HomeMy WebLinkAbout06/27/2025 Audit Monroe County Clerk of Circuit Court & Comptroller
Internal Report
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Audit of
Monroe County Solid Waste
Cash Handling
2025-002
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500 Whitehead Street, Key West, FL 33040 1 (305) 295-3130 1 Monroe-Clerk.com
Report 2025-002
June 2025
Monroe County Clerk of Circuit Court& Comptroller
Kevin Madok, CPA
Interim Internal Audit Director
Pam Radloff
Auditors
Kalina Bringle
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 ems://monroe-clerl<-.com/fraud-waste-abuse.
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:ps @ Kevin Madok, CPA
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;�oN...... ;@ Clerk of the Circuit Court&Comptroller—Monroe County, Florida
June 27, 2025
The Honorable Mayor Jim Scholl
Monroe County Board of County Commissioners
530 Whitehead Street
Key West, FL 33040
Email: boccdis3@monroecounty-fl.gov
Dear Mayor Scholl:
The Monroe County Clerk's Internal Audit Department completed an audit of cash handling at the
Monroe County Solid Waste Department (Department) for the period October 1, 2021, through
September 30,2024. This audit is a continuation of our efforts to evaluate cash handling by County
departments tasked with taking payments by collecting cash, checks, and credit/debit cards.
Our audit noted material and serious shortcomings with the transfer stations' operations. The lack
of controls and the lack of management supervision over the work being performed by transfer
station operators has created an environment that needs the immediate intervention of the County's
senior management team. In addition to recommending strengthening management oversight of
the transfer stations,we also recommend improvements over the handling of cash and preparation
of daily deposits to the bank. When we discussed our audit findings with Department management,
they responded with a strong commitment to implementing necessary corrective actions to
improve their operations.
We appreciate the courtesy and cooperation extended to the Clerk's Office by the Solid Waste
staff during the audit. Appendix I is Solid Waste's response to the audit report.
Sincerely,
A
Kevin Madok, CPA
Monroe County Clerk of Circuit Court & Comptroller
Cc: Board of County Commissioners
Christine Hurley, County Administrator
Kevin Wilson, Assistant County Administrator
Bob Shillinger, County Attorney
Cheryl Sullivan, Director of Solid Waste
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
Table of Contents
Audit of
Monroe County Solid Waste Cash Handling
ExecutiveSummary .......................................................................................... 1
Monroe County Solid Waste Management ..................................................... 2
Purposeand Scope of Audit.............................................................................. 4
Lack of Controls At Transfer Stations ............................................................ 5
Irregularities with Pre-Numbered Receipts......................................................................5
VoidedTransactions............................................................................................................7
PlacingCustomers On Hold................................................................................................8
ReportingDrive-Offs.........................................................................................................10
Handling Of Cash By Transfer Stations........................................................ 12
Strengthening Daily Deposit Procedures At Transfer Stations.....................................12
ReportingOverages and Shortages..................................................................................13
AssigningTills To Employees...........................................................................................14
CreditCard Payments.......................................................................................................15
Safeguardingof County Funds.........................................................................................16
Solid Waste Policies and Procedures Manual.................................................................17
Appendix I: Solid Waste Response To Audit Report.................................. 19
Executive Summary
The Monroe County Clerk of Circuit Court and Comptroller's Internal Audit Department recently
completed an audit of cash handling practices of the Monroe County Solid Waste Department
(Department). The Department's three transfer stations are entrusted with collecting fees from
customers who need to dispose of their solid waste. It is estimated that the cash, checks, and
credit/debit cards handled by transfer station operators total over $1.75 million annually. It is also
estimated that transfer station operators collect$250,000 annually in cash. As a result, it is critical
that the Department have strong management and supervisory oversight of transfer station
operators to ensure that they are adhering to established cash handling policies and procedures.
We found material weaknesses over how transfer station operators are processing specific
transaction types. While the Department has documented policies and procedures, a lack of
supervision and management oversight allows the transfer station operators to bypass procedures
and controls with no consequence. We found no uniformity in the knowledge of the policies or
even an awareness of their existence. The lack of integration among the Department's various
systems provides opportunities for staff to potentially avoid recording and reporting all
transactions. We recommend County senior management work with the Department Director to
strengthen oversight and controls at the transfer stations. Given the lack of controls, it is important
that management critically evaluate how the transfer stations are using available technology to
properly weigh and track customer loads and process related receipts including cash receipts. It is
also important for all staff, including managers and supervisors, to be thoroughly trained in their
responsibilities and understand the importance of controls that ensures all receipts that should be
collected are collected and recorded in the County's accounting records.
We also found improvements are needed over management of tills and preparation of daily bank
deposits to ensure all receipts received are deposited to the bank. Our audit procedures found
inconsistencies in staff's cash handling practices and violations of established policies. We also
noted controls over the physical security of cash needs to be strengthened at the transfer stations.
The Department has responded to the audit with a strong commitment to implementing necessary
corrective actions. Management recognized that many of the issues stemmed from communication
breakdowns and an overreliance on trust rather than a structured verification process. To address
these concerns, they indicated that the Department plans to take steps to strengthen financial
controls including updating its policies and procedures manual; providing enhanced employee
training focused on proper cash management and security; and implementing additional security
measures as recommended by the audit.
� 1 �
Monroe County Solid Waste Management
The Solid Waste Management Department (Department) provides cost-efficient and
environmentally proper collection, transportation, and disposition of solid waste generated in
Monroe County (County). County residents rely on many of the critical services provided by the
Department, including landfill maintenance and environmental compliance; transfer station
operations;recycling programs;hazardous waste disposal initiatives; solid waste enforcement; and
public education programs. Table 1 provides a breakdown of the type of revenue collected by the
Department to support its operations.
