Table of Contents. Planning & Governmental Relations Capacity Enhancement & Concurrency Mitigation Agreements

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1 Table of Contents Planning & Governmental Relations Capacity Enhancement & Concurrency Mitigation Agreements August 28, 2014 Page Number BACKGROUND 2 OBJECTIVE 2 SCOPE AND METHODOLOGY 2 COMMENDATION 3 FINDINGS AND RECOMMENDATIONS 3-6 1

2 BACKGROUND Planning and Governmental Relations (the Department) is responsible for ongoing coordination between local government jurisdictions (12 entities) and developers desiring to build residential communities within the county to ensure sufficient school capacity. Any development project that has an impact on local schools must enter into a Capacity Enhancement (CEA) and/or Concurrency Mitigation (CMA) agreement with the School Board. These agreements may require mitigation and may include prepayment of school impact fees, developer contributions, site development and site acquisition. The Department is responsible for assessing school capacity and student enrollment conditions, calculating mitigation and capital contribution payments and tracking concurrency encumbrances and reservation student capacity of schools for the CEA/CMA s. The Department maintains an Excel spreadsheet-based program, known as CARMA, along with School Capacity and Student Enrollment spreadsheets. These CARMA spreadsheets are used to perform the calculations of mitigation and capital contribution payments. An Access database system, known as the Master Development Inventory, is maintained as an historical record of CEA/CMA information used for tracking purposes. In 2010, the Department was staffed with four Planners. Two positions were eliminated during the economic downturn and reorganization. OBJECTIVE The objectives of this audit were to review the operational processes and procedures associated with Capacity Enhancement and Concurrency Mitigation Agreements for efficiency and effectiveness and to determine compliance with Department Operating Procedures and the Inter-Local Agreement between the School Board and the various local government jurisdictions. SCOPE AND METHODOLOGY Our audit covered transactions and activities for CEA/CMA projects during the July 1, 2012, through June 30, 2014 period. Our audit was conducted in accordance with the International Standards for the Professional Practice of Internal Auditing of the Institute of Internal Auditors and included such procedures as deemed necessary to achieve the objectives. Internal Auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization s operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes. We are required to note any material deficiencies in accordance with Florida Statutes, School Board Policy and sound business practices. We also offer suggestions to improve controls or operational efficiency and effectiveness. 2

3 COMMENDATION During the 2012/2014 period, the Planning and Governmental Relations team administered more than 150 agreements for the District. These agreements have generated prepaid impact fees and mitigation contributions to help fund school construction. This has been accomplished with a very small staff. The district realized approximately $263,040 of General Fund revenue from application fees, and Department records indicate that an estimated $1 million in prepaid school impact fees and over $1 million in mitigation contributions were collected for use in school construction projects over this same period. FINDINGS AND RECOMMENDATIONS CAPACITY ANALYSIS, REVIEW AND MONITORING APPLICATION (CARMA) CONTROLS: Since 2008, the Department has used a custom designed Excel spreadsheet to assess school capacity and student enrollment conditions, calculate mitigation and capital contribution payments and track concurrency encumbrance and reservation capacity for the CEA/CMA s. This spreadsheet is referred to as CARMA. CARMA is linked to an annual Summer Data Supplement worksheet that contains school capacity and student enrollment data. CARMA was developed by the department demographer and the two department planners are the end-users of this application. CARMA is the backbone of the CEA/CMA process and a critical program to the operation of the Department. We noted the following control weaknesses: CARMA s processes and links to supplemental spreadsheets are not documented with narratives or flowcharts describing the steps and linkages of the data. Access to CARMA and the Summer Data Supplemental Workbook is not password protected. We observed an instance where the CARMA password was changed but the change was not documented and communicated to the other users. The Summer Data Supplement and Projection worksheet cells containing School Capacity and Enrollment data that are linked to CARMA are not password protected. Periodic updates to these spreadsheets as a result of information received from the Facilities Department and/or Site Visits to schools are not documented and approved. Although the CARMA application is on the network server, an additional back-up to an external hard drive should be considered to avoid data loss. The student enrollment data and method to arrive at the student generation rates by grade level should be clarified as to which categories of students are included or excluded from CARMA calculations. These rates are default fields for the mitigation calculation in CARMA. A written narrative/flowchart is important to document the roles and responsibilities of the developer and the users of CARMA and how the program works and the data is linked. This documentation is critical should the developer be unavailable for an extended period of time or leave the district. It should describe how the developer controls access to CARMA and its data 3

