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Monitors representing H-GAC visited Houston Works for the FY12 financial compliance review. There are findings in multiple areas, including accounting policies and procedures. Some of these findings remain the same as those from the prior two years' reviews.
Monitors representing H-GAC visited Houston Works for the FY12 financial compliance review. There are findings in multiple areas, including accounting policies and procedures. Some of these findings remain the same as those from the prior two years' reviews.
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Monitors representing H-GAC visited Houston Works for the FY12 financial compliance review. There are findings in multiple areas, including accounting policies and procedures. Some of these findings remain the same as those from the prior two years' reviews.
Copyright:
Attribution Non-Commercial (BY-NC)
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Russell Tomlin Interim Chief Executive Officer Houston Works, USA P_O.Box 667128 Houston, TX 77266-7128 Dear Mr. Tomlin: On June 11-22, 20 i 2, monitors representing H-GAC visited Houston Works for the FY12 financial compliance review for H-GAC's workforce system contract with Houston Works for the period of October 1, 2011 through May 31 , 2012. We would like to thank you and Houston Works staff members who assisted the monitors in their review. A copy of the report is attached to this letter. There are findings in multiple areas, including accounting policies and procedures, accounting information system, procurement, accounts payable, cash management, property management and inventory, cost allocation and budget, financial reporting, subcontracts, and insurance. Some of these findings remain the same as those from the prior two years' reviews, indicating Houston Works did not take action to correct these problems as it stated it would. Please provide H-GAC a written response to the report's findings and recommendations as soon as possible. After we receive your response, we will make a determination about further action steps related to the repeat finding in this report. If you have any questions about the monitors' report, please call Sharron Powell at 713.993 .2445. Sincerely, ~ ~ l--.. , Mike Temple D Manager, Workforce Attachment cc: Rodney Bradshaw MiUie Foster Lucretia Hammond Michael McLauchlan Mailing Address PO Box 22777 Physical Address 3555 Timmons Lane. Suite 120 Houston. Texas 77227- 2777 Houston. Texas 77027-6466 Phone 713-627 -3200 Recvcled Phone 713-627-3200 HOUSTON-GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT OF HOUSTONWORKS, U.S.A. JULY 13, 2012 TABLE OF CONTENTS Page FINANCIAL MONITORING REPORT .. .... ...... ........ ...... ..... ...... ... ..... ... ....... .... ......... .......... .... ........ ............ ..... 1 SUMMARY OF FINANCIAL MONITORING PROCESS .. .. ... ... .. .. ............ .. ............. .. .... .. .. .. ... .. ........ .. .. ......... 2 SCOPE AND OBJECTIVES .. .. .. .... .... ... .. ..... .. ... .. .. .... .. ... .... ... .. ...................... ....... ... .. ... ... .... ...... ...... ...... ... ... ... 2 PROCEDURES PERFORMED, OBSERVATIONS AND FINDINGS ........ ... ... ...... .. ......... .. ... .. ... ....... .. ... ...... 3 CONCLUSION .. .... ...... ... .. ... ... .. .. ... ... .. .. ..... ..... .. .... .. .... ..... ... .. ..... ..... .. ........ ...... .... ... ..... ..... ... ..... ... ... .. ... ... .. .... 23 CLOSING ... .... ......... .... .. ...... ..... ... ....... ....... ...... ....... .......... ....... ....... ... ...... ..... .... .. ..... .... ..... ...... ..... .. ...... ..... ... 23 weaver, To: Houston Galveston Area Council 3555 Timmons, Suite 120 Houston, Texas 77027 This report presents the results of the financial monitoring procedures performed for the Houston Galveston Area Council (H-GAC) - Contractor, HoustonWorks, U.S.A. (HoustonWorks) from June 11, 2012 through July 13, 2012 relating to financial monitoring procedures over contractor funding for Contract Number 103-12 for the period October 1, 2011 through May 31, 2012 within the contract spending period October 1,2011 through September 30,2012. Procedures were performed at the HoustonWorks administrative offices at 2118 Smith Street in Houston, Texas. The objectives of the financial monitoring procedures are as follows: A. To ensure that written policies and procedures address the fundamental requirements of the H-GAC financial guidelines, and applicable