Table 1
Solid Waste Revenues By Type
FY 2022 through FY 2024
Fee Type FY 2024 FY 2023 FY 2022
Solid Waste Assessment $ 15,484,811 $ 14,916,265 $ 13,655,668
Tipping Fees 10,938,079 10,128,418 9,013,344
Franchise Fees 887,626 746,441 661,076
Total $ 27,310,516 $ 25,791,124 $ 23,330,088
The solid waste assessment is an annual assessment, applied to all residential properties benefiting
from solid waste services provided by the County, collected through property tax bills. The
assessment is periodically adjusted to account for changes in operational costs. Similarly, the
County levies a franchise fee on commercial haulers that collect and haul nonresidential waste.
Tipping fees are the fees charged when waste is dropped off at one of the Department's three
transfer stations. The transfer stations are strategically located in Cudjoe Key, Long Key, and Key
Largo. The transfer stations are facilities where waste is unloaded, compacted, and then reloaded
into larger, high-capacity trucks for long-distance hauling to a destination outside of the County.
Transfer station operators weigh and track incoming waste for billing and regulatory purposes
using an automated tracking and billing software system known as WasteWORKS.
Transfer stations handle commercial loads, residential drop-offs from private citizens, and
governmental/interdepartmental disposals. When a vehicle arrives, the transfer station operator
weighs the load using the transfer station's scale system. Once the vehicle is weighed,the operator
must initiate a new transaction in WasteWORKS. The operator then asks for the type of material
being disposed of and selects the appropriate waste type code in the software. The customer is then
directed to the designated unloading area. After unloading, the vehicle returns to the scale for a
second weigh-in. The transfer station operator uses WasteWORKS to calculate the net weight of
the disposed material by subtracting the outbound weight from the initial weight. The
corresponding disposal fee, also referred to as the tipping fee, is based on the waste type code
— 2 —
initially entered. Finally, the transfer station operator completes the transaction by entering the
method of payment and collecting any required tipping fee.
A commercial load refers to waste delivered by a company that holds an active contract with the
Department and maintains an established billing account. These account holders are not required
to pay the tipping fee at the time of disposal. Instead, the Department uses WasteWORKS to bill
the commercial hauler monthly. Companies without a formal contract/account as well as residents
are treated as cash customers and must pay the tipping fee immediately upon unloading. Accepted
payment methods include credit card, check, or cash. Our review of daily deposits estimated that
the cash, checks, and credit cards handled by transfer station operators total over $1.75 million
annually. Of this amount, it is estimated that over$250,000 annually involves the handling of cash.
Given the amount of cash that transfer station operators handle, controls over cash handling are
critical.
� 3 �
Purpose and Scope of Audit
As widely reported in 2012, County Administration contacted the State Attorney's Office to report
their suspicion that two Key Largo transfer station operators were providing cash customers
fraudulent receipts and then pocketing the cash for their personal benefit. Law enforcement
subsequently confirmed that the two operators were stealing cash. Following the reported theft,
the Clerk's Internal Audit Department conducted an audit of the Department's cash handling
procedures and issued a November 2012 audit letter recommending improvements over the
Department's cash handling. In response, the County Administrator reported that, in addition to
training staff on cash handling, the Department developed a written policies and procedures
manual that provided staff direction for handling tipping fees and ensuring cash drawers were
reconciled at the end of each shift.
As follow-up to the 2012 incident, the Monroe County Clerk of Circuit Court and Comptroller
requested the Internal Audit Department conduct a comprehensive review of the transfer stations'
cash-handling processes for the period from October 1, 2021, through September 30, 2024. The
audit included a review of all activities related to the intake,recording,reconciliation, and security
of funds. Our scope was designed to evaluate the integrity and efficiency of the Department's
financial processes, including:
• The assessment,collection,and deposit of tipping fees at transfer stations to determine
whether transactions are accurately recorded and properly accounted for.
• The management and reconciliation of customer deposits for tipping fees to ensure
accuracy and completeness in financial reporting.
• The processing and issuance of customer fee refunds to assess compliance with
established policies and the accuracy of transactions.
• The review and handling of voided transactions to identify potential risks,
inconsistencies, or procedural weaknesses.
• The physical security of cash, checks, and credit card receipts to evaluate whether
proper safeguards are in place to prevent loss, theft, or mismanagement.
This audit's aim was to assess the effectiveness of existing financial controls, identify
vulnerabilities that could compromise financial integrity, and highlight opportunities to strengthen
accountability and security within the department's revenue-handling operations.
— 4 —
Lack of Controls At Transfer Stations
The Department's Monroe County Solid Waste Policies and Procedures Manual For Scale
Operations, issued in 2013, states in its introduction, "Cash is one of the County's most sensitive
assets, and therefore clear accountability for the receipt, deposits, and custodianship (in charge or
responsible for) of cash is required."' The primary purpose of the manual was to standardize cash
handling, daily balancing, and deposit procedures across all transfer stations to ensure consistency
and compliance in the Department's fee collection processes. We found that the controls outlined
in the policies and procedures manual are not being adhered to and that the ability to systematically
divert cash without detection still exists.
Our audit procedures included reviewing how transfer station operators handled different
transaction types to determine whether policies and procedures were effective and proper controls
were established. In addition to finding staff not adhering to established policies and procedures,
we found that staff were able to easily bypass the Department's controls with no supervisory
oversight or approval. Further,the Department's receipt handling processes do not ensure a proper
audit trail exists to verify how transactions are being processed by staff. Following is a summary
of different transactions where we found the Department did not have sufficient controls. After the
summary, we provide recommendations for improving transfer stations' handling of receipt
transactions.
Irregularities with Pre-Numbered Receipts
A critical internal control that the Department has integrated with its WasteWORKS software
application is the use of pre-numbered ticket receipts. As shown in Exhibit 1, the pre-numbered
receipt details customer information, the scale ticket number issued by WasteWORKS, the
quantity of waste, the rate, and the date and time the waste was handled by the transfer station.
Pre-numbered receipts are numbered sequentially in red numbering. Blank pre-numbered receipt
forms are distributed in batches of 1,000 to each transfer station. Transfer station operators are
required to verify and document the receipt of each batch received.
In its Policies and Procedures Manual, the Department emphasizes that transfer station operators
must account for all pre-numbered tickets. Each operator is responsible for, "insuring that all the
red number tickets are accounted for in your daily batch. There is no reason a red-numbered ticket
should go `missing.' If it is damaged,then that damaged ticket must be sent to the Key West office
in your daily paperwork. If a ticket is missing, disciplinary action may be implemented."'
