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    DIVISIONOF LOCAL GOVERNMENT

    & SCHOOL ACCOUNTABILITY

    O F F I C E O F T H E N E W YO R K ST A T E C O M P T R O L L E R

    Report of ExaminationPeriod Covered:

    July 1, 2007 January 6, 2009

    2009M-154

    Schenectady

    City School District

    Internal Controls OverSelected Financial Activities

    Thomas P. DiNapoli

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    11DIVISIONOF LOCAL GOVERNMENTAND SCHOOLACCOUNTABILITY

    Page

    AUTHORITY LETTER 2

    EXECUTIVE SUMMARY 3

    INTRODUCTION 5

    Background 5

    Objective 5Scope and Methodology 5

    Comments of District Officials and Corrective Action 6

    PAYROLL DISBURSEMENTS 7

    Payroll Processing 7

    Payroll Certification 10

    Recommendations 11

    CLAIMS AUDIT 12 Recommendation 13

    INTERNAL AUDITOR 14

    Recommendation 14

    INFORMATION TECHNOLOGY 15

    Recommendation 16

    APPENDIX A Response From District Officials 17

    APPENDIX B OSC Comments on the Districts Response 22

    APPENDIX C Audit Methodology and Standards 25

    APPENDIX D How to Obtain Additional Copies of the Report 27

    APPENDIX E Local Regional Office Listing 28

    Table of Contents

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    33DIVISIONOF LOCAL GOVERNMENTAND SCHOOLACCOUNTABILITY

    Office of the State ComptrollerState of New York

    EXECUTIVE SUMMARY

    The Schenectady City School District (District) is governed by the Board of Education (Board) which

    comprises seven elected members. The Board is responsible for the general management and control

    of the Districts financial and educational affairs. The Superintendent of Schools (Superintendent) is

    the chief executive officer of the District and is responsible, along with other administrative staff, for

    the day-to-day management of the District under the direction of the Board.

    There are 15 elementary schools, an early childhood education center, three middle schools, one highschool, a career center, and an adult education center in operation within the District, with approximately

    10,400 students and 1,700 employees. The Districts operating expenditures for the 2007-08 fiscal year

    were $139.3 million, which were funded primarily with State and Federal aid, and real property taxes.

    Scope and Objective

    The objective of our audit was to examine the Districts internal controls over selected financial

    activities for the period July 1, 2007 to January 6, 2009. Our audit addressed the following related

    questions:

    Have District officials established adequate internal controls over payroll disbursements and

    are those controls operating effectively to safeguard District assets?

    Have District officials established appropriate internal controls over the claims audit process

    and are those controls operating effectively to safeguard District assets?

    Have District officials appropriately established the internal audit function?

    Have District officials appropriately designed the controls over the Districts information

    technology (IT) system to protect District assets?

    Audit Results

    The Board and District administrators need to improve their oversight of District operations. As a

    result of poor oversight, we found weaknesses in controls over the Districts payroll disbursements,

    claims audit process, internal audit function, and information technology system.

    The former Head Utility Worker received over $50,000 in overtime compensation for duties attributable

    to facilities management and energy management during the 2007-08fiscal year. However, his approved

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    4 OFFICEOFTHE NEW YORK STATE COMPTROLLER4

    time sheets did not clearly state the overtime hours that were allocated to each responsibility, and

    the District did not have additional supporting documentation detailing the duties that he performed

    during these hours. Although the employees supervisor approved the time sheets, he could not verify

    the specified hours claimed were actually worked. Approval of overtime payments without supporting

    documentation or supervisory knowledge of hours worked could result in employees receiving

    compensation they may not be entitled to.

    Because District officials do not provide sufficient supervisory review of payroll transactions, employees

    made clerical errors when calculating 12 of the payroll payments in our sample, which resulted in

    incorrect payments totaling $2,373. We also found weaknesses in the Districts internal controls over

    separation payments, resulting in questionable payments to employees totaling $26,026. In addition,

    the Assistant Superintendent for Business did not certify 11 of the 14 final payroll reports that we

    reviewed. These weaknesses can, and did, result in incorrect payments being made to employees.

    We also found weaknesses in the Districts claims audit process. Our review of 50 claims, totaling

    $1,082,675, disclosed that 26 of the claims tested, totaling $293,921, had one or more deficiencies. The

    claims auditor approved these claims for payment, although the claims did not comply with District

    purchasing procedures. As a result, the Board has limited assurance that the claims audit process isworking as intended and that all paid claims were proper and necessary District expenditures.

