City of West Palm Beach Internal Audit Department
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1 POST AUDIT REVIEW OF THE PROCUREMENT CARD PROGRAM Report No. PAR October 17, 2016 City of West Palm Beach Internal Audit Department Roger Strout, City Internal Auditor, CIA, CRMA, CFE, CICA Beverly Mahaso, Deputy City Internal Auditor, JD, CFE Elena Georgiev, Senior Internal Auditor, CPA, CGMA Ellen Misita, Senior Internal Auditor
2 10/17/2016 Audit Committee City of West Palm Beach 401 Clematis Street West Palm Beach, Florida RE: POST AUDIT REVIEW OF THE PROCUREMENT CARD PROGRAM, AUD Dear Audit Committee Members: On September 15, 2015, the Internal Audit Department released an audit of the Procurement Card Program. We performed certain procedures, as enumerated below, with respect to activities of the Finance Department (Finance) in order to render a conclusion on the status of the recommendations made as a result of that audit. This Post Audit Review consisted primarily of inquiries of City personnel and examinations of various supporting documentation. It was substantially less in scope than an audit in accordance with generally accepted government auditing standards. The evidence obtained provided a reasonable basis for our conclusions; however, had an audit been performed, other matters might have come to our attention that would have been reported to you and our conclusions may have been modified. The audit contained six (6) recommendations that addressed the audit s findings. Based on the review performed, we concluded that recommendations 2 and 3 were implemented, and recommendations 1, 4, 5, and 6 were partially implemented. 1
3 Recommendations Status 67% 33% Implemented - 2 Partially Implemented - 4 We have enclosed a table listing all the recommendations with the current statuses. We found that management made significant effort to take corrective action. We thank the personnel at the Finance Department for their assistance in conducting this review. We encourage them to continue their efforts and fully implement the recommendations provided. Respectfully submitted, /s/ Roger Strout City Internal Auditor cc: Shanon Materio, Commission President Keith James, Commissioner Sylvia Moffett, Commissioner Paula Ryan, Commissioner Cory Neering, Commissioner Jeffrey Green, City Administrator Dorritt Miller, Deputy City Administrator Mark Parks, Chief Financial Officer Encl. 2
4 Post Audit Review of Procurement Card Program AUDIT RECOMMENDATIONS Legend Implemented Partially Implemented Not Implemented No. AUDITOR S RECOMMENDATION MANAGEMENT S RESPONSE MANAGEMENT S STATUS UPDATE 1 The Department should ensure that the Purchasing Card Policies and Procedures provide sufficient guidance by: Dedicating resources to update, approve, and post them timely. Ensuring that all relevant matters are fully addressed. Providing guidance with examples of purchases that are appropriate for public purposes versus non-public purposes. Providing refresher training courses on the updates made. We agree and are ensuring that the Purchasing Card Policies and Procedures provide sufficient guidance by dedicating resources to update, approve, and provide the updates to the Purchasing Department ensuring that all relevant matters are fully addressed. The policies will provide guidance with examples of purchases that are appropriate for public purposes versus non-public purposes. The Finance Department in concert with the Procurement Department has committed to providing refresher training courses on the updates made. Partially Implemented: Per discussion with the Treasury Manager, the Finance Department is currently in the process of updating the Purchasing Card Policies and Procedures. A copy of the draft Policies and Procedures was provided to Internal Audit for review. 2 The Department should ensure that only necessary cards are issued by continuing to review cards for low activity and cancelling unnecessary cards. It is understood that this will probably not reduce the number of transactions that must be reviewed, but it will reduce administrative time and risk. Further, Fleet should review its use of P-cards to determine whether the manner in which P- cards are used is reasonable and appropriate. Further, Fleet should review high volume and high dollar value purchases and determine whether they could benefit from being competitively bid. We agree and will work with City departments to ensure that only necessary cards are issued. We will continue to review cards for low activity, slow reporting and cancel unnecessary cards or cards that do not meet stated reporting requirements. The Finance Department will work with Fleet and Purchasing in reviewing its use of P-cards to identify purchases that could benefit from being competitively bid. Implemented: The Finance Department staff has begun performing quarterly analysis of the procurement cards usage. In addition, the Treasury Manager runs an exception report to see if departments submit their documentation in a timely manner. If they do not, departments are informed of that. An additional procedure, related to issuing new cards/increasing credit limits, was introduced. Before issuing a new card or increasing the credit limit of an existing card, the Treasury Manager performs an analysis of the current usage and then makes a decision. Three (3) of Fleet's six (6) cards were closed and their transactions are closely monitored. 3