See Monroe County Solid Waste Policies and Procedures Manual for Scale Operations,2013 version,p. 1.
Ibid.,p.4.
Despite these established procedures, our review of pre-numbered receipts over a sample period
of 280 workdays revealed multiple irregularities that raised concerns. Specifically, we found
instances where pre-numbered receipts were used out of sequence. For example, ticket number
0129829 was used on March 28, 2024, while the surrounding tickets—from 0129801 to 0129828
and 0129830 to 0129871—remained unused until nearly two months later, on May 22, 2024. This
sporadic and out-of-order usage disrupts the traceability of transactions and weakens
accountability of the receipts.
Exhibit 1
Example of Pre-Numbered Receipt
MONROE COUNTY SOLID WASTE MCMT 01 00310145 � Ronald Yoakurn
� .
1100 Simonton St.Room�fi2-3�31 w u, ' i�, l n; ,rI �,u r j r
Key West,FL 3304001/06/22 -- —
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iC11 178:14 f
001840 yeah"souse Gardens ,am " all-
It
I04475 Overseas Hwy yy ;pp
Key Largo FL.33037 WI1T CHUMP �. .G. ..�d... ,.... _.a. ,...e
Scale 1 Gross Wt, 14740 LB inbound-Charge ticket
ket
Scale 1 Tare Wt, 9580 LB
58 TON CONSTRUCTIONIDE;MO OP 133.600 318.63 0.00 318.63
I
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Key Largo'1"ransfer Station.
Operating hours 8 AM to 3.30 PM Monday thru Saturday. 1¢, 3
CATCH THE;"GREEN WAVE"P Please call 305-292-4536 if this
ticket does not contain as green wave". 'Thank you.
f E'lfldf'A)N/ A
More concerning is that our sample noted 72 instances (or 25.7% of the sampled days) of pre-
numbered receipts missing and not reported in the daily paperwork submitted to the Key West
Office. As an example, on October 28, 2021, all pre-numbered receipts for the Long Key Transfer
Station were missing, leaving no record of transactions for that day. Such gaps in ticket
accountability undermine the reliability of the controls the Department established for managing
transfer station receipts.
We also identified one instance where a pre-numbered ticket was duplicated. On November 10,
2021, two separate receipts were found using the same, pre-numbered receipt(1016500), despite
being linked to different transactions. Given the security features designed to prevent such
— 6 —
occurrences, we sought clarification. The Department's investigation into this issue revealed that
the vendor that prints the pre-numbered tickets admitted that sometimes it may mistakenly print
duplicate ticket numbers or may omit numbers entirely.
Voided Transactions
The Department's Policies and Procedures Manual establishes guidelines for voiding transactions.
Procedures require transfer station operators to attach the voided pre-numbered receipt to the
replacement pre-numbered receipt and document the reason for voiding the transaction. These
steps are designed to support auditability and prevent financial discrepancies. Our testing revealed
substantial inconsistencies in how transactions are voided by the transfer stations. In numerous
instances, required voided tickets were missing, preventing verification of whether voided
transactions were legitimate or if proper replacement transactions were recorded. In addition, we
identified 24 cases where a transaction was voided in the WasteWORKS system, but the
corresponding pre-numbered receipt was not marked as voided and missed by management. Such
inconsistencies compromise the reliability of transaction records and hinder effective oversight.
When we asked Department management about the inconsistencies with voiding transactions,they
cited limitations with the WasteWORKS software. According to the Department, the system only
logs the scale ticket number and operator notes for voided transactions. We were told that it does
not retain detailed information such as the type and quantity of waste, vehicle identification, or
customer account details. In effect, if a transaction is voided without a printed ticket, no record
remains of what was originally entered or the justification for its removal. This creates an
accountability gap that could allow transactions to be altered or deleted without proper oversight.
These deficiencies are particularly concerning when a cash transaction is voided that involves a
larger dollar amount. Our sample of receipts found that on November 19, 2021, one of the transfer
stations recorded a voided cash transaction of$908.96 with a vague explanation of"had cd".When
we inquired what this reason meant, we were told it was referencing construction and demolition
debris. However, no voided ticket was available, no replacement transaction could be identified,
and an analysis of all subsequent transactions from that day showed that the missing amount was
never accounted for. Similarly, on June 7, 2024, another transaction for $201.28 was voided in
WasteWORKS with the note "change to cash," yet there was no corresponding cash payment,
corrected transaction, or voided ticket to support the claim. Without the necessary documentation,
it remains unclear whether these transactions were handled properly or if funds were diverted.
In total, our sample included voided cash transactions totaling $12,487.62. However, due to the
widespread lack of documentation, the true scope of potential discrepancies remains unknown.
The absence of voided tickets and the inconsistent application of recordkeeping procedures raise
— 7 —
significant concerns about financial controls at the transfer stations and the department as a whole.
When asked about these issues,the Transfer Station Supervisor acknowledged that operators could
void a transaction, provide an explanation, and retain the payment without additional oversight.
He explained that the scale system is not electronically integrated with the WasteWORKS
software,providing operators opportunity to bypass the system entirely. While he maintained that
dishonest employees would likely avoid recording transactions altogether rather than voiding
them, the lack of system integration and oversight allows operators to bypass normal procedures
without detection. Without proper safeguards,transactions could be left unrecorded, increasing the
risk of financial mismanagement and weakening internal controls.
Despite recognizing this serious system vulnerability, the supervisor expressed confidence in the
integrity of the operators and did not see the need for further controls, relying on trust rather than
enforcing strict compliance with established procedures. A supervisor that relies on trust in lieu of
compliance with Departmental policies and procedures raises red flags as to his ability to properly
oversee and manage the transfer stations' operations.