    Education Law requires that each district has an internal auditor who will undertake annual risk

    assessments of district operations. The Board appointed a certified public accounting firm to serve

    as the Districts internal auditor on December 5, 2007, almost a year after the requirement went into

    effect. The District received the internal auditors final risk assessment statements for the year ended

    June 30, 2007 on February 11, 2009. While the internal auditor should have provided the District with

    a risk assessment for the year ended June 30, 2008 by December 31, 2008, the internal auditor had not

    yet started it at the end of our fieldwork in May 2009. The internal auditors failure to perform a timely

    annual risk assessment leaves the Board with limited assurance that potential risks at the District are

    identified and that appropriate internal controls are in place to address those risks.

    District officials have not established formal policies or procedures to limit users access within the

    financial software system. District officials do not sufficiently use audit logs or change reports to monitor

    the system for inappropriate access or unauthorized changes to the financial software. In addition, we

    found that employees had access rights to the financial software that were not required to perform their

    job duties. These weaknesses increase the risk that inappropriate payments or unauthorized changes to

    data could occur and not be detected in a timely manner.

    Comments of District Officials

    The results of our audit and recommendations have been discussed with District officials and their

    comments, which appear in Appendix A, have been considered in preparing this report. District

    officials generally disagreed with our findings and recommendations. Our comments concerning the

    District officials response can be found in Appendix B.

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    55DIVISIONOF LOCAL GOVERNMENTAND SCHOOLACCOUNTABILITY

    Background

    Introduction

    Objective

    The Schenectady City School District (District) is located in the City

    of Schenectady, Schenectady County. The District is governed by the

    Board of Education (Board) which comprises seven elected members.

    The Board is responsible for the general management and control ofthe Districts financial and educational affairs. The Superintendent of

    Schools (Superintendent) is the chief executive officer of the District

    and is responsible, along with other administrative staff, for the day-

    to-day management of the District under the direction of the Board.

    There are 15 elementary schools, an early childhood education center,

    three middle schools, one high school, a career center, and an adult

    education center in operation within the District, with approximately

    10,400 students and 1,700 employees. The Districts operating

    expenditures for the 2007-08 fiscal year were $139.3 million, which

    were funded primarily with State and Federal aid, and real property

    taxes.

    The objective of our audit was to examine the Districts internal

    controls over selected financial activities. Our audit addressed the

    following related questions:

    Have District officials established adequate internal controls

    over payroll disbursements and are those controls operating

    effectively to safeguard District assets?

    Have District officials established appropriate internalcontrols over the claims audit process and are those controls

    operating effectively to safeguard District assets?

    Have District officials appropriately established the internal

    audit function?

    Have District officials appropriately designed the controls

    over the Districts information technology (IT) system to

    protect District assets?

    We examined the Districts internal controls over payrolldisbursements, claims auditing, the internal audit function and

    information technology for the period July 1, 2007 to January 6, 2009.

    We conducted our audit in accordance with generally accepted

    government auditing standards (GAGAS). More information on

    such standards and the methodology used in performing this audit is

    included in Appendix C of this report.

    Scope andMethodology

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    Comments of District

    Officials and Corrective

    Action

    The results of our audit and recommendations have been discussed

    with District officials and their comments, which appear in Appendix

    A, have been considered in preparing this report. District officials

    generally disagreed with our findings and recommendations. Our

    comments concerning the District officials response can be found in

    Appendix B.

    The Board has the responsibility to initiate corrective action. Pursuant

    to Section 35 of the General Municipal Law, Section 2116-a (3)(c)

    of the Education Law, and Section 170.12 of the Regulations of the

    Commissioner of Education, a written corrective action plan (CAP)

    that addresses the findings and recommendations in this report

    must be prepared and provided to our office within 90 days, with

    a copy forwarded to the Commissioner of Education. To the extent

    practicable, implementation of the CAP must begin by the end of

    the next fiscal year. For more information on preparing and filing

    your CAP, please refer to our brochure,Responding to an OSC Audit

    Report, which you received with the draft audit report. The Boardshould make the CAP available for public review in the District

    Clerks office.

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    77DIVISIONOF LOCAL GOVERNMENTAND SCHOOLACCOUNTABILITY

    Payroll Disbursements

    School districts establish the pay and benefits for professional

    employees and support staff in the written employment contracts

    and agreements they negotiate with employee bargaining units or

    individual employees. Employment contracts, agreements, andpolicies should contain clear language to allow proper interpretation of

    their terms and conditions. In addition, controls such as a supervisory

    review of payroll transactions help to ensure that compensation is

    paid in accordance with employment contracts and District policies.

    District officials and administrators must ensure that appropriate

    controls are established to prevent and detect errors or irregularities

    in the Districts payroll and personnel procedures and practices.

    Education Law requires the District to certify all payrolls to ensure

    that all payments are proper and necessary.

    The former Head Utility Worker received over $50,000 in overtime

    compensation for duties attributable to facilities management and

    energy management during the 2007-08 fiscal year. Although his

    supervisor approved the overtime, he could not verify the specified

    hours claimed were actually worked, and the District did not have

    additional supporting documentation detailing the work performed.

