12 05 City Cash Receipts Audit Report
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1 O FFICE O F T HE C ITY A UDITOR C OLORADO S PRINGS, C OLORADO City Cash Receipts Audit Report Some parts of this public document have been redacted in an effort to minimize the opportunity for control weaknesses to be exploited. A copy of the report without redactions has been shared with City management and City Council. March 2012
2 O FFICE O F T HE C ITY A UDITOR C OLORADO S PRINGS, C OLORADO City Cash Receipts Audit Report March 2012 Purpose The purpose of this audit was to evaluate the adequacy of the internal control environment related to cash receipts and determine that City resources were adequately safeguarded. We also evaluated whether collections were being processed accurately. Highlights Generally, we concluded that reasonable assurance exists that City resources were appropriately safeguarded. We observed that some deposit locations had stronger internal controls and segregation of duties in place than others. The limited staffing at some locations made it difficult to separate duties appropriately. The internal controls over cash receipts were not adequate in some areas. However, most locations tested that processed significant receipts had adequate internal controls in place. Designing and implementing the internal control processes and structure is the responsibility of City management. As management establishes internal controls, various risks should be considered and weighed against the cost of alternatives to address those risks. The City s cash receipt activities were decentralized throughout the City geographically and departmentally. When the internal control environment surrounding cash receipts is decentralized, it is more convenient for citizens to interact with the City and pay amounts due the City. However, a decentralized system that does not incorporate adequate staffing to ensure segregation of duties also increases the risk of loss by the City. (Continued on page 2) Management Response City Management was generally in agreement with the recommendations made. See specific responses in the report. Recommendations 1) Management should address segregation of duties concerns. 2) System user access should be reviewed and adjusted. 3) City Auditorium staff should maintain a system to track open contracts. 4) Internal controls over cash receipts should be strengthened in some departments. 5) Deposit slips should be reviewed by someone other than the person preparing the deposit. 6) Mail should be opened under dual control. If that is not feasible, mitigating controls or payment processes should be developed. 7) An employee, who does not issue checks from the refund checking account, should review the activity in the account and perform a monthly reconciliation. 8) The City should complete a cost benefit analysis related (Continued on page 2)
3 12 05 City Cash Receipts Audit Report March 2012 (Highlights continued from page 1) During our audit, we visited 21 of the 60 locations accepting cash payments. Our audit focused on the period from January 1, 2011 through April 15, We identified areas where processes could be improved. These opportunities are detailed on the pages that follow. (Recommendations continued from page 1) to credit card payment transaction fees and consider alternatives, especially for payments made from related entities such as Colorado Springs Utilities. 9) The City should evaluate opportunities for increasing efficiency through automated interfaces, electronic cash drawers, and similar technologies. 10) The City should consider whether payments should continue to be accepted at all current locations. 11) Deposits should be made and recorded on a consistent basis. City Council s City Hall 107 North Nevada Avenue Suite 200 Mail Code 1542 Colorado Springs CO Tel Fax Reporting Hotline
4 OFFICE OF THE CITY AUDITOR PUBLIC REPORT Date: March 28, 2012 To: Re: President Hente, President Pro Tem Martin, and Members of City Council City Cash Receipts We conducted an audit of the City of Colorado Springs Revenue and Collections functions as part of our financial system cycle reviews. Our audit focused on the period from January 1, 2011 through April 15, The purpose of this audit was to evaluate the adequacy of the internal control structure and receipting procedures of the City. The cash receipting system for the City was decentralized and payments were accepted by a number of different departments. To accomplish our audit objectives, we reviewed departmental policies and procedures and conducted interviews with management. The audit included obtaining an understanding of the internal control structure for each department s cash receipts operations and recording of revenue as well as limited testing of each group s transactions to determine whether policies and procedures were being followed. For security reasons, we found it necessary to redact certain areas of the report. The areas blacked out in the following fashion, ''''''' '''''''' represent the areas redacted. This was done in accordance with all relevant laws, including (2)(VIII)(A),C.R.S. We observed that some deposit locations had stronger internal controls and segregation of duties in place than others. The limited staffing at some locations made it difficult to separate duties. The internal controls over cash receipts were not adequate in some areas. Most locations tested that processed significant amounts in receipts had adequate internal controls in place. Accordingly, we concluded that reasonable assurance exists that City resources were appropriately safeguarded. We identified several observations related to segregation of duties and internal controls. We have listed our recommendations for each in the attached report. City Management has been provided the details on the issues. Their responses are included. We would like to thank the staff from each department for their time and help in completing this audit. As always, feel free to contact me if you have any questions. Sincerely, Denny Nester, MBA, CPA, CIA, CGFM, CFE, CGAP City Auditor City Council s City Hall 107 North Nevada Avenue Suite 200 Mail Code 1542 Colorado Springs CO Tel Fax Reporting Hotline