We contacted the vendor that supports WasteWORKS to confirm the Department's understanding
of the system's limited functionality. According to the vendor, WasteWORKS has the ability to
generate detailed reports on voided transactions, including waste type, weight, vehicle
identification, operator activity, and timestamps. The system also supports audit trails and can be
configured to alert management when transactions are voided or modified. This discrepancy
suggests that Department management is either unaware of or has chosen not to use key reporting
features of the software. Given the importance of maintaining an auditable record of all
transactions, especially those transactions involving cash, it is imperative that management fully
leverage the system's capabilities.
Placing Customers On Hold
Transfer stations are open to the public Monday through Saturday from 8 a.m. to 3:30 p.m. A
transfer station operator's work shift typically is from 8 a.m. to 4 p.m. We found that transfer
stations have adopted informal procedures to allow transfer station operators to place customers
"on hold" at the end of a workday.Placing a customer"on hold"means not finishing the transaction
until the next workday. The Department's practice of placing a customer "on hold" was to apply
exclusively to the Department's commercial accounts to accommodate large trucks that required
loading when the transfer station was not open to the public. The reason for allowing larger
commercial customers to be placed"on hold" is to allow for more accurate weight measurements.
From our sampling of receipts, we found that customers were placed "on hold" at the close of
business 147 out of 280 days. More concerning is that our sample found 18 instances where cash
— 8 —
customers were placed"on hold"; a direct violation of the Department's standard practice. Despite
what we found in our sample, staff confirmed that cash customers should never be placed on hold.
When questioned, transfer station operators and the Transfer Station Supervisor denied placing
cash customers on hold; a claim that was contradicted by the Department's transaction records.
For example, on June 16, 2023, a cash transaction was placed on hold and later voided the
following day with the explanation that the "customer paid yesterday." However, we could not
find a recorded payment in the system to support this claim, leaving a gap in accountability and
raising questions about whether the funds were ever properly collected or possibly diverted.
Exhibit 2 shows how this transaction was recorded in WasteWORKS.
Exhibit 2
Recording of Cash Customer"On Hold"June 16,2023
003-0047 22 06/1.6/23 16:23 ON IM OLL1
Date 6/1 /2023
lime 3:41, P
003-00 24627 06/16/23 16.23 VOID *°* KEVIN 13:32:32 Reason: PAS" 6-16-23
Another example of a cash customer being placed "on hold" was recorded on May 20, 2023. The
transaction was for$51.68 and was voided on May 23, 2023,with the note: "customer never came
back to pay" as shown in Exhibit 3.
Exhibit 3
Recording of Cash Customer"On Hold"May 20,2023
licket Batch Report fw� Site 3
Ary "If / 9/ � 11, ', W A
fK43,N97iW 0i,r"nt''VW,3 1001P ** W11,0UY WM16 Id*a%w a':u%w: %ool"Or u,4,049 &'awck Vlaawy
Cash Voids W66
When we inquired about the 18 cash customers who were placed"on hold", we were advised that
these were likely customers who were unable to pay. In these instances, per the Department's
policies and procedures manual, the transfer station operators are expected to obtain additional
documentation from these customers such as the customer's license plate number and a copy of
their driver's license. This additional documentation allows the Department to seek legal action to
require these customers to pay for disposing of waste.
- 9 -
We found that none of the 18 transactions included the required documentation, leaving no way to
verify whether the customers ultimately returned to make payment. Additionally, on 16 separate
occasions,transactions that had been placed on hold were later voided, often with the justification
that the customer had never returned. This pattern raises significant concerns about the
management and oversight of the transfer stations' operations.
The failure to comply with policies regarding cash customers being placed on hold introduces
significant risks. Without the necessary documentation, transactions cannot be properly verified,
creating opportunities for errors, mismanagement, or worse. Additionally, voiding these
transactions without sufficient justification compromises the accuracy of financial reporting and
undermines trust in the integrity of the system. A lack of monitoring and enforcement only
exacerbates these risks, further weakening accountability and transparency in daily operations.
Reporting Drive-Offs
Transfer stations experience customers driving off before paying for the services rendered The
Department's manual outlines clear steps for handling this type of situation. Transfer station
operators are required to report the "drive off' to the Sheriff's office. Additionally, all three
transfer stations are equipped with security cameras that record activity, providing an additional
layer of oversight. We found that these procedures are not being consistently followed.
A review of transactions across all three transfer stations revealed multiple instances where
transactions were voided with the explanation that the customer drove off. However, further
investigation showed that in many of these cases, staff did not follow the required procedure of
notifying the Sheriff's office. Although the security cameras at the transfer stations store footage
for 30 days, the Transfer Station Supervisor was unaware of this retention period and does not
actively monitor or review the recordings.
When asked about reporting drive-offs to the Sheriff's office, Department management indicated
that these reports are maintained at the transfer stations and fall under the Transfer Station
Supervisor's responsibility. However, when asked, the Supervisor stated that he does not keep
such reports, explaining that he prefers to handle each situation on a case-by-case basis. He also
noted that he often chooses not to file reports,particularly in instances involving elderly or out-of-
state customers.
Even if the Transfer Station Supervisor regularly reported drive-offs to law enforcement,we found
that transfer station operators are not collecting key information when customers arrive at the
transfer station such as type of vehicle, license plate number, and the customer's Driver's License
_ 10 —
number and state of issuance. This type of information is critical for law enforcement to investigate
and prosecute offenders.
As documented above, our sampling of receipts noted material and serious shortcomings the
transfer stations' operations. The lack of controls and the lack of supervision over the transactions
being handled by transfer station operators has created an environment that needs the immediate
intervention by the County's senior management team. We recommend County senior
management work with the Department Director to strengthen controls and oversight at the
transfer stations including:
• Critically evaluate how the transfer stations are using available technology to manage
customer loads and processing receipts. The goal should be to ensure there is a seamless
integration between the transfer stations' scale system, the WasteWORKS billing system,
and the handling of cash transactions. It is imperative that controls are put in place that
staff are not able to bypass without management knowledge or pre-approval. The controls
must also ensure that each transaction performed by transfer station operators is
documented and generates an audit trail. Department management should be expected to
use the system's capabilities for oversight of the transfer stations' daily operations.