    Therefore, the District could not be assured that the overtime the

    employee claimed was accurate and necessary. In addition, District

    officials do not sufficiently review payroll transactions initiated by

    the Human Resources Department or processed by the payroll clerks.

    We found clerical errors in the calculation of 12 of the payments inour test sample, which resulted in incorrect payments totaling $2,373.

    We also found weaknesses in the Districts internal controls over

    separation payments, resulting in questionable payments to employees

    totaling $26,026. Furthermore, the Assistant Superintendent for

    Business (ASB) did not certify 11 of the 14 final payroll reports that

    we examined. As a result of these weaknesses, the District cannot

    be assured that all payroll disbursements were proper and necessary

    District expenditures.

    The primary objective for internal controls over payroll processing

    is to ensure that employees are paid wages and salaries and providedbenefits to which they are entitled. Controls, such as supervisory

    review of payroll transactions and certification of payrolls, help to

    ensure that compensation is made in accordance with Board action,

    employment contracts, and District policies. Employment contracts

    and policies generally address matters such as hours to be worked,

    rates of compensation, amount and type of leave time to be granted,

    eligibility for health insurance and other fringe benefits, and post

    employment benefits to be granted.

    Payroll Processing

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    Overtime While overtime pay can be an expected cost of doing

    business for a school district, it is a cost that must be carefully

    controlled. A critical control over payroll and overtime expenditures

    is verification of overtime worked and subsequent approval of the

    employees time sheet for payment. This helps ensure that the District

    incurs only necessary overtime costs. Properly detailed logs of work

    performed can further provide control of overtime costs and allow for

    analysis of additional staffing needs or revision of work priorities and

    scheduling.

    The District paid the former Head Utility Worker $50,836 in overtime

    during the 2007-08 fiscal year. This individuals time sheets indicated

    that the overtime coverage was for overtime split between his duties

    attributable to facilities management and energy management. Each

    duty performed had separate and distinct responsibilities.

    We reviewed the 26 time sheets that the former Head Utility Worker

    submitted for the 2007-08 fiscal year and found that he recorded that

    he worked at least 36 hours of overtime each two-week pay period.

    The former Head Utility Workers supervisor, the ASB, initialed his

    approval for all of the overtime hours documented on the time sheets.

    However, the Head Utility Workers approved time sheets were the

    only supporting documentation for the overtime that he claimed

    to have worked, and did not adequately document the reasons for

    overtime coverage. In fact, of the 26 time sheets reviewed, two did

    not document the reason for overtime coverage at all, and 19 included

    overtime hours worked that were consolidated into one number, but

    were attributable to both duties. Therefore, District officials did not

    have sufficient documentation of the overtime hours attributable toeach duty. The District did not have documentation to describe in

    detail the work that he actually performed during these hours, such as

    a detailed log of completed tasks or progress that was made on tasks

    that were not yet completed. The ASB indicated that the former Head

    Utility Worker was required to enter District buildings when District

    officials were not present (e.g., nights, weekends); thus, the ASB was

    unable to verify the specified hours claimed were actually worked.

    Approval of overtime payments without supporting documentation

    or supervisory knowledge of hours worked could result in employees

    receiving compensation that they may not be entitled to.

    Payroll Calculation Errors It is important that District officials

    review payroll transactions to ensure that they are correct and

    necessary District expenditures. District officials did not sufficiently

    review payroll transactions that were initiated by the Human

    Resources Department or processed by the payroll clerks to ensure

    that all payments were correct and made in accordance with District

    policies and employment contracts.

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    99DIVISIONOF LOCAL GOVERNMENTAND SCHOOLACCOUNTABILITY

    We tested 54 payroll payments totaling $69,984 that the District

    made to 25 employees that included overtime payments to eligible

    employees to verify that they were accurate and properly approved.

    We found 12 calculation errors in payroll and overtime payments

    totaling $2,373. Errors in payroll and overtime payment calculations

    occurred because employees used incorrect pay rates when calculating

    these payments, and did not accurately calculate the number of hours

    worked. For example, the District incorrectly paid a maintenance

    employee his 2006-07 hourly overtime rate of pay for overtime

    that he completed in the 2007-08 fiscal year, which resulted in an

    underpayment of $328.

    Absent an adequate review and approval of payrolls, calculation

    errors were made and not detected or corrected. Therefore, employees

    received incorrect compensation for services rendered.