4 and what procedures and authorizations are needed to make changes to CARMA. It should also address how the integrity of the data is protected and what provisions have been made for data backup and disaster recovery. The department is in the process of transferring the data in the CARMA application from Excel to Access. However, these issues are applicable regardless of the platform used for the program. We recommend that the Department develop and implement controls to address these concerns. DATA ACCURACY: As noted earlier in this report, the Department maintains a substantial amount of data to track school capacity, student enrollment and developer contributions. We noted the following errors in data maintained by the department during our audit: Supplement Data: A comparison of the CARMA Summer Data Supplement spreadsheet to its underlying supporting documents (the State of Florida FISH Level of Service Capacity Report & Pupil Assignment s October Student Enrollment Summary Report) disclosed six variances that were not adequately supported with appropriate documentation. Access Database: Checks payable to the local governments representing prepaid impact fees, capacity reservation fees or mitigation funds were not always recorded in the Project Information table of the Master Development Inventory database. We noted 10 instances where checks totaling more than $1,000,000 were not recorded in the database. We also noted one transposition error and one amended mitigation payment that had not been revised. Spreadsheet for Capital Budget Annually the department provides a report titled CEA Mitigation Payment Status to the Office of Management and Budget (OMB). The 2014 CEA Mitigation Payment Status did not agree with the Master Development Inventory database or the SAP system. We noted a variance of $387,758 when comparing the CEA Mitigation Payment Status report with SAP system postings. The OMB relies on the accuracy of the CEA Mitigation Payment Status report to record expenditures of CEA/CMA funds in the proper project accounts. The data being tracked is dynamic and variances can occur at various points in time, but there still should be agreement between and among these important records and management should have reliable and accurate data for decision making. In addition, one of the department s goals is to create and maintain an annual report of CEA/CMA mitigation dollars received. This goal will be difficult to achieve without accurate records. We recommend that the department continue to evaluate and improve its record keeping methods. 4

5 REVENUE MONITORING: We noted the following posting errors in the SAP system: CEA/CMA application fees totaling $3,300 were posted to the Public Relations funds center (6231) instead of the Planning and Governmental Relations funds center (6234). CEA/CMA application fees totaling $4,600 were posted to funds center ( ) instead of the Planning and Governmental Relations funds center (6234). A mitigation payment totaling $106,525 was posted to Business Area 100 instead of Business Area 390. This entry was corrected after we brought this to the attention of management. Impact Fees totaling $101, were posted to Business Area 390 instead of Business Area 393. This entry was corrected after we brought this to the attention of management. Impact Fees totaling $27, were posted to Business Area 100 instead of Business Area 393. The $600 CMA application fees paid to Orange County for Concurrency agreements are not clearly identifiable when remitted to the District each quarter since the project numbering convention is different. It should also be noted that the Department shares an Administrative Specialist with the Pupil Assignment Department and the two Department Planners do not have log on access to the SAP system. This makes it difficult to verify correct postings in SAP. We recommend that the Department develop and implement a method to check the posting of CEA/CMA revenue that is forwarded to the Finance Department. CEA/CMA PROJECT FOLDER REVIEW: Our review of the 10 CEA/CMA project folders found the following areas that need improvement: Updated and complete CARMA documentation had not been filed for six projects. Official school capacity determination letters were not available for two projects. Official school capacity determination letters were not completed within 15 days for two projects. Explanations for the delays included: complete documentation was not initially submitted; revisions were made to the original applicant information; verification of a property sale caused a change; and, split zoning reviews. While these explanations appear reasonable, adequate documentation to support these explanations was not always available for review. School Development Review Committee (SDRC) documentation was not available for one project and evidence that a subsequent SDRC meeting occurred was not available for another project. Typographical errors regarding project numbers and the number of multi-family units were noted on School Board Agendas and SDRC documentation for two projects. 5

6 We recommend procedures be enhanced to ensure documentation maintained in the project folders is complete and accurate. This could be accomplished by implementing a peer and/or supervisor review of the project folders. DELAYED DEPOSITS TO FINANCE: Mitigation payments totaling more than $51,000 were not forwarded to the Finance Department in a timely manner. We noted delays of almost two weeks for these checks. We were informed that checks are held at times to research what projects to which the revenue should be recorded. Such research should not delay deposit of funds. We recommend that procedures be reviewed and revised where necessary to ensure checks are forwarded promptly to the Finance Department. OPERATING PROCEDURES: The Department adopted and obtained School Board approval of its Operating Procedures in The Operating Procedures were amended with Board approval in 2010 and in Management has acknowledged that the Procedures need to be revised again to reflect current practices. We recommend that Operating Procedures be reviewed and updated as necessary to reflect current processes. INTERLOCAL AGREEMENT COMPLIANCE: Section 6.2 of the Inter-Local Agreement states that by March 1 of each year Mutual Reports will be provided between the District and the local jurisdictions. This has not been occurring. We were informed that the information is not prepared due to time constraints. We recommend that the Planning and Governmental Relations Department and the local government jurisdictions work together to ensure compliance with the Inter-Local Agreement. We wish to thank the staffs of the Planning and Governmental Relations, Budget and Finance Departments for their cooperation and assistance during the audit. Vince Roberts, CIA, Auditor 6

