Thursday, March 24, 2016

Urban Economics: What is a CAFR? Application to Internal Control Over Financial Reporting



To Monroe County Taxpayers and School Board:
How the Early Learning Center’s Shortfall Gets ‘Disappeared’

Martha K. Huggins
The $20K-plus ‘shortfall’ at Key West’s Horace O’Bryant School’s Early Learning Center (ELC) may not be much money compared to the millions in Monroe County’s school system budget but it is still taxpayers’ money that could have gone to early childhood education.  The newly discovered missing funds could signal much larger past losses and administrative failures that go way beyond the actions of  the now-terminated ELC manager.  The disappearance of taxpayer money should have been known about and reported in the School District’s 2014-2015 annual audit, but it is impossible to know if this was done since that audit is missing from the school district’s website. 

Key West taxpayers may want to declare their loss of confidence  in Monroe County School District executives, whose initial failure to fully implement US government auditing standards and practices system-wide has gotten the county into a financial conundrum.  To sort out this mess means spending more taxpayer money by hiring a forensic accountant, who undoubtedly will raise questions about higher-ups’ oversight, accountability, and credibility.   
Bottom line:  A government entity like the Monroe County School District is legally bound to transparency and honest reporting in its use of taxpayer monies.  County school executives may not have immediately uncovered or correctly reported the suspicious shortfall in its 2014-2015 year-end financial audit, but I wouldn’t know this because, as of today, I this document is  not available on the school system website.   

‘Disappearing’ a Shortfall

This analysis will use two different terms, not interchangeable with one another.  The ELC  budgetary “shortfall,” discovered in December 2014 by bookkeepers at Horace O’Bryant School, is said have occurred while just one ELC employee collected and recorded parents’fees.  This seems to contain the possible illegality right there by locating it in one part of the system as the act of one person.  Firing the ELC’s Manager then presumably punished the assumed transgression and helped protect taxpayers’ money in the future.  Not so! The ELC shortfall points to much larger problems in the school system’s supervisory oversight. If  Monroe County schools’ 2015 end-of-year audit does not explicitly address this shortfall, then the school system’s Superintendent and Finance Director must be accused of  ‘disappearing’ a dangerous irregularity that could signal more shortfalls in other parts of the system and potentially more cover-ups.

Bottom line:  Officials need not or cannot correct a problem if through poor supervision the problem is not uncovered; and these same officials can be held accountable if they learn of a shortfall and either ignore it or hide such information from the school board and taxpayers by ‘disappearing’ it from their annual audit’s report. 

Losing $20K+ in Taxpayer Monies
In  his very informative “Commentary” for The Blue Paper (11/30/2015), Dr. Larry Murray reported that Horace O’Bryant School’s Early Learning Center [i] ended the first half of the 2014-2015  fiscal year with “$20,036.79  unaccounted for.”  He pointed to ELC Manager Tina Godfrey’s role in the financial loss, arguing that, “It seems to me that the person to talk to is Tina Godfrey.”  It would indeed be very helpful if Ms. Godfrey could enlighten us about which county administrators failed to investigate the shortfall when it was revealed to them.
Certainly, the Monroe County officials who signed off on the school system’s 2014-2015 annual audit—Superintendent of schools Mark Porter and his Executive Director for Finance and Performance Jim Drake—bear considerable responsibility if they allowed the 2015 school system’s financial report to go to the Florida Auditor General, the Monroe County government, Monroe County’s School Board, and  the taxpayers without a specific indication of the occurrences, amounts, and causes of the Early Learning Center’s shortfall. It took almost a year  for this shortfall to become public, and then only because the media blew the whistle.  As of today, six months into the county school district’s 2016 fiscal year,  the 2015 audit is still unavailable to the public on the school system’s website.

Bottom line: Finance staff at Horace O’ Bryant School finally exercised due diligence in December 2014 and January and February 2015 by carrying out a “test” of the  ELC’s established criteria for examining its own ‘internal control’ over financial management and reporting.  It does not look like this can be said for Monroe County higher-ups,.[ii]  But this is getting ahead of the story.

Internal Control over Financial Operations

First of all, put simply, US public corporations and government bodies are required to use and demonstrate their having “internal controls over financial reporting.”  As Florida state’s Auditor General explains, “a deficiency in internal control [over spending and reporting] exists when the design and operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect and correct misstatements on a timely basis.”[iii]  In other words, a reporting entity such as the Monroe County School System must demonstrate that it has mechanisms for detecting, testing, and preventing ‘fraud’ or other ‘losses.’

Let’s see how these stipulations were tested  by financial staff at Horace O’Bryant School and what its  investigation disclosed? In December 2014, an internal memorandum--with no signatories, specific departmental attribution, or intended recipients--stated that “the Principal” (presumably at Horace O’ Bryant School) had just discovered a $20K-plus shortfall in ELC daycare funds.  Great!   That’s how accurate and corrective financial reporting ideally begins.  Then, in January and February 2015, according to the same internal memorandum, “Finance staff”—likely at the Horace O’ Bryant School--further investigated the $20K-plus loss and found two shortcomings in ELC financial operations. Most worrisome is that these shortcomings violate two very basic “Business Management 101” principles that secure money management requires:  “all physical cash transactions have been correctly recorded during a specified period”—this ‘internal control’ mechanism known as “bank reconciliation” was violated by the ELC Manager and those who supervised her and did nothing about making sure that the money collected was accounted for.  The second internal control mechanism, that, no single employee receives fees/payments, records them, and then deposits them at the bank—relating to “segregation of duties,” was partially violated in by the ELC Manager:  her supervisors allowed her to be in control of “taking attendances, collecting fees, and entering both attendance and fees into student records.” Godfrey apparently did this for a relatively long period without being told that this was inappropriate. 