    Separation Payments A total of 58 employees received retirement

    and/or separation payments during our audit period, totalingapproximately $1.4 million. We tested seven separation payments

    for retiring employees, totaling $329,566, to determine if the

    payments were properly supported, calculated, and authorized. Due

    to complicated contract language and District officials failure to

    sufficiently review the separation payment calculations prepared

    by the Human Resources Administrator, we questioned payout

    calculations for five of the seven payments, amounting to $23,408. In

    addition, as part of our payroll disbursements testing, we questioned

    $2,618 in separation payments made to another individual. Examples

    of the problematic payments are below:

    The District paid two administrators a total of $139,728 in

    retirement benefits that consisted of a retirement incentive

    and sick leave payments. Both administrators elected to defer

    their retirement dates until the year following their first year

    of eligibility. Their employment agreements stated that the

    retirement incentive was a percentage of the employees base

    salary payable in the first year of eligibility. However, District

    officials incorrectly calculated the retirement incentive

    payments based on total salary during the year of retirement

    deferral, which included base salary, tax sheltered annuitycontributions, and credit hour stipends. Consequently, the

    administrators were potentially overpaid a total of $10,605 in

    retirement incentives.

    The District paid an Assistant Superintendent a total of

    $109,031 in retirement benefits that consisted of a retirement

    incentive, vacation leave, and sick leave payments. Her

    employment agreement stated that her retirement incentive

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    would be a percentage of her base salary and that her vacation

    and sick leave payments would be calculated using her

    salary day rate. However, in addition to her base salary, her

    employment agreement provided benefits including expense

    reimbursement and tax sheltered annuity contributions.

    Because of complicated contract language concerning how to

    determine this individuals salary day rate and base salary for

    retirement purposes, District officials may have incorrectly

    calculated all of her retirement benefits using her base salary

    plus the additional benefits, which resulted in a potential

    overpayment totaling $7,697.

    The absence of clear contract language regarding the determination

    of an employees separation payments raises questions about the

    legitimacy of the amount that the District paid to its employees.

    Employment contracts, agreements, or policies containing provisions

    that are not clearly articulated or that do not address all pertinent

    aspects of employment can lead to uncertainty about the rights, duties,and responsibilities of all parties involved. Furthermore, the lack of a

    process in place for reviewing separation payment calculations can,

    and did, result in incorrect payments being made.

    Education Law requires the District to certify all payrolls. A

    certified payroll is one that has been examined and approved by

    an administrator who determines that the persons included in the

    payroll reports have performed their duties in accordance with the

    terms of their employment. The administrator who certifies payroll

    must be independent of the human resources and payroll processes. A

    properly certified payroll helps to ensure that payments are accurateand justified.

    The ASB certifies the payrolls; however, there is no District policy

    or Board resolution designating him to do so. Furthermore, the ASB

    is not independent of the payroll process because he has full access

    rights to the financial management software system that is used

    for payroll processing. The Districts payroll certification process

    includes printing two payroll reports: a preliminary report prior to

    printing the payroll checks and a final report containing a certification

    page after the payroll checks are printed.

    We examined 14 final payroll reports during our audit period to

    determine whether the ASB had properly certified them. Although

    the ASB initialed 13 of the 14 preliminary reports, he did not certify

    11 of the 14 final payroll reports. For example, although a final

    report was printed with a certification page for the pay period ending

    November 21, 2008, totaling $3,562,967, the ASB did not certify the

    payroll. In other instances, final reports were not even printed for the

    Payroll Certification

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    1111DIVISIONOF LOCAL GOVERNMENTAND SCHOOLACCOUNTABILITY

    ASBs secondary review and proper certification. Failure to review

    payroll reports prior to payroll checks being processed allows for

    changes to be made that may not be detected or corrected. Without an

    independent review and properly performed certification of payroll,

    District officials cannot ensure that payroll payments are accurate and

    justified.

    1. The Board should investigate the discrepancies noted in this report

    to determine whether the payments were appropriate, and recoup

    any inappropriate amounts.

    2. The District should require that employees properly document

    overtime hours worked. Such documentation should include

    detailed logs of the work performed during overtime hours.

    3. District officials should provide adequate supervision to ensure

    that payroll is processed accurately and that employees are paid

    the wages and salaries which they are entitled to, as approved bythe Board.

    4. The Board should ensure that collective bargaining agreements

    and employment contracts that include provisions for separation

    payouts are clearly written. District officials should make only

    those payments that are authorized by such agreements.

    5. District officials should ensure that separation payments are

    calculated as intended by the District in compliance with collective

    bargaining agreements and employment contracts. To help assure

    this compliance, someone independent of the process shouldreview separation payment calculations prepared by the Human

    Resources Administrator.

    6. The Board should formally designate an administrator independent

    of the payroll process to certify the payroll. The administrator or

    his/her designee should certify each payroll by attesting that the

    persons included in the payroll have regularly performed their

    duties in accordance with the terms of their employment.