• Require all staff to understand and adhere to all departmental policies and procedures.
It is imperative staff understand that the departmental policies and procedures are not only
established to protect the County but also to protect the employee. Management should
develop policies and procedures that guide staff on how to process/handle all types of
transactions. Staff must be thoroughly trained in established policies and procedures. Staff
should be required to acknowledge, in writing, that they comprehend and will abide by the
Department's policies and procedures.
• Establish effective supervisory and management oversight of the transfer stations'
operations. Management and supervisors must be forbidden to turn a blind eye to
established policies and procedures because they trust their staff. It is important for
management to be visible at the transfer stations so staff know that management has
expectations for staff performance. Supervisors should work with management to
discipline employees who are not meeting expectations. The Department needs to establish
a formal reporting structure so management oversight is effective and responsive.
• Evaluate traffic control options. Improvements are needed so staff are able to effectively
control and avoid chaotic traffic flow. This may include strategic installation of gates and/
or traffic lights.
• Establish effective security measures at each transfer station. It is important that security
measures be implemented at each transfer station so staff and law enforcement are given
the tools to react when customers are causing problems.
� 11 �
Handling Of Cash By Transfer Stations
Transfer station operators are entrusted to properly handle and account for cash transactions. To
that end, proper control measures are essential to minimize errors and reduce the risk of
misappropriation. The previous audit conducted in 2012 highlighted weaknesses in this area,
particularly with the handling of cash shortages and overages. In response, the Department
committed to incorporating clearer guidelines into its Policies and Procedures Manual. During our
audit,we assessed whether these procedures were effectively implemented in the transfer stations'
daily operations.
Strengthening Daily Deposit Procedures At Transfer Stations
While transfer station operators and their supervisor indicated that deposits are counted under dual
control,our review found that the current work schedules do not fully support this practice. Instead
of two employees counting cash together, one operator typically counts the deposit at the end of a
shift, and another verifies it at the start of the next shift. While this process provides an additional
layer of oversight, it does not align with the standard definition of dual control, where two
employees count the cash simultaneously. The transfer station supervisor acknowledged that while
two employees sign the deposit paperwork, they do not conduct their counts together. This
approach defeats the purpose of the controls and results in a divided process that may allow for
discrepancies to go unnoticed and increases the risk of errors.
Another control designed to enhance accountability is the requirement for operators to complete a
daily cash form,which provides a detailed breakdown of deposits and serves as a verification tool.
However, rather than maintaining this daily record, Department management has adopted a
monthly sheet that only confirms that two operators have reviewed the deposit, cash drawer, and
safe at the beginning and end of each workday. While this practice offers a broad level of oversight,
it does not provide the detail needed to identify and resolve any discrepancies.
To strengthen controls and enhance accountability, we recommend the Department refine its
deposit procedures to align more closely with best practices. If it is not practical to ensure two
staff are available to prepare the daily deposit, one acceptable way to prepare a daily deposit is to
implement a"blind drop"method,whereby a designated transfer station operator prepares the daily
bank deposit without access to transaction records.Under this method,the transfer station operator
prepares the bank deposit without knowledge of the day's transaction detail. The designated
transfer station operator would deposit all funds received that day. This process would help
eliminate potential errors or discrepancies since the operator is not influenced by the day's
transactions. The independent preparation of the deposit would allow management to verify the
— 12 —
deposit amount against recorded receipts in WasteWORKS, improving the accuracy of financial
records.
Reporting Overages and Shortages
The Department's Policies and Procedures Manual emphasizes the importance of precise cash-
handling practices and requires that transfer station operators verify bank deposits against cash
tickets and summary reports. Any discrepancies must be documented before submitting the
paperwork to the Department's Key West Central Office. These measures are intended to uphold
financial integrity, minimize errors, and prevent the mismanagement of funds.
During the audit we observed a shortage in the daily deposit that had not been properly recorded.
When we inquired about the process for handling such discrepancies, the transfer station operator
explained that while shortages are reported to the Key West Office, overages—often referred to
internally as "customer tips"—are placed in a "coffee jar." The operator explained that the "tips"
are from customers who do not want change back or leave before the operator is able to hand the
customer their change.By placing these overages in a community tip j ar rather than including them
in the daily deposit, these receipts are not properly recorded in the County's accounting records
and are not subject to any controls.
In addition, our sample of receipts for 280 workdays revealed 79 instances of cash
overages/shortages. One case in our sample showed a reported shortage and its correction was
missing from the system. Some discrepancies were substantial, such as an overage of$560.96 on
June 22, 2023, and another of $231.00 on March 31, 2022 both detected by the bank. These
findings indicate inconsistencies and inaccuracies in cash-handling practices and indicate likely
policy violations.
The absence of a standardized reporting process for overages and shortages results in gaps in
oversight, allowing issues to go unnoticed until identified by external sources such as the bank.
Without a clear and structured process, financial controls are weakened, and the Department
remains vulnerable to undetected errors.
To strengthen controls and enhance accountability,we recommend the Department to incorporate
a "blind drop"method for preparing daily deposits at the transfer stations. This method, where
the designated transfer station operator prepares the daily bank deposit without access to
transaction records, would minimize the risk of errors or discrepancies in cash handling.
Additionally, we recommend the Department update its Policies and Procedures Manual to
clearly specify that management should, on a daily basis, verify bank deposits against cash
tickets and summary reports and properly account for all cash overages and shortages. This will
— 13 —
ensure that deposit amounts are accurately recorded and reconciled, reducing the opportunity for
mismanagement.
Assigning Tills To Employees
The Department's Policies and Procedures Manual outlines clear steps for maintaining
accountability during mid-shift transitions. It specifies that the outgoing transfer station operator
must cash out the drawer, while the incoming operator verifies and checks the balance.
Additionally, the manual requires that at the end of each shift or whenever operators change, the
cash drawer must be fully reconciled, with all funds counted and recorded on a cash sheet. These
measures are designed to prevent discrepancies and ensure accuracy in cash handling. Our audit
examined the procedures for cash drawer recounts during shift changes to assess whether
established controls were being followed.