5 Cc: Steve Bach, Mayor Laura Neumann, Chief of Staff Steve Hilfers, Interim Finance Director Kara Skinner, Interim Budget Director Candice Bridgers, Controller Rick Lewis, Municipal Court Administrator Wendi Lichtenegger, Municipal Court Operations Supervisor Kim King, Parks and Recreation Manager Greg Warnke, Parking Administration Manager Cindy Conway, Interim City Clerk Leslie Hickey, CSFD Fiscal Planning & Analysis Manager Nancy McCauley, CSPD Fiscal & Planning Analyst Principal
6 OFFICE OF THE CITY AUDITOR PUBLIC REPORT Report Details... 1 Purpose... 1 Scope... 1 Background... 3 Commendable Practices... 3 Conclusion... 3 Observations, Recommendations, and Responses... 4 Observation 1 - Segregation of duties concerns were noted in nine deposit groups... 4 Observation 2 IT system user access conflicts were noted... 6 Observation 3 The City Auditorium did not maintain a system to track open contract amounts Observation 4 ''''''''''''''''''' ''''''''''' internal controls over cash receipts were not adequate Observation 5 The ''''''' '''''''''' Department system had control weaknesses Observation 6 Deposit slips were not being reviewed Observation 7 Mail was not opened under dual control Observation 8 '''''''''' ''''''' '''''''''''''''''''' ''''''''''''' Office refund checking account was maintained and reconciled by one employee Observation 9 Credit card processing fees were not added to customer balances but were paid by the City Observation 10 Automated interfaces and electronic cash drawers were not in place in a number of locations and cost benefit analyses had not been performed Observation 11 Payment activity may be more decentralized than necessary Observation 12 Some locations did not make and record deposits on a consistent basis... 20
7 REPORT DETAILS PURPOSE We performed an audit of the City s Revenue and Collections functions, including various enterprises and departments that accept payments from the public. The purpose of this audit was to evaluate the adequacy of the internal control environment related to cash receipts and determine that City resources were adequately safeguarded. We also evaluated whether collections were being processed accurately. SCOPE The scope of the audit included reviewing the processes used in accepting, posting, and depositing payments by cash, check, and credit card, as well as proper segregation of duties. Our audit focused on the period from January 1, 2011 through April 15, Our methodology included an examination of various department s records and activities. To accomplish our audit objectives, we reviewed departmental policies and procedures as well as obtained an understanding of the internal control structure for each department s cash receipt operations and recording of revenue. We performed a risk assessment to determine which areas to test. Our selections included locations accepting high dollar low volume amounts, and high volume low dollar amounts. We also selected locations where budgetary constraints resulted in reduced staffing levels. Based on our selections, we conducted site visits at nine departments or enterprises, some with multiple locations, which had cash receipting and processing responsibilities. These departments and enterprises consisted of 21 of the 60 locations that accept cash payments from the public. These 21 locations received 42% of the 2010 City revenues. (See Table 1 City Deposit Totals on following page for details.) We interviewed management and staff. We observed daily operations to identify the systems used and procedures in place for collecting, handling, recording, and depositing cash receipts. We also tested a sample of each group s transactions to determine whether the locations were following policies and procedures. Some cash receipts were processed by vendors on the City s behalf and deposited directly to the City s account, for example the Transit contractor directly deposits fare collections from bus routes. In these cases, we obtained the vendor s procedures and reports to ensure controls were in place. Additionally, in some cases, the City contracts with third party operators for some facilities, such as golf courses. We reviewed these locations to ensure receipts were deposited in a timely manner, but we did not review the vendor s control procedures for cash collection as it was not within the scope of our review. Page 1 of 21
8 TABLE 1 CITY DEPOSIT TOTALS GROUPS TESTED IN AUDIT 2009 TOTAL DEPOSITS % OF TOTAL 2010 TOTAL DEPOSITS % OF TOTAL CITY FINANCE $19,578, % $30,316, % HUMAN RESOURCES $251, % $166, % CITY CLERK $853, % $1,105, % CEMETERY $1,160, % $1,112, % PARKING ADMINISTRATION, GARAGE, & METERS $3,224, % $3,283, % TRANSIT $3,779, % $6,041, % PARK & RECREATION ADMMINISTRATION $1,587, % $1,347, % SPORTS OFFICE $1,010, % $1,298, % SERTICH ICE CENTER $512, % $631, % COTTONWOOD RECREATIONAL FACILITY $500, % $471, % HILLSIDE COMMMUNITY CENTER $97, % $123, % CITY AUDITORIUM $99, % $154, % VALLEY HI GOLF $1,157, % $1,069, % FIRE $1,541, % $1,076, % POLICE $5,186, % $5,397, % MUNICIPAL COURT $4,466, % $4,238, % PIKES PEAK HIGHWAY $3,511, % $4,549, % TOTALS TESTED LOCATIONS $48,518, % $62,384, % TOTAL OTHER LOCATIONS $68,210, % $84,950, % TOTALS $116,728, % $147,334, % Page 2 of 21
9 BACKGROUND The City s cash receipt activities are decentralized throughout the City geographically and by departments. When the internal control environment surrounding cash receipts is decentralized, it is more convenient for citizens to interact with the City and pay amounts due the City. However, a decentralized system that does not incorporate adequate staffing to ensure segregation of duties also increases the risk of loss by the City. Designing and implementing the internal control processes and structure is the responsibility of City management. As management establishes internal controls, various risks should be considered and weighed against the cost of alternatives to address those risks. City staff at most locations recorded payments in their department specific system and the City s accounting system, prepared the deposit, and provided deposit details to the City Finance Office for reconciliation. In most cases, an armored car service transported the