescue (MCFR) marked trucks (e.g., emergency lights, special paint schemes, and insignia) for certain fire and rescue employees: Deputy Fire Marshals, Deputy Chiefs, Mechanics, the Fire Chief, and Paramedics. The MCFR employees report commuting usage on a quarterly basis, which is then added to the employees' income as a tax liability. Because the employees are mandated to drive the vehicle between home and work, they receive a 2%pay increase over and above the normal salary level to offset the tax liability. The 2% pay increase over and above normal salary is designed to cover the federal income and payroll taxes that result from the $3 usage valuation. However, per IRS regulations, the vehicles being driven by MCFR employees are exempt from taxation. An employee's use of a qualified nonpersonal use vehicle is a working condition fringe benefit and is not taxable if the specific requirements for the vehicle are met. The requirements to be a qualified nonpersonal use vehicle include being a clearly marked'police, fire, or public safety officer vehicle, and that the employee must always be on call, required to use the vehicle, and the employer must prohibit personal use. Because the MCFR employees meet these requirements, the use of the vehicle is not taxable. z Clearly marked means that it is readily apparent, by words or painted insignia, that the vehicle is a public safety vehicle.The MCFR's vehicles are painted red and white,with a logo on three sides,plus a lightbar. 12 4429 As shown in Figure 2,the quarterly reporting form indicates that the use of authorized emergency vehicles should not be reported by employees. The MCFR employees are not required to report and should not receive the increased compensation. Figure 2 Quarterly Report Form Excerpt Report the use of ALL vehicles used for community to and from work other than authorized emergency vechicles. Vehicle Details* �V�c I�cdcV,end Ys�r cf la�hi�V� We recommend that Administrative Instruction 4713.6 be amended to reflect the appropriate treatment of qualified nonpersonal use vehicles and that MCFR employees are not required to report their vehicle usage unless it is determined that a vehicle is not a qualified nonpersonal use vehicle. In addition, we recommend the pay supplement should be discontinued for those employees driving a qualified nonpersonal use vehicle. County's Response: The County will conduct a review of its vehicle assignments.If after consulting with tax advisors it is determined that a take-home vehicle meets the criteria to be properly classified as a clearly marked emergency vehicle by the Internal Revenue Service, and should the individual be receiving a pay supplement, the County shall discontinue the pay supplement associated with that use. Additionally, the County will review its vehicle use policy and amend accordingly. Applying Appropriate Valuation Rule for Personal Use According to IRS regulations, personal use of an employer's vehicle creates a tax liability to the employee. Personal use is generally regarded as commuting, evening and weekend use, and the use by other members of the family. Accordingly, IRS regulations permit three valuation rules to determine the tax liability: • Automobile Lease Valuation Rule (also known as Fair Market Value Rule); • Vehicle Cents per Mile Rule; and • Commuting Valuation Rule. 13 4430 Per IRS guidance, the rules are generally applied on a vehicle-by-vehicle basis and the employer may use different rules for different vehicles,provided that the conditions for the rule are met. The IRS notes that, generally,the amount to include in an employee's income is the Fair Market Value (FMV) Rule. The other rules may be used in only certain circumstances and only if all conditions are met. Although the IRS notes that the general approach is to use FMV, the BOCC has opted to use only the Commuting Valuation Rule to determine the amount to include in employees' income. However, it is not evident that all criteria for the Commuting Valuation Rule are met for all employees. To use the Commuting Valuation Rule, the following conditions must be met: • The vehicle is owned or leased by the employer. • The vehicle is provided to the employee for use in the business. • The employer requires the employee to commute in the vehicle for a bona fide noncompensatory3 business reason. • The employer has a written policy prohibiting personal use other than commuting. • The employee does not use the vehicle for other than de minimis personal use. • The employee who uses the vehicle is not a control employee'. In its guidance to governments, the IRS specifically notes that the employer must require the employee to use the vehicle for a business purpose; it cannot be voluntary on the employee's part. It is explicit that it is not enough for the employer to simply state that it requires employees to commute in employer-owned vehicles. Given the requirements for the use of the commuting rule, Public Works staff will not qualify for the commuting valuation rule as the employees are not required to commute in the vehicles. Thus, the BOCC would need to use an alternative formula for calculating the taxable value of the fringe benefit. The other valuation rules require records to be kept identifying