5 Legend Implemented Post Audit Review of Procurement Card Program Partially Implemented Not Implemented No. AUDITOR S RECOMMENDATION MANAGEMENT S RESPONSE MANAGEMENT S STATUS UPDATE 3 The Department should ensure that adequate We agree and will work to affirm that adequate Implemented: The Finance Department has review and approval procedures are in place by review and approval procedures are in place by identified an alternative way of addressing this establishing procedures requiring reviews of establishing procedures requiring reviews of issue. It has begun removing vendors from the receipts and statements promptly. Receipts receipts and statements promptly. Receipts pre-approved purchasing card list and requiring should be reviewed and initialed by the shall be reviewed and initialed by the departments to submit purchase orders instead. cardholders supervisor as the purchases are cardholder s supervisor as the purchases are made, or shortly thereafter. Further, each made or shortly thereafter. Further, each statement should be reviewed and signed by the statement shall be reviewed and signed by the Department Approver and the Department Department Approver and the Department Manager. Finally, the Policy and Procedures Manager. The Purchasing Card Policies and should be updated to reflect the changes. Procedures shall be updated to reflect the changes. 4 The Department should ensure that all departments remit monthly statements and receipts in a timely manner by enforcing procedures that: State when reconciliation documents are due, and Require deactivation of procurement cards when policies are not followed. 5 The Finance Department should ensure that tax reimbursements are received by establishing a procedure to monitor, track, and request fuel tax reimbursements on a monthly basis. Further, for the reimbursements that are currently available, the Department should file the requests for reimbursement with the FDOR for the past three years and track usage in the future to facilitate quarterly filings. The Department should work with the FDOR and attempt to reach an agreement with the FDOR on a procedure to estimate usage and avoid We agree and affirm that all departments shall remit monthly statements and receipts in a timely manner by enforcing procedures that state when reconciliation documents are due. Late reporting will result in deactivation of procurement cards when policies are not followed. We agree and will work with the Fleet Department to assure that tax reimbursements are received by establishing a procedure to monitor, track, and request fuel tax reimbursements on a monthly basis. Further, for the reimbursements that are currently available, the Finance Department will evaluate filing the requests for reimbursement with the FDOR for the past three years. Finance will work with Fleet to track usage in the future to facilitate quarterly filings. With assistance from Finance, the Fleet Department should work with the FDOR and attempt to reach an Partially Implemented: As mentioned in item #2, an exception report is being run, but the cards are not being suspended yet. The Treasury Manager is drafting a memo to department heads to inform them of the future suspension of cards belonging to holders who do not submit their statements and receipts in a timely manner. Partially Implemented: Per discussion with the Treasury Manager, the Finance Department is currently in the process of establishing procedures for filing for tax reimbursements. A file was created by Finance, which is in turn updated by Police with the number of gallons purchased. 4
6 Legend Implemented Post Audit Review of Procurement Card Program Partially Implemented Not Implemented No. AUDITOR S RECOMMENDATION MANAGEMENT S RESPONSE MANAGEMENT S STATUS UPDATE manually calculating gallons of fuel from agreement with the FDOR on a procedure to individual receipts. Because of the three-year estimate usage and avoid manually calculating limitation, this should be done immediately, gallons of fuel from individual receipts. The starting with the transactions approaching the process to request reimbursement and work three-year limit. with Fleet and FDOR will begin immediately, starting with the transactions approaching the three-year limit. 6 The Department should update its Policies and Procedures and implement a process for reconciling rebates, including those from the Bank of America. Further, the Department should review other programs to determine if a more favorable rebate program is available. Finally, the Department should consult with the City s Legal Counsel regarding any contractual obligations with the Bank of America or the State of Florida that may impact changes to the current rebate program. We agree and will update the Purchasing Card Policies and Procedures and implement a process for reconciling rebates, including those from the Bank of America. Further, the Finance Department will periodically review other programs to determine if a more favorable rebate program is available. Partially Implemented: The Treasury Manager attempted to reconcile the amount received for FY 2014 and FY 2015, but a discrepancy was noted. He is currently working with BOA to understand what causes the discrepancy. In regards to identifying alternative programs, the Treasury Manager is examining options. 5
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