deposit to the bank. Nonsufficient fund (NSF) processing and processing of unpaid invoices for collections were centralized in the City Finance Office. Each location or department was responsible for collecting the NSF checks and remitting funds to City Finance. The individual deposit groups were also responsible for determining the timing of when past due accounts would be sent to a collection agency by the City Finance Office. COMMENDABLE PRACTICES During the audit, we interacted with several deposit groups with limited resources and small numbers of staff. Due to the limitations present, in a number of cases, staff had engineered creative ways to strengthen internal controls. For example, a Parking Administration employee conducts monthly unannounced audits of the parking garage vendor s deposit. CONCLUSION The cash receipts process at the City was decentralized with various systems and processes in place at the 60 locations that accepted payments during our audit period. We observed that some deposit locations had stronger internal controls and segregation of duties in place than others. This was because the limited number of staff at some locations made it difficult to separate duties, resulting in some level of risk that receipts would not be recorded. As most locations tested that processed significant receipts had adequate internal controls in place, we conclude reasonable assurance exists that City resources were appropriately safeguarded. The items we noted were related to segregation of duties and department system user access. City Management has been provided the details on the issues and will be working to address the items. Their response to each observation is included in this report. Page 3 of 21
10 OBSERVATIONS, RECOMMENDATIONS, AND RESPONSES OBSERVATION 1 - SEGREGATION OF DUTIES CONCERNS WERE NOTED IN NINE DEPOSIT GROUPS Segregation of duties involves separating certain areas of responsibility and duties in an effort to reduce the possibility of fraud and unintentional mistakes. These procedures provide an internal check on activities by separating duties involving custody of assets, authorizations surrounding the assets, and record keeping. Management should establish procedures to separate duties and responsibilities of personnel who accept cash receipts. For example, a staff member receiving customer payments should not be preparing the bank deposit. As part of our audit, we examined the cash receipt handling processes. We observed that the proper segregation of duties for cash handling and processing was not always in place (See specific observations in chart below.) In some cases, this situation may have resulted from budgetary constraints that yielded reduced staffing levels. Management should be aware that the lack of segregation of duties increases the risk of inappropriate cash handling and the misuse of funds. AUDITOR S RECOMMENDATION We recommend Management require that a reconciliation of cash receipts be performed by someone other than the person receiving the funds. This person should also be reviewing the deposit slip for completeness and noting their approval by signature on the document. When staffing levels do not permit duties to be separated, management should adequately review the duties performed on a frequent basis. Specifically for the areas where deficiencies were noted, we recommend the following: Deposit Group Observation Recommendation Management Response '''''''' '''''''''''''''''''' Staff levels require that the Office Specialist receive payments and record the deposit. Maintain and reconcile a log book for receipt numbers to track usage. Have management reconcile the cash receipts in the deposit to the payment log to verify all cash receipts are included. recommendation and will implement the recommended corrective action in January ''''''' ''''''''' Four employees accept payments, record them, and prepare the deposit Have the Supervisor review the deposit against the system detail of receipts. recommendation and have implemented the recommended procedure. Page 4 of 21
11 Deposit Group Observation Recommendation Management Response '''''''''''''''''''''' '''''''''''''''''''' '''''''''''''' Staff levels require that the Office Specialist prepare and record the deposit without review. Have the Head Cashier or their backup prepare the deposit and the Administrative Technician review and record the deposit. recommendation and will implement the recommended corrective action in January ''''''''''''''' ''''''''''''''''''''''' '''''''''''''' Staff levels require that the Office Technician receive payments and prepare the deposit. Have the Supervisor review the deposit against the department system detail of receipts. recommendation and will implement the recommended corrective action in January '''''''''''' ''''' '''''''''''''' Staffing functions do not provide for proper segregation of duties. Hourly staff should only accept cash receipts. The ''''''''''''''''''''' '''''''''''''''''' should be able to initiate account adjustments and not accept cash receipts. The Office Specialist should approve account adjustments, prepare the deposit and record it in City general ledger system. The ''''' '''''''''''' Manager should review the deposit slip against the department system cash receipt reports and the amounts recorded in the City general ledger system. recommendations and the review by the '''''''''''''''''' '''''''''''''''''''''' will be implemented January Limited staff levels do not allow a complete segregation of duties. ''''''' '''''''''' Department acknowledges that it is accepting additional risk by not implementing all recommendations. '''''''''' ' ''''''''''''''''''' ''''''''''' '''''''''''' The Senior Office Specialist prepares and records the deposit without review. Have the Supervisor review the deposit against the department system detail of receipts. recommendation and will implement the recommended corrective action in January CITY S RESPONSE The City recognizes the importance of segregation of duties to a strong internal control environment. We will be reviewing the current internal control policies to ensure recommended changes have been implemented where possible. Updates to the policies should be complete by April Page 5 of 21