7 AUDIT RESPONSE MATRIX FISCAL PERIOD: DEPARTMENT/SCHOOL: ADMINISTRATOR/PRINCIPAL: DEPARTMENT HEAD/AREA SUPERINTENDENT: Planning, Governmental Relations and Pupil assignment Sandra R. Simpson Scott Howat Exception Noted Management Response Responsible Person Outcome Timeline What is? What should be? What needs to be done? Who needs to do it? When will the action be completed? What is the evidence of completion? CAPACITY ANALYSIS, REVIEW AND MONITORING APPLICATION (CARMA) CONTROLS: CARMA s processes and links to supplemental spreadsheets are not documented with narratives or flowcharts describing the steps and linkages of the data. As CARMA transitions from Excel to Access, the work flow will be included in the process. The work flow will be documented with flow charts and narratives. Senior Administrators completing the transition process It is the goal for the transition to be completed by April of The work flow will document the process with flow charts and narratives. Access to CARMA and the Summer Data Supplemental Workbook is not password protected. A pass word protected system will be updated. Senior Administrator managing CARMA. April of Access denied without pass word. We observed an instance where the CARMA password was changed but the change was not documented and communicated to the other users. Change in the password protocol will be a part of the updated process. Senior Administrator managing CARMA April of Access denied without pass word.

8 The Summer Data Supplement and Projection worksheet cells containing School Capacity and Enrollment data that are linked to CARMA are not password protected. All data within the CARMA system will be password protected. Senior Administrator April of Access denied without pass word. Periodic updates to these spreadsheets as a result of information received from the Facilities Department and/or Site Visits to schools are not documented and approved. The entire CARMA process is being documented by a work flow map including documentation for updates. All regular updates will be done in CARMA annually and documented. If a FISH issue is found it will be researched, documented and updated. Senior Administrator Currently in process. Although the CARMA application is on the network server, an additional back-up to an external hard drive should be considered to avoid data loss. CARMA is currently being backed-up weekly on an external hard drive Senior Administrator Currently in process The student enrollment data and method to arrive at the student generation rates by grade level should be clarified as to which categories of students are included or excluded from CARMA calculations. These rates are default fields for the mitigation calculation in CARMA. For the upcoming impact fee study (January 2015) the calculation for generation rates will be documented and included in the CARMA documentation and the work flow. Senior Administrator January 2015

9 A written narrative/flowchart is important to document the roles and responsibilities of the developer and the users of CARMA and how the program works and the data is linked. This documentation is critical should the developer be unavailable for an extended period of time or leave the district. It should describe how the developer controls access to CARMA and its data and what procedures and authorizations are needed to make changes to CARMA. It should also address how the integrity of the data is protected and what provisions have been made for data backup and disaster recovery. The department is in the process of transferring the data in the CARMA application from Excel to Access. However, these issues are applicable regardless of the platform used for the program. A CARMA workflow document is being captured in a flowchart (including persons responsible for updating the data). Transition to Access will be assisted by an OCPS Business Process Specialist. Additional staff members will be trained and actively involved in updating the data in CARMA. CARMA is currently being backed-up weekly on an external hard drive Senior Administrators April 2015

10 DATA ACCURACY: : Supplement Data: A comparison of the CARMA Summer Data Supplement spreadsheet to its underlying supporting documents (the State of Florida FISH Level of Service Capacity Report & Pupil Assignment s October Student Enrollment Summary Report) disclosed six variances that were not adequately supported with appropriate documentation. Access Database: Checks payable to the local governments representing prepaid impact fees, capacity reservation fees or mitigation funds were not always recorded in the Project Information table of the Master Development Inventory database. We noted 10 instances where checks collectively more than $1,000,000 were not recorded in the database. We also noted one transposition error and one amended mitigation payment that had not been revised. Staff will keep adequate file archives of support data for CARMA any extraneous changes will be documented in the Summer Data Supplement Worksheet. Meetings will be scheduled with local government entities to address the Inter-local agreements including PGR providing a Fee Submission Form to be submitted to OCPS for all impact fees and this form will pair payments with appropriate project. New database and procedures will ensure appropriate documentation of payments. The new work flow plan will document the payment process. Senior Administrators PGR staff During the October 2014 update this will be implemented December 2015