During our review, we found no documentation to support that the cash drawer recount procedure
was being conducted. When speaking with staff, we received conflicting accounts of the process.
One staff person stated that a specific form is used for mid-shift recounts and is kept in the station's
safe. However, the Transfer Stations Supervisor provided a different account, explaining that no
dedicated form exists and that an extra daily cash form is used instead. This form, he stated, is
included in the daily work reports sent to the Department's Key West central office. However,
when asked,the Key West central office stated that no such form exists and indicated that it is left
to the discretion of the transfer station operators whether or not to follow established policies and
procedures.
The lack of a standardized form and proper documentation makes it difficult to verify whether
cash drawer recounts are consistently performed. Without a clear record of these recounts, errors
can go unnoticed. This increases the risk of financial mismanagement, inaccuracies, or potential
fraud, as there is no formal mechanism for tracking when and how the cash drawer is reviewed.
To improve these procedures, we recommend each operator be assigned their own cash drawer,
eliminating the need for recounting when shifts change and minimizing the risk of errors. If
individual cash drawers are not feasible,the Department should implement a standardized recount
form that details bill denominations and requires signatures from both operators involved in the
shift transition. The completed forms should be submitted to the Key West central office for
review. Adopting these measures would help strengthen cash-handling practices and enhance
accuracy when preparing daily deposits.
— 14 —
Credit Card Payments
The Department's policies and procedures requires "a check, cash, or credit card . . . must be
present for each load."3 Despite these guidelines, a review of receipts from all three transfer
stations revealed multiple instances where transactions were marked as "over the phone." When
questioned about this practice, the Department advised us that transfer station operators do not
process credit card payments over the phone. Rather, the term "over the phone" referred to those
instances when transfer station operators manually enter card numbers. However, during
interviews with staff, one admitted that when a customer's credit card fails, the customer may
contact someone within their company to provide an alternate card for payment. Transfer station
operators also reported that when cash customers fail to return after being placed on hold, the
operator calls them and offers to accept a credit card payment over the phone as an alternative.
The Department must take immediate steps to ensure compliance with its existing policy that
requires a physical credit card for all transactions. If credit card payments must be accepted over
the phone, we recommend the Department amend its policy to explicitly permit such payments
under strict conditions such as prohibiting the recording or storage of credit card numbers—
or modify the system to block such transactions entirely. The Department must ensure any policy
changes are consistent with the County's credit card policy as documented in Chapter 15 of the
Monroe County Purchasing Policy Manual. It is important for the Department not to jeopardize
the County's adherence to Payment Card Industry (PCI) standards. Adhering to PCI standards is
essential for ensuring the security of a customer's credit/debit card payment data. Violations of
PCI standards could result in serious consequences including increased risk of data breaches.
Another issue that arose during the review was the situation where customers report fraudulent
transactions after leaving the transfer station. In these cases, the payment is often canceled by the
customer's financial institution, typically because the customer notices two separate charges on
their statement—one for the payment of dumping fees and another for a $2.50 credit card
processing fee. This second charge, which does not appear under the name of the transfer station,
is often questioned by customers after-the-fact. Customers sometimes dispute the charge,
prompting their financial institution to cancel the entire payment, including the original
transaction. The $2.50 charge is not County funds but rather is a direct payment to the County's
credit card services provider.
To reduce customer confusion, we recommend that clear signage be posted at each transfer
station. In addition, we recommend transfer station operators be trained to advise customers to
expect two credit card charges. The signage should clearly explain the credit card processing fee,
the amount charged, and how it will appear on customers' credit card statements. By informing
3]bid.,p.4.
� 15 �
customers upfront, the county can reduce misunderstandings and minimize the risk of transaction
disputes.
Safeguarding of County Funds
Safeguarding County funds is a critical component of preventing theft,maintaining accountability,
and ensuring compliance. Proper security measures, such as locking safes, securing cash registers,
monitoring access, and regularly updating security protocols, help protect these assets while
fostering public trust. During our visits to the transfer stations, we observed practices that raised
concerns about the overall security and handling of funds, highlighting areas where improvements
are needed.
At one transfer station,the transfer station operator directed us to the safe, which was situated in a
separate room. However, both the room and the safe were unlocked and open, with no security
cameras monitoring the area. Additionally,the operator's cash drawer remained unsecured. When
asked about the safe's security, the operator explained that a malfunction in the combination
mechanism prevented them from locking it using both the key and combination, further
compromising its security.
At one transfer station, the safe key was kept in the Supervisor's office, which was left unlocked
at the time of our visit. While the operator did use the key to lock the safe, he failed to spin the
combination lock, leaving the safe susceptible to be opened with simply a key. The accessibility
of the Supervisor's office meant that anyone who entered could potentially retrieve the key. At
another transfer station, a safe key was stored in an unlocked drawer near the register. While we
were told that the safe required both a key and a required code to open, the operator was able to
open the safe by using the key and entering a random incorrect code.
Further discussions with the Transfer Station Supervisor revealed additional vulnerabilities with
the handling of keys. While the office key can be duplicated, the safe key requires a specialized
key maker and written approval for duplication. Despite this safeguard, if an individual were to
duplicate the office key, they could easily access the safe key. Another issue involved the
collection of keys from past employees. Although Department management assured us that all but
one former employee had returned their keys—prompting the replacement of the office key—no
formal records existed to verify these returns. Without signed documentation confirming key
collection, the County is unable to ensure that former employees no longer have access to secure
areas.
To address these concerns, we recommend measures be taken to improve security and safeguard
financial assets including:
— 16 —
• Installing cameras in all safe rooms to monitor access to cash storage areas, ensuring
that all interactions are documented.
• Regularly reviewing camera footage and maintain a log to track when the Supervisor
checks the recordings.
• Changing safe combinations routinely in line with bestpractices to prevent unauthorized
access.
• Requiring both the key and combination each time the safe is opened to maintain proper
security protocols.
• Ensuring all cash drawers are lockable and that operators keep them secured at all times.
• Restricting access to the safe key by storing it in a locked and secure location.