12 OBSERVATION 2 IT SYSTEM USER ACCESS CONFLICTS WERE NOTED City Cash Receipts A number of City departments utilized stand-alone application systems for cash receipting, printing receipts, and cash balancing. Proper segregation of duties for user access in these systems should separate duties involving custody of assets, authorizations surrounding the assets, and record keeping. Improper system access can provide the opportunity for misappropriation. User access to these systems appeared to be assigned by job title rather than by job function (See specific observations in chart below.) For example, cashiers had the ability to edit or void previously recorded payments in the system. AUDITOR S RECOMMENDATION Access to these systems should be reviewed and adjusted according to the job functions performed. Specifically for the areas where deficiencies were noted, we recommend the following: Deposit Group Observation Recommendation Management Response '''''''' '''''''''' The IT System Administrator of the department system occasionally processes payments. The IT Administrator should not accept payments. Should it be operationally necessary due to the limited staff size, the IT Administrator should have another staff initial the payment when it is accepted. recommendation and have implemented the recommended procedure. ''''''''''''''''''''''' '''''''''''''''''''' ''''''''''''' Staff accepting payments also have system permissions allowing changing and canceling of payments in the department system. User permissions allowing the changing and canceling of payments should be removed from staff accepting payments. recommendation. A new system was implemented in 2012 that does not allow staff accepting payments to cancel transactions. ''''''''''''''' ''''''''''''''''''''''' ''''''''''''' The Office Technician receives payments, prepares the deposit and has system administrator privileges in the department system. The Office Technician's system administration user permissions should be removed and permissions relevant to the job performed should be assigned. recommendation; however, due to the inability to increase staffing levels at this facility will not be able to comply. ''''''' '''''''''''' Department acknowledges that it is accepting additional risk due to non-compliance with the recommendation. Page 6 of 21
13 Deposit Group Observation Recommendation Management Response '''''''''''''' '''''''''''''''''''''' ''''''''''''' Staff accepting payments have system permissions allowing changing and canceling of payments in the department system. User permissions allowing the changing and canceling of payments should be removed from staff accepting payments. recommendation. Due to the limited staff levels not allowing proper segregation of duties, we are unable to comply. However beginning in January 2012, a report of payment adjustments and cancellations will be reviewed monthly by the Program Coordinator to increase oversight. '''''''''' ' '''''''''''''''''''' '''''''''''''''''''''''''''' '' '''''''''''' The Sr. Office Specialist prepares the deposit and has permissions allowing changing and canceling of payments in the department system. User permissions allowing the changing and canceling of payments should be removed from staff preparing the deposit. recommendation. Due to the limited staff levels not allowing proper segregation of duties, we are unable to comply. However beginning in January 2012, a report of payment adjustments and cancellations will be reviewed monthly by the ''''''''''' '''''''''''''''''''''''''' Manager to increase oversight. '''''''''' ' ''''''''''''''''''''' '''''''''''''''''''''''' Several users throughout ''''''''''' '''''''' '''''''''''''''''''''' that are not system administrators have the view credit card information user permission in the department system. Remove the "view credit card" user permission from all staff except system administrators. recommendation. Only the System Administrator and the Backup System Administrator will have permissions to view credit cards. '''''''''' '''''''''''''''' ' ''''' Cashiers have the ability to void completed transactions. Require supervisor approval in system in order to void transactions. recommendation; however, the current system in place does not have the capability to prevent line level workers from voiding transactions without supervisor approval. The department is currently researching a system that would better fit their needs. Page 7 of 21
14 Deposit Group Observation Recommendation Management Response '''''''''''''' '''''' '''''''''''''' The ''''''''''''''''''' '''''''''''''''''' accepts payments and has system administrator privileges in the department system. The '''''''''''''''''''' '''''''''''''''''''' system administrator user permissions should be removed and permissions relevant to the job performed should be assigned. recommendation; however, the '''''''''''''''''''' '''''''''''''''''' has job functions that require this level of administrative permission at this facility and we will not be able to comply. ''''''' ''''''''''' Department acknowledges that it is accepting additional risk due to non-compliance with the recommendation. '''''''''''' ''''' '''''''''''''' Staff accepting payments also have system permissions allowing changing and canceling of payments in the department system. User permissions allowing the changing and canceling of payments should be removed from staff accepting payments. recommendation. Due to the limited staff levels not allowing proper segregation of duties, we are unable to comply. However, beginning in January 2012, a report of payment adjustments and cancellations will be reviewed monthly by the '''''''''''''''''''' Supervisor to increase oversight. '''''''''''' '''''' '''''''''''' The Office Specialist prepares the deposit and has permissions allowing changing and canceling of payments in the department system. User permissions allowing the changing and canceling of payments should be removed from staff preparing the deposit. recommendation and will implement the recommended corrective action in January '''''''''' ' '''''''''''''''''''' ''''''''''''' ''''''''''' The Senior Office Specialist prepares the deposit and has system administrator privileges in the department system. The Senior Office Specialist's system administration user permissions should be removed and permissions relevant to the job performed should be assigned. recommendation; however, the Senior Office Specialist has been designated as the backup to the IT Administrator for the Department and we will not be able to comply. '''''''' '''''''''' Department acknowledges that it is accepting additional risk due to non-compliance with the recommendation. Page 8 of 21