    Recommendations

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    Claims Audit

    Education Law requires that each claim against the District be

    audited prior to payment to ensure that all payments are proper and

    legal. The Board is responsible for auditing the Districts claims or,

    alternatively, may appoint a claims auditor to assume the Boardspowers and duties of auditing and approving or denying all claims for

    payment. A proper claims audit is intended to ensure that each charge

    is properly authorized, accurately calculated, adequately supported,

    in conformance with District policy, and a valid District expense.

    Employees must attach supporting documentation to each claim that

    includes evidence that the District received the goods or services and

    that employees followed District policy when procuring the goods or

    services. The claims auditor is responsible for certifying a list of all

    approved claims (warrant) and for communicating the claims audit

    results to the Board.

    The Board appointed a claims auditor to assume its claims auditing

    duties. We examined 50 claims that the District paid during the audit

    period, totaling $1,082,675, to determine whether they were properly

    authorized, made in accordance with District policy, adequately

    supported, and showed evidence of receipt of goods and services.

    Twenty-six of the 50 claims, totaling $293,921, had one or more

    deficiencies. Nineteen of these claims totaling $272,175 did not have

    verbal or written quotes attached1 and therefore did not comply with

    the Districts purchasing procedures. The claims auditor approved

    these claims for payment, although the claims did not contain evidence

    that employees had obtained the quotes in accordance with District

    purchasing procedures. The remaining seven claims totaling $21,746

    lacked supporting documentation. They either did not have purchase

    receipts attached, did not contain sufficient itemization such as lists

    of attendees who received District-paid meals and refreshments, and/

    or did not have prior approvals attached, such as a District-issued

    purchase order or authorization to attend a conference.

    When District officials and employees do not adhere to the Districts

    purchasing procedures and purchase goods and services without

    the benefi

    t of obtaining quotes, they cannot be sure that they haveacquired goods and services in the most economical manner and in

    the best interest of District taxpayers. Failure of the claims auditor to

    perform a proper audit could result in the inappropriate payment of

    claims.

    ____________________1 The Districts Purchasing Procedures require a written request for quotation

    from at least three vendors for purchases between $5,000 and $10,000 and a verbal

    quotation from at least three vendors for purchases between $2,500 and $5,000.

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    7. The Board should ensure that the claims auditor conducts a

    proper audit of claims in accordance with District policies and

    procedures. The claims audit should include verification that

    District personnel complied with the Districts purchasing policy

    and procedures.

    Recommendation

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    Internal Auditor

    By law, school districts must have had an internal audit function

    in operation no later than December 31, 2006. The internal audit

    function must include, at a minimum, the development of a risk

    assessment of district operations. The risk assessment should includea review offinancial policies, procedures and practices; an annual

    review and update of such risk assessment; and annual testing and

    evaluation of one or more areas of the districts internal controls. The

    internal auditor is also required to prepare reports (at least annually

    or more frequently as the Board may direct) that analyze significant

    risk assessment findings, recommend changes for strengthening

    controls and reducing identified risks, and specify timeframes for

    implementation of such recommendations.

    The Board appointed a certifi

    ed public accountingfi

    rm to serve as theDistricts internal auditor on December 5, 2007, almost a year after the

    requirement went into effect. Due to claimed scheduling conflicts, the

    internal auditor did not present the draft risk assessment to the audit

    committee until the Fall of 2008. Furthermore, the District received

    the final risk assessment report for the year ended June 30, 2007 on

    February 11, 2009. While the internal auditor should have provided

    the District with a risk assessment for the year ended June 30, 2008

    by December 31, 2008, the internal auditor had not yet started it at

    the end of our fieldwork in May 2009.

    The internal auditors failure to perform a timely annual riskassessment leaves the Board with limited assurance that potential

    risks are identified and that appropriate internal controls are in place

    to address those risks.

    8. The Board should ensure that the internal auditor performs risk

    assessments in a timely manner and on an annual basis as required

    by the law.

    Recommendation

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    Information Technology

    The use of information technology affects the fundamental manner

    in which the District processes, records, and reports financial

    transactions. The Districts widespread use of information

    technology presents a number of internal control risks that mustbe addressed, such as misuse or loss of data from unauthorized

    access. District policies and procedures that limit user access to only

    authorized persons protect the data from intentional or unintentional

    manipulation. Furthermore, software access controls must restrict

    user access to only those functions needed by staff to perform their

    job duties and to prevent these users from being involved in multiple

    aspects offinancial transactions. In this way, software access controls

    help to preserve proper segregation of duties. District officials can

    implement compensating controls, such as reviewing edit/change

    reports (audit logs), to help offset control weaknesses resulting fromthe failure to properly restrict user access.