• Implementing a formal key return process for departing employees, requiring signed
documentation to verify key collection and reinforce accountability.
By taking these steps,the Department can significantly improve the security of its financial assets,
reduce the risk of unauthorized access, and strengthen overall accountability. With enhanced
measures in place, the County will be better equipped to safeguard public funds and ensure that
proper financial controls are maintained.
Solid Waste Policies and Procedures Manual
Written policies and procedures manuals are an important internal control that provides
management assurance that staff are given detailed instruction on how to do perform their job
duties and responsibilities. Manuals allow management to communicate their expectations to staff.
Because it is such a critical communication tool, it is important for manuals to be regularly
reviewed and updated by management in addition to staff being required to acknowledge that they
read and understand the policies and procedures set forth in the manual.
As part of our audit procedures, we reviewed the current version of the Department's Monroe
County Solid Waste Policies and Procedures Manual For Scale Operations as well the process for
distributing it to staff. When we requested a copy of current manual, we were informed that the
manual was only available in paper format. While the Department reported that the manual had
been updated within the last 3-6 months, our review indicated that there appears to have been no
substantial update of the manual since 2013. The Department also advised us that all transfer
— 17 —
station operators had copies of the manual and received proper training. However, when we
conducted site visits, transfer station staff could not produce a copy of the manual. In fact, some
staff reported never being provided the manual.
We recommend the Department take immediate steps to:
• Review and update the manual;
• Distribute the updated manual to all staff;
• Require staff to acknowledge that they have received, read, and understand the
Department's policies and procedures;
• Develop training for staff to reinforce the Department's cash handling procedures; and
• Develop a process for management to review and update the manual on a regular basis.
� 18 �
Appendix I
Solid Waste Response
To Audit Report
� 19 �
BOA"OF C°C)L":`«'TY CC?1N IISSIONT-RS
Countyof Monroe r�"a� !+�d'w;«^or 3 Scholl,Lbestut 3
Mayor Pro Tom NficheUe Lincoln,Distirct 2
�& Florida� �4 ' Craig Gate-,Di,,tnct 1
"tl l �' '" David Rice„Di:trxt 4
i,,�"'� oUy Menril Rawliem,Di-,,taact a
DATE,; JUNE 26, "2025
M Kalina l3iugle. Senior Innternnal Auditor
Kevin Madola,CPA-Clerk of the Circuit Court and Comptroller
Pan Radloff,Interinn Internal Audit Director
FROM- Cheryl Sullivan, Director
Solid Waste Management
SUBJECT- Monroe County Solid Waste Mmiagement
Internal Audit Report,Cash I°ILandhng
Dear Ms,Kiliria Binngle„
I would like to t1vin c you for tine tainnte and tenacity you applied to the audit of Monroe County Solid Waste
Management, Your knowledge and experience in processes and financial ruaaa,gernnent;can only help make the
department stronger and better equipped to provide confidence for the citizens of Monroe County,
Through you recommendations we,have implemented the following processes,procedures and tools to
improve consistency,accountability and security of daily operation rind cash. The improvements below along
with feedback on the department operation and the challenges Solid Waste encounters daily will hopefully
help everyone understand we are not challenging the report but hoping to iriforin you as to why source points
may not be as they seeernn,
hi plenn erntatiorns
r� Updated Solid Waste Policy and Procedures l aanaual with current processes and recoinnnnienndwatiorns,.
to be maintained and updated periodically as needed by administrative staff:
Conducted group training and review of PPNI for all scales operators..with signed acknnowledgernernt
of trailing and understanding,along with being posted at each mwisfer station,
Initiated and trained staff on"bliiad deposit"procedure
Daily drawer count using denoinination sheet for both opeiniung,and deposit as required.
All new Hires will complete a"Key Assignment Sheet".along with current staff,with signed
acknowledgement form..
An additional camera liar been installed in each safe room,directed at the safe,by the IT
Department.
New locking cash register draws that connect to scale softuvare are positioned to be ordered,
currently on backorder froizn tine maaxnufaacture. We are ordering drawers reconannennded by the
soft vare company that are compatible with the Waste Works prograatri.
r A recent upgrade to Waste Works software and identified reports we were not aware of.
- 20 -
Solid Waste Management of Monroe County is critical to the health and well-being of the conirminiq,by
providing a sere ice riot only for residential garbage collection and removal but also for corarriercial debris
collection anti disposal,During the audit review years,2021-2024,the three transfer stations processed 164,340
tickets for an average of 54,780 tickets per year.
Response to findings and recommendations.
To avoid the duplication/copying of tickets issued for a scale weight,a"water inark"was added for security
because,of the 2012/2013 audit.If in fact a ticket is copied the word"voiCis displayed oil the copy. To
explain ticket minibers being"out of order".Tickets are printed oil a continilous rem of 1000 tickets per box,a
total of 50-60 thousand tickets are ordered in bulk per year, Each transfer station is issued a box as
needed/requested by the transfer station operator. The operator must sign an acknowledgment form that they
received time tickets, reviewing that numbers are consecutive, What we have found is that the operator has at
times filled their prilater by putting;the new tickets oil top of the old tickets,instead of putting their under the
current ticket.,,,being used,this would cause tickets to tie out of order. 'I'lirough group training we emphasized
the importance of keeping the tickets iii order and being mindful of their job responsibilities. It is also the
operators responsible for Informing the administrative staff or supervisor of any irregularities or reasons wily
tickets would be out of order throughout flieff shift.