15 Deposit Group Observation Recommendation Management Response '''''''''' ' '''''''''''''''''' '''''''''''' '''''''''' The IT System Administrator of the department system occasionally processes payments. The IT System Administrator should not accept payments. Should it be operationally necessary due to the limited staff size, the IT Administrator should have another staff initial the payment when it is accepted. recommendation and will implement the recommended corrective action in January ''''''''''' ' ''''''''''''''''''' ''''''''''' '''''''''''' Staff accepting payments also have system permissions allowing changing and canceling of payments in the department system. User permissions allowing the changing and canceling of payments should be removed from staff accepting payments. recommendation. Due to the limited staff levels not allowing proper segregation of duties, we are unable to comply. However, beginning in January 2012, a report of payment adjustments and cancellations will be reviewed monthly by the Supervisor to increase oversight. ''''''' ''''''''''' Department acknowledges that it is accepting additional risk due to partial noncompliance with the recommendation. CITY S RESPONSE We agree that IT system segregation of user access is important to a strong internal control environment. Finance will develop some additional guidance to provide to all cash receipts areas regarding appropriate segregation of duties by April Page 9 of 21
16 OBSERVATION 3 THE CITY AUDITORIUM DID NOT MAINTAIN A SYSTEM TO TRACK OPEN CONTRACT AMOUNTS The City Auditorium collected a deposit when a contract was signed. Once the event had been held, the remaining amount on the contract was calculated and invoiced in the City s accounting system. We observed that the City Auditorium does not have a system in place to track open contract amounts owed to the City from the time the deposit payment was made until the remaining amount was invoiced. The staff at the Auditorium was extremely limited and tracking these amounts would help ensure all revenue was accounted for, should one of the staff become unavailable. AUDITOR S RECOMMENDATION We recommend utilizing a spreadsheet to track all contract payments from the time the contract is signed until payment in full is received. CITY S RESPONSE recommendation regarding utilizing a spreadsheet to track all contract payments from the time the contract is signed until payment in full is received. This improvement will be implemented January Page 10 of 21
17 OBSERVATION 4 '''''''''''''''''''''' ''''''''''''' INTERNAL CONTROLS OVER CASH RECEIPTS WERE NOT ADEQUATE ''''''''''''''''' ''''''''''' ''''''''''' regular job functions require them to '''''''''' ''''''''''' ''''''''''. We observed that it would be possible for '' '''''''' to remove funds received '''''' '' ''''''''''''''''''' '''''''' ''''''' ''''''''''''' '''''''''''''''''''' '''' ''''''''' '''''''''''''' ''''''''''' '''''' ''''''''''' '''''''' and avoid detection as long as the funds were returned for deposit before ''''''' '''''''''' ''''''''' '''''''' ''''''' ''''''''''''''. We also noticed that it was also possible for the clerk to do this '''''''''''''' ''''''''''''''''' '''''' '''''''''' ''''''''. The clerk would avoid detection as long as the funds were returned and included in the drawer deposit before ''''''' '''''''''' '''''''''. AUDITOR S RECOMMENDATION We recommend that internal controls over cash receipts be strengthened. The '''''''''''''''''' ''''''''''' Operations Supervisor should conduct unannounced random audits of cashier drawers to verify that all funds are being deposited in a timely manner. We also recommend that City IT generate a report of ''''''''''' ''' ''''''''' has accessed on a quarterly or monthly basis for the '''''''''' ''''''''''''''''''' Supervisor to make random selections in order to review. Although this was being done on an annual basis, we feel that increasing the frequency would assist in strengthening controls. CITY S RESPONSE recommendation. The '''''''''' ''''''''''''''''''' Supervisor and/or Senior ''''''''''''''''''' '''''''''' Clerk will begin performing unannounced, random cash drawer and ''''''''' '''''''''''''''''''' audits beginning February The complete auditing process requires a new report to be developed in ''''''' ''''''''' management software which we anticipate being available by the end of January Page 11 of 21
18 OBSERVATION 5 THE '''''''' ''''''''''' DEPARTMENT SYSTEM HAD CONTROL WEAKNESSES We observed some internal control weaknesses in the department system used by the '''''''' ''''''''''. Normally, a ''''''''''''' was generated when payment was taken; however, '''''''''' ''''''''''''''' must be paid for and have a waiting period elapse before the ''''''''''''' was issued. As a result, '''''''''' '''''''''''''''' were processed at a zero fee when they were actually issued. The system did not differentiate between ''''''''''''' types and therefore, allows all '''''''''''''' the opportunity to be issued at a zero fee. We observed that audit trails did not exist in the department system. As there was no record of the date, time and user that changed information, any irregularity would be more difficult to investigate. We also observed that all staff had the ability to change transaction fees or waive late charges that were automatically populated by the system. This removes assurance that correct fees were being collected. AUDITOR S RECOMMENDATION We recommend that the '''''''''''''''' system be enhanced to ensure all fees are recorded at the correct amounts, that fees are only waived when approved, and that transactions activity is logged. Specifically, we recommend the