personal use versus business use. However, because the County does not require usage logs to be kept, determining the taxable value is not feasible.Moreover,the use of either of the other valuation methods requires that any fuel provided by the County (e.g. use of County fuel) is also a taxable fringe benefit. We recommend the County Administrator amend MCAI 4713.6 to reflect the three IRS valuation methodologies, and how the BOCC is to determine which valuation methodology to apply to each take-home vehicle. Per the IRS the term"bona fide noncompensatory business reason"means that the employee must be required to commute in the vehicle for the benefit of the employer,not for the benefit of the employee.It is not enough for the employer to simply state that it requires employees to commute in employer-owned vehicles. 4 A control employee in a governmental organization is either an elected official or an employee whose compensation is at least as great as a federal government employee at the Executive Level V(beginning January 1,2024,this is $180,000). 14 4431 County's Response: The County will review its policies regarding emergency vehicles with the Clerk in order to comply with IRS regulations and will consult with the appropriate tax advisors. County's Overall Response: County Administration welcomes the review of its policies, processes, and procedures. The County is committed to addressing any the concerns identified in the audit and will take the necessary steps to ensure full compliance with County policies and amend its policies accordingly. The County and its respective departments are committed to improvement, transparency and accountability. The County is open to considering alternative methods and implementation of best practices. 15 4432 Appendix I Monroe County Administrative Instruction 4713 .6 Use of County Vehicles � 16 - 4433 L10%RD.CLF C(A.NTY C(AIMISSIONFR'� County of Monroe \Ltyw Heathcr Cxrukhi,.D@%om I Maym Pro TcrnNficW,:Coldiron.Dwrici 2 Craig Caie%.Di,irio t Ile Florida Keys Da%id Rdcc,Dimnct 4 Syl%mJ Murphy.Dwrick5 Monroe County Attomey's Office is Management Department 1111 12thStreet,Suite 408 Key West®FL 33040 OFFICE OFT COUNTY ADMINIMATOR Key Wcsi,Flees MONROE COUNTY ADMINISTRATIVE INSTRUCTION 4713.6 Date: March 50 2020 Subject: Use of County Vehicles Reference:(A)Section 1.04 Monroe County Personnel Policies and Procedures Manual (B)Monroe County Safety Policies and Procedures Manual (C)IRS Public Law 99-44 Enclosure:(1) Vehicle Usage Form Effective Date:January 28,2002 (1)Background: Various policy standards and/or disciplinary actions are outlined in References (A)and(B).However,there are no single established uniform procedures,which detail proper assignment and use of Monroe County vehicles. (2)Eyrasc.The purpose oft is instruction is to establish standardized procedures for all employees to follow when assigning and/or utilizing County vehicles. (3)CLanggjl 'glL Ltl :This instruction supersedes and replaces M.C.A.Instruction 4713.5 and is to remain continuously in effect until specifically revised or canceled. (4) A.County vehicles will be permanently assigned only toemployees whose responsibilities routinely take the from their normal work place. 17 - 4434 M.C.A. Inst.4713.6 March 5,2020 Page 2 B. COUNTY VEHICLES WILL BE USED ONLY FOR CONDUCTING COUNTY BUSINESS! Use of any County vehicle forte personal convenience or gain of a County employee is prohibited. One allowable exception tothis policy would be using the County vehicle for the purpose of obtaining sustenance when working remote from the normally assigned work place and other transportation is unavailable.The other exception would be when it is more practical and tot County's economic benefit for the employee totake the vehicle home in order to facilitate attendance at an early morning meeting at locations remote and/or in opposite direction from the normal work place.This exception does not apply to employees who,in the normal course aft eir daily work,travel throughout the County.These employees must first report to their regular place of work before proceeding further. C. Authority for an employee to drive a County vehicle back and forth from home to the work place shall only be granted when such is deemed essential to ensure the health,safety and/or welfare of the public is protected. D. The criteria to be used in determining vehicle take home use authority is whether the delay resulting from the effected employee having to first proceed tothe workplace to access a County vehicle would be such that the health,safety or public's welfare could be jeopardized. E. Non-Exempt County employees who are on call 24 hours a day and are mandated to drive a County vehicle back and forth between their work place and home for emergency purposes shall receive a 2%pay increase over and above their normal salary level.This increased compensation is to offset the payroll reduction equivalent mandated by the I.R.S.,i.e. the tax assessed on$3.00 per day for each day of vehicle usage,which is the value placed on this drive home benefit by Reference(C.) F. Persons who are not County employees or under County contract are prohibited from operating or riding in any County vehicles,with the exception of transporting