Voided tickets are going to happen due to many factors in the solid waste environment, Some of time reasons
include,custorners providing wrong information as to material in load(yard waste,construction,white goods,,
etc.,payment type,change(credit card won't process,mast pay cash),wrong account number,human error by
scale operator keying in wrong material type. account nuniber.,inbound was outbound and conuirunication
limitations or confusion front customers who don't understand or speak English. In reference to Nov. 19,2021,
concern,We were able to research and find that transaction(see Exhibit B)and provide time followulg
explanation, This ticket was voided before an"out"'weight was taken for the wrong material vype,only the"rem"'
gross weight in on the ticket, Then when it was weighed back in you see the gross weiglit of the correct
material,and then the net weight ofwhat was dropped off hi reference to June 7,, 2024(see Exhibit Qthere
was another transaction that supports the void was collected. After multiple conversations with Waste Works
we were able to find,there is a report to provide a detailed transaction report,which will allow us to monitor
vol(Is more thorou911 . , Staff have been itifornied they must provide substantial inforniation as to why a ticket
must tie voided,and fallure to do so may result in disciplinary action
Placing customers on hold was also identified is a finding, While I understand the firiding and support flie
finding.I offer the followilig niforniation regarding why a ticket inay be put on hold. In reference to the June
16,2023„transaction placed oil hold,we find it was accounted for on June 17,2023(see Exhibit A).Another
reason a ticket may be,on hold is if someone, forgets their wallet or does riot have enough nioney to pay for the
transaction, We then tell there they have till the end of business hours to pay for their ticket.We then get a
copy of their license. good phone number and write down the license tag, If they don't return by the end of
business hours,it will be turned over to the sheriff s department,We are continuing to work with staff to
educate why they should riot be,placing a ticket on hold,if a cif cumstarice occurs and they are not sure how to
handle it,they should be reaching out to administrative staff or supervisor for direction.
Drive-offs do happen,occasionally, intentionally or accidentally,and should be all area we strive to Unprove
upon. While we do serve a diverse group of people,from all areas of the country, some who don't have to pay
when they go to a disposal facility vs a business vs a local who understarids the workings of Monroe County
transfer stations. We currently have sigriage but will be looking to update signage at the scales to better infoint
customers they rust;stop at scales before leaving arid reiterate verbally upon entry to the scales the need to stop
before leaving, We have looked at traffic arms,and/or stop lights, as recommended, Due to space limitations
- 21 -
and traffic flow in acid out over the scales this type of inechamisin may cause a back tip of large trucks and
trailers,which in turn could cause a.health safety issue. However.we will continue to look for ways to reduce
drive offs front happening. it has been discussed with the supervisor that all drive-offs should be monitored by
hill for follow tip with the sheriff s office
Strengthening daily deposits and cash controls is always taken very seriously. We have improved
accountability through verification processes.,however,through your expertise in finance and recommendation
we have changed some of past practices going forward as identified under-implementations". The audit did
not reflect airy missed deposits,or gross shortages/overages While there was a discrepancy on the Daily
Collection Surrunary Sheet dated 03/3112022 which was a,"clerical error"in the aniourit collected m Long Key,
the,correct amount was written on the deposit ticket and deposited correctly at the bank and again On
06/22/2023 for Key Largo, Discussions with adininistrative staff to ensure the surarwry sheet breakdown
matches the reconciliation repots front Alaste "rorks intist be accurate, When I investigated the reporting,of the
dates above, I did see that the back tip that was sent to the clerk's office from Waste Works balanced the
deposits niade,however the manual simunary sheet that was sent did not match. I would like to respectfully
ask that if or when the clerk's office identifies a clerical error such as these that I be notified so I call take
disciplinary action if applicable,to hold those accountable. Regarding the safe being open and unlocked. I
spoke with the super,-isor as to why this was hippening. The supervisor explained that lie did in fact tell the
scale operators to make sure the room and safe were unlocked on the day you were.coraing. He instructed them
to do this in case they(scale operators)ivere busy with customers and to inake it easy for you to access in a
timely maturer. Hindsight 20x2O was not a good(lecision, and he realizes it after he and I discussed the
situation, The supervisor assured me this is not normal practice and both the,room and safe, are always locked.
The spare key to the safe is now being kept in the safe room,which is always locked,not the, supervisor's
office.Access to the safe which is always locked, can be opened with either/or,a key or combination,which
his always been the case. We Iiive,also installed an additional camera that points directly at the safe. The
transfer station reporting;of overages came tip as a reference internally as-customer tilys,"are placed in a
"coffee jar". The staff does not solicit tips,and ni;airtgement will not support any such reference. It is my
understanding that the"coffee Jar-is when a customer does not want the 3 cents of change and is then used if
someone is short 2-3 cents. As we know this type of change method is standard throughout the business
coitununity,and not a"tip"if you would, However,I respect the acknowledgement and understand that it is
"unaccounted for money",At your recommendation ure have implemented the"blind deposit"and added the
change left by custorneis. The daily counting of drawers at the begurning of the day was being counted by two
scale operators.,except for the days when onty one operator was available,which usually is on a Saturday or
Monday. At your recorimiendation each operator must fill out the denomination sheet at the beginrung of shift,
sign to acknowledge the cash drawer is correct and then again when making the deposit,the sheets will be kept
on file with daily operations, The assign
ment of a drawer to each operator would require an additional 5
drawers assigned, for a total of 8 drawers,and additional monies on site.With space limitations.and additional
cash that would be,required to be oil site.,we will be purchasing new locking cash drawers that will engage with
the Waste Works software when they are back in inventop y,one for each transfer station. In reference to credit
cards. Because there may be time-,,it is necessary for a scale operator or administrative staff to take a payment
of the phone, at,your recominenlation Solid Waste is preparurg an acknowledgement form that roust be sigired
by each staff member taking phone payments,that-they will not record or store any credit card numbers or
informition". Because the$2.50 service fee through"Snap Pay"shows tip as a separate item.customers seem
to be confused and think it has already been charged. There are signs at all the transfer stations,and we stamp
the,tickets explauling the$2.50 charge.We are changing the start p fliat is currently used for the tickets,with
more explanation, and rewording the signage at the,transfer station window.
- 22 -
Kalina,I appreciate your lusiglit,professionalism,knowledge and reconunendations to help Solid Waste be a
futancially secure and accoitntable department.,with sound busitiess practices. We are all Ininian and raist.*es
are going to happen,however using safeguards,best practices,being proactive,and seeking knowledge to
improve is soinethirig that benefits us all,
Tlimik you for the opporhunty to share the improvements and explanations.
Sincerely,
S'
Cheryl Sullivan
Director,Monroe,County Solid Waste Management
- 23 -
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