following: Deposit Group Observation Recommendation Management Response '''''''' '''''''''' The department system allows all '''''''''''''' to be issued for a zero fee. Eliminate the option to issue '''''''''''''' without receipt for all transactions except '''''''''''' ''''''''''''''''. Consider generating and reviewing reports of '''''''''''''' issued for zero fees. recommendation. The program changes are in process and should be completed by December ''''''' ''''''''' No audit trails exist in the department system Consider developing a logging process if feasible and retention of logs. Reports should be generated of any receipts deleted by the IT System Administrator. recommendation. The program changes are in process and should be completed by December '''''''' ''''''''' Transaction fees can be changed and late fees can be waived by any staff. Restrict/protect fields to ensure fees are not intentionally or inadvertently changed (except if needed '''''' ''''''''''' ''''''''''''''''). Create report of waived fees for review by '''''''''''''''' '''''''' '''''''''. recommendation. The program changes are in process and should be completed by December CITY S RESPONSE recommendation. The program changes are in process and should be completed by December Page 12 of 21
19 OBSERVATION 6 DEPOSIT SLIPS WERE NOT BEING REVIEWED City Cash Receipts Throughout the course of the audit, it was noted that several deposit groups were not performing reviews of the deposit slips against daily transaction reports and reconciliations. Cash receipts were being verified to the department system, but the deposit slip was not reviewed against the department system. Once the cash receipts were entered in the City s accounting system, they were reconciled to the deposit. As there were no direct interfaces between the department receipting systems and the City s accounting system, the deposit slip should be compared to the receipts recorded in the department system to provide assurance that all receipts are being recorded. AUDITOR S RECOMMENDATION The deposit slip should be reviewed by a staff not preparing the deposit. It should be reviewed against the department system receipt details to verify the deposit is complete and accurately represents what was collected. CITY S RESPONSE Finance agrees with the recommendation and will include this step in our overall cash receipts guidelines to departments by April Page 13 of 21
20 OBSERVATION 7 MAIL WAS NOT OPENED UNDER DUAL CONTROL City Cash Receipts In several deposit groups that received payment by mail, we noted that a single employee was opening the mail. Normally, two staff should be present when mail is opened if there is a chance payments might be received. There is a risk the cash receipts could be misappropriated before they enter the system. We are aware that several deposit locations operate with very limited staff and it was often difficult to have two people present when the mail was opened. In these cases, other controls should be developed and utilized to help mitigate the risk of misappropriation. Other controls to consider are using security cameras or drop boxes at the location. AUDITOR S RECOMMENDATION We recommend mail be opened with two people present. For departments that do not have enough staff to ensure adequate segregation of duties, consider requiring customers to mail payments to City Finance, or asking that payment be made at the City Finance Office. Alternatively, departments could utilize a drop box for payments, which would be emptied and counted by two employees on a scheduled basis. Specifically, we recommend the following: Deposit Group Observation Recommendation Management Response '''''''' '''''''''''''''''''''' Mail is opened by one staff member. Open the mail when two staff members are present. recommendation and will implement the recommended action. Limited staff levels do not allow two staff members to be available to open mail on a daily basis. However, whenever we have at least two people on site, they will open the mail together. ''''''' ''''''''''' Mail is opened by one staff member. Open the mail when two staff members are present. recommendation. Due to limited staffing levels, we are unable to comply with the recommendation. We are exploring alternatives that would address the risk raised by the auditor. Page 14 of 21
21 Deposit Group Observation Recommendation Management Response '''''''''''''''''''' Mail is opened by one staff member. Open the mail when two staff members are present. recommendation and will implement the recommended action. Limited staff levels do not allow two staff members to be available to open mail on a daily basis. However, whenever we have at least two people on site, they will open the mail together. ''''''' '''''''''''' ''''''''''''''''' ' ''''''''''''''' Mail is opened by one staff member. Consider the use of a drop box so that payments can be opened by two staff members. recommendation. As of January 2011, it is '''''''''' policy that two people are present when opening mail. However, we recognize there may be opportunities to improve. Staff has been reminded to open mail with two people present. '''''''''' ' '''''''''''''''''''' '''''''''''''''''''''''''''''' '''''''''' Mail is opened by one staff member. Open the mail when two staff members are present. recommendation. This improvement will be implemented January ''''''''''''' '''''' '''''''''''''' Mail is opened by one staff member. Open the mail when two staff members are present. recommendation. This improvement will be implemented January CITY S RESPONSE Finance agrees with the recommendation. We agree that funds should be received in a manner that prevents theft and misappropriation. We are exploring various options such as a lockbox or centralized processing area that would address the risk identified by the auditors in the most cost effective and efficient manner. Page 15 of 21