out-of-town visitors or other personnel while participating in official County business,or in promotional events approved by the County Administrator.. G. All County passenger vehicles will be painted the color white,the County insignia affixed upon each of the front doors,and the name of the represented Department or Division included thereon.This action shall be appropriately scheduled through the applicable County garage site. — 18 — 4435 M.C.A. lnsL 4713.6 March 5®2020 Page 3 H. Routine maintenance and cleaning of vehicles will be scheduled in accordance with M.C.A. Instruction 6402 series.The same applies to leased vehicles®unless otherwise- specified in the lease agreement- (5)Action: A. The Risk Management Office will request information from each Department on a quarterly basis as to which employees have County vehicle take home authorization.The Departments will have fifteen(15)days to respond with corrections.Subsequently,by use of Enclosure(1). is Management will provide this information to the Payroll Department for implementation of the tax deduction described in paragraph(4)E of this instruction. B. All supervisory personnel/cmployces are directed to be alert for employee misuse of County vehicles.Any such activity is to be immediately reported to the concerned Department and the County Administrator, C. The practice of employees gathering in large groups at business or eating establishments is often perceived by the public to be a misuse of government property and funds. Additionally®such gatherings tend to extend the meal period longer than that which is authorized and is indeed a misuse of taxpayer dollars.Therefore,such practices are discouraged,and applicable supervisors shall insure that their personnel are so instructed. If such an occurrence is observed®the establishment is to be visited®a determination made as to the reasons for said gathering,and a written report citing time place®vehicle license numbers,personnel involved,ctc,will be provided to the County Administrator. D. County vehicle operators will obey all applicable traffic,safety,and inspection regulations, including those provided for in Reference:(B). E. For safety reasons,all vehicles(including personal vehicles)shall have their headlights turned on when driving U.S. I or ounty business. Roman Gastesi County Administrator Distribution: List III Originator:HRD Review: 3-5-2023 19 - 4436 Appendix II Memo on KWIA and Fleet Services - 20 - 4437 s fi.",,, Key West, Intenistiona Airport 1 South Rowevelt Blvd. Key West,Florida MEMORANDUM, Roman Gastesi,t ounty Administrator r FROM. Richard Strickland,Sr.Director of Airports FYF® EYW Fleet Management Services DATE: March 1, 2021 Per our,previous discussions,,with upcoming relocation of Public Works and Fleet W na nt (except for fueling )from the Key West International Airport at the end of July,2021,the Airport is requesting longer be included in the Fleet Management program nor the annual vehicle maintenance billing. The Airport will be exempt from Monme County Administrative Instruction 6402 and instead will budget sufficient funding each year to of vehicle maintenance and repairs, as well as the purchase Airport vehicles and equiipmenit as needed. In the immediate future, the Airport will use mobile vehicle service companies to repair and maintain Airport vehicles on site rather than leaving Airport, property fbr service. In the near future, the Airport will budget funding to add one additional ARFF mechanic W supplement the current ARFF mechanic due to the A220 aircraft being added to the fleet rr bi and bath mechanics will take care o'ARFF and Airport vehicle service and repair needs. Please notet the change does not affect Fleet Management services for the Florida Keys Marathon International Airport Thank you. n Roman Gastesi Darryl Greenlee Kevin Wilson 21 4438 BOARD OF COUNTY COMMISSIONERS Mayor Holly Merrill Raschein,District 5 Comity of Monroe � 1' Mayor Pro Tem James K.Scholl,District 3 The Floflda,Keys ;,The Cates,District 1 � �" Michelle Lincoln,District 2 David Rice,District 4 Monroe County Attorney's Office Risk Management Department 1111 12th Street, Suite 408 Key West, FL 33040 OFFICE OF THE COUNTY ADMINISTRATOR Key West,Florida MONROE COUNTY ADMINISTRATIVE INSTRUCTION 4713.7 Date: May 7, 2024 Subject: Use of County Vehicles Reference: (A) Section 1.04 Monroe County Personnel Policies and Procedures Manual (B) Monroe County Safety Policies and Procedures Manual (C) IRS Public Law 99-44 Enclosure: (1) Vehicle Usage Form Effective Date: Immediately (1) Background: Various policy standards and/or disciplinary actions are outlined in References (A) and (B). However, there are no single established uniform procedures, which detail proper assignment and use of Monroe County vehicles. (2)Purpose: The purpose of this instruction is to establish standardized procedures for all employees to follow when assigning and/or utilizing County vehicles. (3) Cancellation: This instruction supersedes and replaces M.C.A. Instruction 4713.6 and is to remain continuously in effect until specifically revised or canceled. (4) Instructions: A. County vehicles will be permanently assigned only to employees whose responsibilities routinely take them from their normal work place. 