11 Spreadsheet for Capital Budget: Annually the department provides a report titled CEA Mitigation Payment Status to the Office of Management and Budget (OMB). The 2014 CEA Mitigation Payment Status did not agree with the Master Development Inventory database or the SAP system. We noted a variance of $387,758 when comparing the CEA Mitigation Payment Status report with SAP system postings. The OMB relies on the accuracy of the CEA Mitigation Payment Status report to record expenditures of CEA/CMA funds in the proper project accounts. This will be monitored weekly to ensure posting accuracy. Administrative Staff November 2014 The data being tracked is dynamic and variances can occur at various points in time, but there still should be agreement between and among these important records and management should have reliable and accurate data for decision making. In addition, one of the department s goals is to create and maintain an annual report of CEA/CMA

12 mitigation dollars received. This goal will be difficult to achieve without accurate records. REVENUE MONITORING: CEA/CMA application fees totaling $3,300 were posted to the Public Relations funds center (6231) instead of the Planning and Governmental Relations funds center (6234). CEA/CMA application fees totaling $4,600 were posted to funds center ( ) instead of the Planning and Governmental Relations funds center (6234). A mitigation payment totaling $106,525 was posted to Business Area 100 instead of Business Area 390. This entry was corrected after we brought this to the attention of management. Part of the new workflow process will ensure, based on the current memo that accompanies the check to finance, that the payment is posted in the appropriate fund center and business area. Administrator October 2014 Impact Fees totaling $101, were posted to Business Area 390 instead of Business Area 393. This entry was corrected after we brought this to the attention of management.

13 Impact Fees totaling $27, were posted to Business Area 100 instead of Business Area 393. The $600 CMA application fees paid to Orange County for Concurrency agreements are not clearly identifiable when remitted to the District each quarter since the project numbering convention is different. This is going to be addressed by the PGR newly created Fee Submission Form. Director of PGR Coincidental with meeting with local governmental entities It should also be noted that the Department shares an Administrative Specialist with the Pupil Assignment Department and the two Department Planners do not have log on access to the SAP system. This makes it difficult to verify correct postings in SAP. The Administrative Specialist duties include payroll, purchasing and inventory for Planning, Governmental Relations and Pupil Assignment. All other duties are related to PGR. Director of PGR October 2014 CEA/CMA PROJECT FOLDER REVIEW: Updated and complete CARMA documentation had not been filed for six projects. Official school capacity determination letters were not available for two projects. New workflow process will eliminate this situation Senior Administrators October 2014

14 Official school capacity determination letters were not completed within 15 days for two projects. Explanations for the delays included: complete documentation was not initially submitted; revisions were made to the original applicant information; verification of a property sale caused a change; and, split zoning reviews. While these explanations appear reasonable, adequate documentation to support these explanations was not always available for review. School Development Review Committee (SDRC) documentation was not available for one project and evidence that a subsequent SDRC meeting occurred was not available for another project. Only completed applications will be processed The workflow process will ensure that the SDRC documentation is included in the project folder. Senior Administrators Senior Administrators October 2014 October 2014 Typographical errors regarding project numbers and the number of multifamily units were noted on School Board Agendas and SDRC documentation for two projects. Staff will proof for accuracy of data. Additional organization of folders has been implemented. Senior Administrators October 2014

15 We recommend procedures be enhanced to ensure documentation maintained in the project folders is complete and accurate. This could be accomplished by implementing a peer and/or supervisor review of the project folders DELAYED DEPOSITS TO FINANCE: Mitigation payments totaling more than $51,000 were not forwarded to the Finance Department in a timely manner. We noted delays of almost two weeks for these checks. We were informed that checks are held at times to research what projects to which the revenue should be recorded. Such research should not delay deposit of funds. We recommend that procedures be reviewed and revised where necessary to ensure checks are forwarded promptly to the Finance Department. Deposits will be made within 5 business days of receipt of the check. The time is based on the amount of research needed to verify the accuracy of the payment. During the time needed for research, the checks will be stored in a secure location. Administrative Staff October 2014

16 OPERATING PROCEDURES: The Department adopted and obtained School Board approval of its Operating Procedures in The Operating Procedures were amended with Board approval in 2010 and in Management has acknowledged that the Procedures need to be revised again to reflect current practices. PGR has updated procedures and will bring forward any amended operating procedures to the Board. PGR Administrators April 2015 We recommend that Operating Procedures be reviewed and updated as necessary to reflect current processes. INTERLOCAL COMPLIANCE: AGREEMENT Section 6.2 of the Inter- Local Agreement states that by March 1 of each year Mutual Reports will be provided between the District and the local jurisdictions. This has not been occurring. We were informed that the information is not prepared due to time constraints. PGR will send the LOS report and the report annually. Meetings will be scheduled with local government entities to address the Inter-local agreements and ensure deadlines are honored. PGR Administrators April 2015 We recommend that the Planning and

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