22 OBSERVATION 8 '' '''''''''''' ''''''''' ''''''''''''''''''''''' '''''''''''''' OFFICE REFUND CHECKING ACCOUNT WAS MAINTAINED AND RECONCILED BY ONE EMPLOYEE Segregation of duties involves separating certain areas of responsibility and duties in an effort to reduce fraud and unintentional mistakes. Management should establish procedures to separate duties and responsibilities of personnel who handle cash or cash equivalents. These procedures provide an internal check on activities by separating duties involving custody of assets, authorizations surrounding the assets, and record keeping. The ''''''''' '''''''' '''''''''''''''''''' '''''''''''' Office did not make adjustments to customer accounts that result in credits. Instead, these adjustments were handled by using a '''''''''''' Office checking account for refunds. Checking account replenishments were obtained from City Finance by submitting a warrant requisition with a copy of the bank statement and reconciliation. During the course of the audit, we noted that the refund checking account used by the ''''''''''''' Office was being reconciled by the staff member who issued the refund checks. This is a violation of segregation of duties, which presents a risk to the City. AUDITOR S RECOMMENDATION We recommend having another staff member review the activity in the account and perform a monthly reconciliation. CITY S RESPONSE recommendation. We will have the Supervisor review the activity in the account and perform a monthly reconciliation. This improvement will be implemented January Page 16 of 21
23 OBSERVATION 9 CREDIT CARD PROCESSING FEES WERE NOT ADDED TO CUSTOMER BALANCES BUT WERE PAID BY THE CITY Credit cards were accepted for payment in a number of departments and enterprises throughout the City both in person and for on-line transactions. We noted that the transaction fee charged by the card processor was not added to the customer balance, but was absorbed by the City. Transaction fees for 2010 related to credit cards were approximately $200,000. We also observed that approximately $60,000 was incurred in fees related to payments to the City by Colorado Springs Utilities made by credit card. A significant portion of payments to the City from CSU made by credit card were related to engineering and street degradation fees processed through the City s website. While the City has not added the credit card transaction fee to the customer s balance, a different practice was in place at Colorado Springs Utilities, also a City Enterprise. At Colorado Springs Utilities, the third party processor added a fee to every credit card transaction which was paid by the customer at the time of payment. A cost benefit analysis that considered the potential labor savings from using credit cards as compared to the fees incurred by the City had not been performed. We were informed that City Finance was in the process of studying this issue in greater detail and developing recommendations for City departments and enterprises. AUDITOR S RECOMMENDATION We recommend that: City Finance works with each City department to complete a cost benefit analysis related to credit card payment transaction fees. This analysis should include considerations of whether adding a fee would tend to increase the payments by cash or check, and internal labor costs related to processing cash and check payments. Consideration should be given to utilizing a third party vendor to process credit card transactions including the additional fee, as was the procedure in place at Colorado Springs Utilities. For payments made by Colorado Springs Utilities via credit card, the City should consider whether payment could be made in an efficient manner between the two organizations without use of a credit card. The cost of the fee should be compared to any additional staff time required to process intercompany payments. CITY S RESPONSE recommendation. The City would like to have an enterprise-wide solution during Page 17 of 21
24 OBSERVATION 10 AUTOMATED INTERFACES AND ELECTRONIC CASH DRAWERS WERE NOT IN PLACE IN A NUMBER OF LOCATIONS AND COST BENEFIT ANALYSES HAD NOT BEEN PERFORMED During our site visits to various locations accepting payments, we observed that manual cash drawers and receipt books were in use in some smaller locations. A cashiering module was available that is integrated with the City s general ledger package and would eliminate the need for receipt transactions to record activity in the various locations; however, this integrated module was not in place. Additionally, even in departments with separate department systems collecting significant receipts, there were no interfaces between department systems and the City s general ledger. As no interface existed, employees had to create a receipt in the general ledger to record the activity from the department system. This process required additional staff time to create receipts, and if employees did not record an entry to the general ledger timely, a reconciling difference could exist between the general ledger, the cash deposit amount and activity in the subsystem. Although reconciliations and controls were in place, automated interfaces can reduce time spent performing reconciliations and provide more assurance that all receipts are recorded. Technology is now available to allow remote check deposit, which eliminates the need to transport checks to the bank, although the need for a bank deposit would still be necessary if cash (currency) was accepted. We observed that a detailed cost benefit review for this technology had not been conducted. Additionally, a cost benefit analysis that considered the control risk of accepting cash (currency) payments in a decentralized environment had not been performed. AUDITOR S RECOMMENDATION We recommend that opportunities for increasing efficiency and improving the control environment be evaluated as follows: City Finance and IT should work with City departments to evaluate the cost benefit of implementing electronic cash drawer systems or an integrated cashiering module. Evaluate the cost benefit of remote check deposit technology. The City should consider not accepting currency to eliminate the need for a bank deposit and reduce controls risks in locations with limited staff. CITY S RESPONSE recommendation. Finance is currently testing remote deposit to determine the cost effectiveness of this technology. We are discussing a cash drawer system with IT. We expect to have the cash drawer system evaluated by April 2012 with possible implementation by year end Page 18 of 21