    The District uses a financial accounting software package (financial

    software) to process and maintain financial transactions. The financial

    software can be programmed to restrict users access to transactions

    within the scope of their responsibilities. District officials have not

    established formal policies or procedures to limit users access within

    the financial software system. Although the Assistant Superintendent

    for Business (ASB) uses audit logs to monitor productivity, he

    stated that he does not use audit logs or change reports to monitor

    for inappropriate access or unauthorized changes to the financialsoftware.

    In addition, we found that the ASB and the Deputy Treasurer have full

    access rights to the financial software, including full administrative

    rights to modify user access. We also found that a payroll clerk

    has access rights to add, update, and delete journal entries, process

    payroll, and also print, void, and re-issue computer checks. With

    these capabilities, these individuals have the opportunity to initiate

    and conceal inappropriate financial transactions without detection.

    Due to these control weaknesses, we generated and reviewed eight

    audit logs for cash disbursements to determine if employees with

    incompatible duties inappropriately used their access rights to make

    changes to these modules. Although we found no instances of misuse,

    the failure to establish and monitor policies and procedures relating

    to financial data user access, restrict user access to the financial

    software, and review corresponding audit logs increases the risk that

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    inappropriate payments or unauthorized changes to data could occur

    and not be detected in a timely manner.

    9. District officials should adopt and monitor comprehensive policies

    and procedures that address user access rights to the financial

    software system. The Board should designate a responsible person

    to carry out these policies and procedures, and restrict user access

    based on users job duties. If this is not feasible, District officials

    should implement compensating controls, such as reviewing audit

    logs.

    Recommendation

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    APPENDIX A

    RESPONSE FROM DISTRICT OFFICIALS

    The District officials response to this audit can be found on the following pages.

    The page numbers included in the response letter refer to the "draft" audit report distributed earlier

    to District officials. The final audit report has been reformatted. Therefore, the page references in the

    response letter are no longer accurate.

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    SeeNote 1Page 22

    SeeNote 2Page 2

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    SeeNoPag

    SeeNotPag

    SeeNoPag

    SeeNoPag

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    SeeNote 7Page 23

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    APPENDIX B

    OSC COMMENTS ON THE DISTRICTS RESPONSE

    Note 1

    During our review of payroll processing, District staff and officials provided no information indicating

    that payroll transactions were reviewed by Business Office supervisory staff. Our review of District

    payroll transactions also did not provide any evidence that the transactions were reviewed. In addition,

    during our exit conference District officials did not provide any evidence that supervisory level staff

    in the Business Office reviewed the payroll documentation prepared by the Human Resources Office

    prior to payroll clerical staff processing the information.

    Note 2

    It is important that District officials review payroll transactions to ensure that they are correct and

    necessary District expenditures. Our report does not conclude that District officials should personallyreview each of the thousands of payroll checks issued each biweekly pay period. Rather, in light of

    the payroll processing deficiencies cited in this report (e.g., calculation errors, questionable separation

    payments), we recommend that District officials provide adequate supervision to ensure that payrolls

    are processed accurately and that employees are paid the wages and salaries to which they are entitled,

    as approved by the Board. Because District officials did not perform an adequate review and approval of

    payrolls, calculation errors were made and not detected or corrected, resulting in employees receiving

    incorrect compensation for services rendered.

    Note 3

    The District has no assurance that the employee did perform duties for which overtime payments weremade. The only indication that the employee performed overtime duties was the number of overtime

    hours he recorded on his time sheets, initialed by the Assistant Superintendent for Business (ASB).

    Further, the ASB indicated that the employee was required to enter District buildings when District

    officials were not present (e.g., nights, weekends); thus, the ASB was unable to verify the specified hours

    claimed were actually worked. Approval of overtime payments without supporting documentation or

    supervisory knowledge of hours worked could result in employees receiving compensation that they

    may not be entitled to.

    Note 4

    This statement is incorrect. We tested 54 payroll payments totaling $69,984 that the District made to 25

    employees that included overtime payments to eligible employees to verify that they were accurate and

    properly approved. We found 12 calculation errors in payroll and overtime payments. The District paid

    the former Head Utility Worker $50,836 in overtime during the 2007-08 fiscal year. Due to calculation

    errors found during our initial payroll testing, coupled with the significant amount of overtime paid to

    this one employee, we performed further review.

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    Note 5

    Audit staff held discussions with numerous District officials and staff, including the Human Resources

    Administrator, ASB, Deputy Treasurer, Senior Payroll Audit Clerk and Payroll Clerk regarding the

    Districts payroll process, supporting documentation and payroll payments made. Audit staff also had

    discussions with these individuals to gain an understanding of the Districts collective bargaining

    agreements, memorandums of agreement, and employment contracts, when warranted.

    Our findings were based on a sample of transactions, not the entire population. Given the significant

    error rate that we found, the actual level of inaccurate payments in the Districts payroll will be much

    higher than $2,373. The fact that we found so many errors in the payments that we tested indicates an

    internal control weakness that should be addressed by District officials.