 

Bottom line:   Jim Drake, the Executive Director of Monroe County Schools Finance and Performance Department, is responsible for “supervising and collaborating with subordinate professionals District-wide in the planning, implementation, and evaluation of District and school financial operations and programs.” [iv]   Given his central financial administrative position within the school system’s structure, it is highly probable that Drake knew--and certainly should have known, perhaps as early as December 2014—about the internal memorandum that formally reported irregularities in ELC financial management.  If Drake disregarded the breach of two very basic ‘internal controls’ over financial practices at ELC, then he too must be held  accountable for the ELC loss of taxpayer monies.  And as  Professor Rosemary Nurre teaches her introductory accounting classes at California’s San Mateo Community College, failure of  ‘internal controls’ enhances the probability of  “employee theft, robbery, and unauthorized use [of funds],” [v] a negative outcome for taxpayers that should be the responsibility of Superintendant Mark Porter as well.

 

Internal Control  Over Financial Reporting

Is the ELC financial shortfall wholly absent from the Monroe County school system’s 2014-2015 “Certified Annual Financial Report” (CAFR, 2015)? [vi]  The County Commissioners declared themselves shocked at not being notified by Superintendent Porter about the shortfall so I assume that they have not seen the school district’s CAFR yet.  But is it possible that latest school system end-of-year audit (CAFR) has no notification of the ELC shortfall?  How will Commissioners feel if the shortfall has been ‘finessed’ out of the school system’s 2015 audit, for which they must assume responsibility?  Superintendent Mark Porter and the audit’s likely co-signatory, finance director Jim Drake, could avoid mentioning the district’s missing funds by using the boiler plate language found in all CAFRs:  “management has established a comprehensive internal control framework…designed to protect District assets from loss, theft or misuse….”  This phrasing does not appear to require admitting that the government entity’s  inner controls were found to have been breached.

But there’s an even more serious problem with the Monroe County School’s annual audits: Their financial materials are organized and financial statements assembled and reconciled by, guess who? : The Superintendent’s in-house CPA, Executive Director for Finance and Performance, Jim Drake.  Most U.S. city and state CAFRs explicitly indicate in their Certified Annual Financial Report that it was audited by  a CPA or  accounting firm ‘independent’ of the government entity being examined.  

Bottom Line:  Using an executive officer of Monroe County Schools to audit the organization that employs him, and whose finances he himself supervises, could end in the school system’s sending a compromised report to Florida’s Auditor General.  Jim Drake’s potentially conflicting positions—being finance manager of county school operations and end-of-year auditor of his own performance and fiduciary outcomes--invite malfeasance that could be difficult to track, since Drake himself controls what can be tracked.  And let’s not forget that such a non-segregation of duties is what led in the first place to the long undiscovered shortfall at the Early Learning Center.[vii]  [viii]

 

Recommendation:  Hire An Outside Auditor and Use Her Annually

Taxpayers should energetically support immediately hiring an independent forensic accountant to examine all Monroe County’s school system’s finances for the last five years, comparing them with what officials have reported in their annual CAFRs for the same years.  We should also demand that the Monroe County School System (and each of the County’s other government entities), contract with  an independent auditor to research and prepare the county’s annual CAFR for the school system.  It is bad accounting to let the fox guard the hen house!  Maybe that’s why a whole year after the Horace O’Bryant Principal discovered the ELC’s financial shortfall and initiated an internal examination of the organizational sources of this problem, the public still knows very little about the problem’s paper trail.    
Here’s what I want to know: Was there a disconnect between  the ELC shortfall,  the investigation of this shortfall by Horace O’Bryant “finance staff,” and  the Monroe County School System’s Superintendent and Finance Director being informed of the local “finance staff’s”  findings?   How exactly was the  shortfall ‘finessed’ into the school system’s 2014-2015 CAFR’s by Monroe County’s  School District’s Finance Director?   Did the county’s Finance Director ‘disappear’ the shortfall? 
Clearly, the existence of only one end-of-year CAFR report (2014) on the Finance Director’s website suggests that financial “transparency” is the last thing on his mind.
Bottom line: The ‘buck’ for not earlier launching a full and open examination of the ELC shortfall stops with School Superintendant Mark Porter and his Director for Finance and Performance Jim Drake.  Fellow taxpayers:   this disgraceful matter cannot pass the ‘smell test,’ rendering it very unlikely to pass fiduciary ‘muster’ and honesty.

[ii]     Informal, in-house “Finance staff” memorandum (http://thebluepaper.com//wp-content/uploads/HOBFinanceReport.pdf)

[iii]  “Comprehensive Annual Financial Report Monroe County School District,” Florida, For
      the Fiscal Year Ended June 30, 2014, P. 160-161

[iv]     See job description (http://www.keysschools.com/schoolBoard/agenda_folders/12-13_Agenda_Folders/April%209/Exec%20Dir%20of%20Finance%20and%20Performance%20REVISED%2004092013.pdf

[vi]     See the school district’s 2013-2014 CAFR to get an idea of what one contains (http://www.myflorida.com/audgen/pages/pdf_files/2015-126.pdf)

[vii] According to common practice across the US, a local or state government’s end-of-year finances are audited by an outside CPA or by a CPA accounting firm.  Such auditors are not already employed by the organization they are to audit.  Not so for the Monroe County School system, where the system’s Director of Finance conducts an audit essentially on himself and his organization. 

[viii]  Of course, the Florida State Auditor General (AG) reviews the annual CAFR that is submitted to him by Monroe County Schools, after its financial statements have been assembled and reconciled by the school system’s finance director Jim Drake.  (See AG Report example in 2014 CAFR (Auditor General State of Florida, Independent Auditor’s Report, CAFR 2014, p.  173-179 (Roman vi for link to CAFR report)

 


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