25 OBSERVATION 11 PAYMENT ACTIVITY MAY BE MORE DECENTRALIZED THAN NECESSARY There were a total of 60 deposit locations for City departments and enterprises, excluding Colorado Springs Utilities, Memorial Hospital, and the Colorado Springs Airport, that accepted or processed payments in some form from walk-in customers or via mail. In some departments, payment must be accepted at the location as the public uses the facility, (for example, in the case of a pool facility within the Parks and Recreation Department). However, there were also locations accepting payments which have a small volume of receipts, a small staff, and little walk-in traffic. Locations such as the City Auditorium may benefit from such a review. However, the City should consider customer service concerns along with internal control considerations. AUDITOR S RECOMMENDATION To improve segregation of duties, we recommend that the City consider whether payments should be accepted at all current locations. Alternatively, payments could be accepted at a location where duties could be better segregated, such as the City Finance Office. City Finance and City department management should work together to identify opportunities to reduce the number of locations accepting payments. CITY S RESPONSE recommendation. We are currently reviewing all locations that accept cash and evaluating whether it would be more efficient and effective for Finance to accept the cash instead. We expect this review to be completed by April Page 19 of 21
26 OBSERVATION 12 SOME LOCATIONS DID NOT MAKE AND RECORD DEPOSITS ON A CONSISTENT BASIS Several City departments allowed cash receipts to accumulate before the deposit was made and did not record the receipts until the deposit was made. Allowing cash receipts to accumulate at a location increases risk to the City because the receipts could be stolen by outside parties, lost or misappropriated. Revenue should be recorded when received or earned. It is not appropriate to delay recognizing revenue until it is deposited. AUDITOR S RECOMMENDATION We recommend that deposits be made and recorded on a consistent basis to reduce the risk of misappropriation and minimize security risks. Specifically, we recommend the following: Deposit Group Observation Recommendation Management Response ''''''' '''''''''''''''''''''' Deposits are made once a month. Consider increasing the frequency of deposits to once a week by sharing deposit services with the ''''''''''''' '''''' '''''''''''' ''''''''''' ''' ''''''''''''''''' '''' '''''' '''''''''''' '''''''''''''''' recommendation; however, cash flow varies widely throughout the year which inhibits our ability to establish a routine deposit schedule. We will attempt to make deposits at least every two weeks based on need starting in January '''''''' ''''''''' Department acknowledges that it is accepting additional risk by not fully complying with the recommendation. Page 20 of 21
27 Deposit Group Observation Recommendation Management Response '''''''''''' ''''' ''''''''''''' Deposits are being made infrequently. Consider weekly deposits. recommendation; however, due to limited staff and increased workloads we are unable to comply on a consistent basis. '''''''' ''''''''''s Department acknowledges that it is accepting additional risk by not fully complying with the recommendation. CITY S RESPONSE Finance agrees with the recommendation. Our policy is for departments to make deposits as close as possible to the day funds are received. If there are delays, deposits should be stored in a secure location until the deposit can be made. Staffing shortages have prevented this from occurring in some areas. We will reiterate the policy to departments. We believe reducing locations as recommended in Observation 11 will also help achieve this recommendation s goal. Page 21 of 21
28 C ITY C OUNCIL S O FFICE O F T HE C ITY A UDITOR C OLORADO S PRINGS, C OLORADO About our Office The mission of the is to provide City Council with an independent, objective and comprehensive auditing program for operations of the City. Our auditing program includes: Evaluating the adequacy of financial controls, records and operations Evaluating the effectiveness and efficiency of organizational operations Providing Council, management and employees objective analysis, appraisals, and recommendations for improving systems and activities The is responsible for auditing the systems used by the City of Colorado Springs and its enterprises, including Colorado Springs Utilities and Memorial Health System. We perform a variety of audits for these entities, including financial audits, performance audits, contract audits, construction audits, and information system audits. We also perform follow up on a periodic basis to monitor and ensure management actions have been effectively implemented. Authorization and Organizational Placement Our audits are conducted under the authority of Chapter 1, Article 2, Part 7 of the Colorado Springs City Code, and more specifically parts 703, 705 and 706 of the Code. The Office of the City Auditor is structured in a manner to provide organizational independence from the entities it audits. This independence is accomplished by the City Auditor being appointed by and reporting directly to the City Council. Audit Standards The audit was planned in a manner that meets or exceeds the International Standards for the Professional Practice of Internal Auditing, a part of the Professional Practices Framework promulgated by the Institute of Internal Auditors, with the exception of the requirements under standards 1312 and 1321 to obtain an external quality assurance review once every five years. We do not believe this non compliance impacted the quality of our audit. The audit will include interviews with appropriate personnel and such tests of records and other supporting documentation as deemed necessary in the circumstances. We will review the internal control structure and compliance tests. Sufficient competent evidential matter was gathered to support our conclusions. City Hall 107 North Nevada Avenue Suite 200 Mail Code 1542 Colorado Springs CO Tel Fax Reporting Hotline
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