    Note 6

    Except where contract language explicitly stated that the retirement incentive was a percentage of

    the employees base salary payable in the first year of eligibility, and the District instead calculated

    the retirement incentive payment based on total salary during the year of retirement deferral, ourreport did not conclude that the District incorrectly calculated separation payments that resulted in

    overpayments, since the contracts are unclear and complicated. Rather, our report questioned payments

    that were made and recommended that District officials ensure that separation payments are calculated

    as intended by the District in compliance with collective bargaining agreements and employment

    contracts. To help ensure this compliance, the School Attorney, in conjunction with the ASB, should

    review separation payment calculations prepared by the Human Resources Administrator.

    Note 7

    Nowhere in this report do we counsel the District to renege on contracts, violate collective bargaining

    agreements, or abridge the Taylor Law. Our report simply points out that contract language is unclearand complicated regarding separation payments, which raises questions as to the legitimacy of

    separation payments.

    Note 8

    Effective internal controls provide for a payroll certification control by requiring a periodic sign-off

    by a management level employee independent of the payroll operation. This procedure should ensure

    that all payments are made to bona fide employees and reflect the proper pay rate. Minimally, the

    administrator who certifies the payroll should sign-off on the final bi-weekly payroll and employ a

    sampling process for a more in-depth review. This control is essential, particularly in light of thepayroll processing deficiencies cited in this report resulting from an insufficient review of payroll

    transactions. Our report states that the ASB did not certify 11 of the 14 final payroll reports.

    Note 9

    During the audit, audit staff made specific requests to District officials for additional documentation

    when items were not attached to a claim. At the exit discussion, District officials did not request this

    information. We will provide this information to District officials under separate letter.

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    Note 10

    The Senior Payroll Audit Clerk is the official Civil Service title for the payroll clerk. However, the

    Senior Payroll Audit Clerk has access rights to add, update, and delete journal entries, process payroll,

    and also print, void, and re-issue computer checks, thereby resulting in an inadequate separation of

    duties. Further, the Senior Payroll Audit Clerks access is not restricted to only those functions needed

    by her to perform her job duties. Absent restricted user access, employees have the opportunity to

    initiate and conceal inappropriate financial transactions without detection. Software access controls

    must restrict user access to only those functions needed by staff to perform their job duties and to

    prevent these users from being involved in multiple aspects offinancial transactions. In this way,

    software access controls help to preserve proper segregation of duties.

    District officials can implement compensating controls, such as reviewing change reports/audit logs,

    to help offset control weaknesses resulting from the failure to properly restrict user access. Although

    the ASB uses audit logs to monitor productivity, the ASB stated that he does not use audit logs or

    change reports to monitor for inappropriate access or unauthorized changes to the financial software.

    There is an audit trail recorded within the Districts financial software application that captures who

    is entering transactions with a date and time stamp. It provides details on the point of entry (e.g.,workstation identification). Reports can be generated from this audit trail. The ASB does not generate

    exception and change reports and stated that these reports would be too cumbersome to generate due

    to the system not being fast enough.

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    APPENDIX C

    AUDIT METHODOLOGY AND STANDARDS

    Our overall goal was to assess the adequacy of the internal controls put in place by officials to safeguard

    District assets. To accomplish this, we performed an initial assessment of the internal controls so

    that we could design our audit to focus on those areas most at risk. Our initial assessment includedevaluations of the following areas: financial oversight, cash receipts and disbursements, purchasing,

    payroll and personal services, and information technology.

    During the initial assessment, we interviewed appropriate District officials, performed limited tests

    of transactions, and reviewed pertinent documents, such as District policies and procedures manuals,

    Board minutes, and financial records and reports. In addition, we obtained information directly from

    the computerized financial databases and then analyzed it electronically using computer-assisted

    techniques. This approach provided us with additional information about the Districts financial

    transactions as recorded in its databases. Further, we reviewed the Districts internal controls and

    procedures over the computerized financial databases to help ensure that the information produced by

    such systems was reliable.

    After reviewing the information gathered during our initial assessment, we determined where

    weaknesses existed, and evaluated those weaknesses for the risk of potential fraud, theft and/

    or professional misconduct. We then decided on the reported objective and scope by selecting for

    audit those areas most at risk. We selected payroll disbursements, claims audit process, internal audit

    function, and information technology for further audit testing.

    To determine if the Board and District officials had properly designed and implemented internal

    controls over the selected audit areas, we inquired and observed District staff and examined the

    following records and reports for the period July 1, 2007 through January 6, 2009:

    We reviewed minutes from the proceedings of Board and Audit Committee meetings and

    selected supporting documentation.

    We reviewed pertinent District policies and procedures.

    We reviewed employee personnel files, collective bargaining agreements, and individual

    employment contracts.