4439 M.C.A. Inst. 4713.7 May 7, 2024 Page 2 B. COUNTY VEHICLES WILL BE USED ONLY FOR CONDUCTING COUNTY BUSINESS! Use of any County vehicle for the personal convenience or gain of a County employee is prohibited. One allowable exception to this policy would be using the County vehicle for the purpose of obtaining sustenance when working remote from the normally assigned work place and other transportation is unavailable. The other exception would be when it is more practical and to the County's economic benefit for the employee to take the vehicle home in order to facilitate attendance at an early morning meeting at locations remote and/or in opposite direction from the normal work place. This exception does not apply to employees who, in the normal course of their daily work, travel throughout the County. These employees must first report to their regular place of work before proceeding further. C. Authority for an employee to drive a County vehicle back and forth from home to the work place shall only be granted when such is deemed essential to ensure the health, safety and/or welfare of the public is protected. D. The criteria to be used in determining vehicle take home use authority is whether the delay resulting from the effected employee having to first proceed to the workplace to access a County vehicle would be such that the health, safety or public's welfare could be jeopardized. E. Non-Exempt County employees who are on call 24 hours a day and are mandated to drive a County vehicle back and forth between their work place and home for emergency purposes shall receive a 2%pay increase over and above their normal salary level. This increased compensation is to offset the payroll reduction equivalent mandated by the I.R.S., i.e. the tax assessed on $3.00 per day for each day of vehicle usage, which is the value placed on this drive home benefit by Reference (C.) F. Persons who are not County employees or under County contract are prohibited from operating or riding in any County vehicles, with the exception of transporting out-of-town visitors or other personnel while participating in official County business, or in promotional events approved by the County Administrator. Additionally,persons participating in County sponsored recreational events preapproved by the County Administrator may ride in any County vehicle. G. All County passenger vehicles will be painted the color white, the County insignia affixed upon each of the front doors, and the name of the represented Department or Division included thereon. This action shall be appropriately scheduled through the applicable County garage site. 4440 M.C.A. Inst. 4713.7 May 7, 2024 Page 3 H. Routine maintenance and cleaning of vehicles will be scheduled in accordance with M.C.A. Instruction 6402 series. The same applies to leased vehicles, unless otherwise specified in the lease agreement. (5) Action: A. The Risk Management Office will request information from each Department on a quarterly basis as to which employees have County vehicle take home authorization. The Departments will have fifteen (15) days to respond with corrections. Subsequently, by use of Enclosure (1), Risk Management will provide this information to the Payroll Department for implementation of the tax deduction described in paragraph(4) E of this instruction. B. All supervisory personnel/employees are directed to be alert for employee misuse of County vehicles. Any such activity is to be immediately reported to the concerned Department and the County Administrator. C. The practice of employees gathering in large groups at business or eating establishments is often perceived by the public to be a misuse of government property and funds. Additionally, such gatherings tend to extend the meal period longer than that which is authorized and is indeed a misuse of taxpayer dollars. Therefore, such practices are discouraged, and applicable supervisors shall insure that their personnel are so instructed. If such an occurrence is observed, the establishment is to be visited, a determination made as to the reasons for said gathering, and a written report citing time place, vehicle license numbers,personnel involved, etc. will be provided to the County Administrator. D. County vehicle operators will obey all applicable traffic, safety, and inspection regulations, including those provided for in Reference (B). E. For safety reasons, all vehicles (including personal vehicles) shall have their headlights turned on when driving U.S. 1 on County business. M Kevin G. Wilson Acting County Administrator Distribution: List III Originator: HRD Review: 05-07-2027 4441 Enclosure (1) M.C.A. Inst. 4713.6 May 7, 2024 Page 4 VEHICLE USAGE REPORT NAME AND SOCIAL SECURITY NUMBER OF EMPLOYEE USING VEHICLE EMPLOYEE NAME: SOCIAL SECURITY NUMBER: DEPARTMENT: REPORTING QUARTER FM: TO: REPORT THE USE OF ALL VEHICLES USED FOR COMMUTING TO AND FROM WORK OTHER THAN AUTHORIZED EMERGENCY VEHICLES MAKE,MODEL AND YEAR OF VEHICLE: VEHICLE ID# NUMBER OF DAYS USED EACH MONTH: EMPLOYEE SIGNATURE: NOTE:IF VEHICLE IS USED FOR COMMUTING ON AN OCCASIONAL BASIS,PLEASE INDICATE. EMPLOYEE IS RESPONSIBLE FOR REPORTING VEHICLE USAGE TO RISK MANAGEMENT. 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