    We reviewed supporting documentation for payroll payments including payroll journals and

    reports, time sheets, payroll payment requests, canceled payroll checks, and separation paymentcalculations.

    We reviewed selected claims packets, corresponding warrants, and canceled accounts payable

    checks.

    We reviewed documents pertaining to the internal auditor including the completed risk

    assessment, a risk assessment process document prepared by the CPA firm, and Board

    resolutions.

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    We reviewed user-access permission rights reports and audit logs generated from the financial

    accounting software package.

    We conducted our performance audit in accordance with generally accepted government auditing

    standards (GAGAS). Those standards require that we plan and perform the audit to obtain sufficient,

    appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit

    objective. We believe that the evidence obtained provides a reasonable basis for our findings and

    conclusions based on our audit objective.

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    APPENDIX D

    HOW TO OBTAIN ADDITIONAL COPIES OF THE REPORT

    To obtain copies of this report, write or visit our web page:

    Office of the State Comptroller

    Public Information Office

    110 State Street, 15th Floor

    Albany, New York 12236

    (518) 474-4015

    http://www.osc.state.ny.us/localgov/

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    BUFFALO REGIONAL OFFICE

    Robert Meller, Chief Examiner

    Office of the State Comptroller

    295 Main Street, Suite 1032

    Buffalo, New York 14203-2510

    (716) 847-3647 Fax (716) 847-3643

    Email: [email protected]

    Serving: Allegany, Cattaraugus, Chautauqua, Erie,

    Genesee, Niagara, Orleans, Wyoming counties

    ROCHESTER REGIONAL OFFICE

    Edward V. Grant, Jr., Chief Examiner

    Office of the State Comptroller

    The Powers Building

    16 West Main Street Suite 522

    Rochester, New York 14614-1608

    (585) 454-2460 Fax (585) 454-3545

    Email: [email protected]

    Serving: Cayuga, Chemung, Livingston, Monroe,

    Ontario, Schuyler, Seneca, Steuben, Wayne, Yates

    counties

    SYRACUSE REGIONAL OFFICE

    Eugene A. Camp, Chief Examiner

    Office of the State Comptroller

    State Office Building, Room 409

    333 E. Washington Street

    Syracuse, New York 13202-1428

    (315) 428-4192 Fax (315) 426-2119

    Email: [email protected]

    Serving: Herkimer, Jefferson, Lewis, Madison,

    Oneida, Onondaga, Oswego, St. Lawrence counties

    BINGHAMTON REGIONAL OFFICE

    Patrick Carbone, Chief Examiner

    Office of the State ComptrollerState Office Building, Room 1702

    44 Hawley Street

    Binghamton, New York 13901-4417

    (607) 721-8306 Fax (607) 721-8313

    Email: [email protected]

    Serving: Broome, Chenango, Cortland, Delaware,

    Otsego, Schoharie, Sullivan, Tioga, Tompkins

    counties

    GLENS FALLS REGIONAL OFFICE

    Karl Smoczynski, Chief Examiner

    Office of the State Comptroller

    One Broad Street Plaza

    Glens Falls, New York 12801-4396

    (518) 793-0057 Fax (518) 793-5797

    Email: [email protected]

    Serving: Clinton, Essex, Franklin, Fulton, Hamilton,

    Montgomery, Rensselaer, Saratoga, Warren, Washington

    counties

    ALBANY REGIONAL OFFICE

    Kenneth Madej, Chief Examiner

    Office of the State Comptroller

    22 Computer Drive West

    Albany, New York 12205-1695

    (518) 438-0093 Fax (518) 438-0367

    Email: [email protected]

    Serving: Albany, Columbia, Dutchess, Greene,

    Schenectady, Ulster counties

    HAUPPAUGE REGIONAL OFFICE

    Jeffrey P. Leonard, Chief Examiner

    Office of the State Comptroller

    NYS Office Building, Room 3A10

    Veterans Memorial Highway

    Hauppauge, New York 11788-5533

    (631) 952-6534 Fax (631) 952-6530

    Email: [email protected]

    Serving: Nassau, Suffolk counties

    NEWBURGH REGIONAL OFFICE

    Christopher Ellis, Chief Examiner

    Office of the State Comptroller33 Airport Center Drive, Suite 103

    New Windsor, New York 12553-4725

    (845) 567-0858 Fax (845) 567-0080

    Email: [email protected]

    Serving: Orange, Putnam, Rockland, Westchester

    counties

    APPENDIX E

    OFFICE OF THE STATE COMPTROLLER

    DIVISION OF LOCAL GOVERNMENT

    AND SCHOOL ACCOUNTABILITY

    Steven J. Hancox, Deputy Comptroller

    John C. Traylor, Assistant Comptroller

    LOCAL REGIONAL OFFICE LISTING