state and federal guidance. B. To verify that HoustonWorks has adequate internal controls within the financial and accounting processes are designed to ensure compliance with the guidance identified in the policies and procedures. C. To verify that the financial controls are operating as designed and transactions are processed and reported accurately. To accomplish these objectives, we conducted interviews with selected HoustonWorks employees. We also reviewed documentation and performed specific testing procedures. The procedures were performed based on general guidelines provided by H-GAC . We were not engaged to, and did not perform an audit, in which the objective would be the expression of an opinion. Accordingly, we do not express such an opinion. This report is intended solely for the use of H-GAC and should not be used by those who have not agreed to the procedures and taken responsibility for the sufficiency of the procedures for their purposes. The following report summarizes the procedures performed, observations and findings. Weaver and Tidwell, L.L.P. Houston, Texas July 17, 2012 AN INDEPENDENT WEAVER AND TIDWEllllP HOUSTON MEMBER OF BAKER TILLY CERTIFIED PUBLIC ACCOUNTANTS AND CONSULTANTS 24 GREENWAY PLAZA, SUITE 1800, HOUSTON, TX 77046 INTERNATIONAL WWWWEAVERllP.COM P: (713) 850 8787 F: (713) 850 1673 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 SUMMARY OF THE FINANCIAL MONITORING PROCESS The Houston Galveston Area Council (H-GAC) is the region-wide voluntary association of local governments in the 13-county area of southeast Texas. Its service area is 12,500 square miles and contains more than 5.7 million people. H-GAC's mission is to serve as the instrument of local government cooperation, promoting the region's orderly development and the safety and welfare of its citizens. The Gulf Coast workforce system is made up of the Gulf Coast Workforce Board and its operating affiliate, Workforce Solutions. The Board sets the agenda for the region's workforce policy and determines the strategic direction and operational guidelines for its operating affiliate. H-GAC houses the Board's staff and serves as the home office for the affiliate contractors, providing fiscal and management services. During the last year, Workforce Solutions provided employment services to 405,639 individuals and 43,298 area employees with over $200 million in resources through its Employer Service Division and 25 local career offices. Houston Works, U.S.A. (Houston Works) provides a variety of workforce services to the general public through the Workforce Solutions career offices. H-GAC establishes franchise requirements governing how Houston Works operates and delivers services under the Workforce Solutions name. Under the Workforce Solutions name, Houston Works uses grants provided by the state and federal government. The funding streams integrated into the Workforce Solutions career offices include state and federal funds available through the U.S. Department of Labor, U.S. Department of Health and Human Services, U.S. Department of Agriculture funding streams including Workforce Investment Act, Temporary Assistance for Needy Families, Employment Services, Supplemental Nutrition Assistance Program (SNAP), Employment Services authorized by the Wagner-Peyser Act, Child Care and Development Fund, Jobs for Veterans Act of 2002, and Trade Act of 1974, as amended. HoustonWorks offers these services at the following offices: Astrodome, East End, Hobby, Northline, Northeast, Northshore, Pasadena, and Southwest. The purpose of this financial monitoring process is to report on contractor compliance related to contract number 103-12 requirements and related reimbursements for expenses incurred. SCOPE AND OBJECTIVES The scope of our procedures to perform financial monitoring included the review of policy and procedures, conducting interviews, tests of transactions, and internal controls against documented policies for the period of October 1, 2011 to May 31, 2012 to validate performance of the following identified areas: 1. Accounting Policies and Procedures 2. Accounting Information System 3. Procurement 4. Accounts Payable 5. Personnel (Human Resources and Payroll) 6. Cash Management 7. Property Management and Inventory 8. Cost Allocation and Budget 9. Financial Reporting 10. Customer Complaints 11. Subcontracts 12. Insurance weaver RISK ADVISORY SERVICES Page 2 of23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 The objectives of our procedures are as follows: A. To ensure that written policies and procedures address the fundamental requirements of the H GAC financial guidelines, and applicable state and federal guidance. B. To verify that HoustonWorks has adequate internal controls within the financial and accounting processes are designed and operating to ensure compliance with the guidance identified in the policies and procedures. C. To verify that the financial controls are operating as designed and transactions are processed and reported accurately. PROCEDURES PERFORMED, OBSERVATIONS AND FINDINGS We conducted an entrance conference identifying participants, purpose, scope, and timing of the financial monitoring procedures. The opening meeting was conducted on Thursday, June 7, 2012 at the office of HoustonWorks located at 2118 Smith Street, Houston, Texas at 10:00 am. Attendees included the following : Russell Tomlin HoustonWorks Executive Director Terry Hudson Consultant Rudy Martinez Director of Finance Monica Williams Senior Director of Administration Georgetta Mitchell Customer Service Supervisor Sharron Powell HGAC Representative Alyssa Martin Weaver and Tidwell, LLP Tamara Shepherd Weaver and Tidwell, LLP To complete these objectives we performed a variety of procedures such as conducting interviews with key individuals, inspecting written policies and procedures and validating them against the financial guidance provided by H-GAC, the Texas Workforce Commission and federal regulations. Furthermore, we performed specific detail testing based on the criteria identified in the formal policies and procedures as well as the financial guidance provided by H-GAC , the Texas Workforce Commission and the federal regulations. The following information is presented for each area: Financial Monitoring Objective Procedures or Tests Performed Observations Findings (if applicable) Recommendations (if findings are applicable) weaver RISK ADVISORY SERVICES Page 3 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 The issues identified in our procedures will be classified as Observations or Findings which are defined as follows : Observation: The financial areas identified are not considered to be non-compliance issues with federal and state rules and regulations or contract requirements. The intent for the recommendation of the observations is to strengthen the subcontractor's current processes and controls. Finding: The financial areas identified are considered to be non-compliance issues with federal and state rules and regulations or contract requirements. The subcontractor must implement a corrective action plan immediately to address these findings. The issues identified in our procedures have also been risk rated based on criticality to Houston Works according to the below risk definitions: High - The issue(s) noted are likely to have a significant financial, compliance or operational consequence to the organization. Medium - The issue(s) noted, though may not have a significant financial, compliance or operational consequence, exposes the organization to increased risk. Low - The issue(s) noted are considered insignificant individually as it relates to potential for negative financial, compliance or operational consequence to the organization. 1. Accounting Policies and Procedures A. Procedure: We obtained the Accounting Policies and Procedures over Purchasing, Accounts Payable, Cash Disbursements, Fixed Assets, Payroll , and Financial Close and Reporting and reviewed for the following to determine if policies and procedures address H-GAC financial guidance in the following areas: i. Accrual basis of accounting ii . Detailed records that support receipts and expenditures iii . Timely reporting of financial activity iv. A complete and well documented audit trail for all financial transactions v. Budgeting and expenditure tracking vi. Salary limitation vii. Program income viii. Travel allowability, request and approval, classification and reimbursement ix. Cost allocation x. Cash balance reconciliation Finding: 1. Medium - (FIN AP-1) The Payroll policies and procedures do not address review and approval of employee payroll to ensure that all salaries and merit bonus' remain below the maximums identified by the H-GAC contract. 2. High - (F IN-AP-3) The HoustonWorks Payroll poliCies and Cash Disbursement policies do not adequately address the requirements of H-GAC or the Texas Workforce Commission with regards to the review and approval of payroll to ensure no employee's salary breaches the salary cap and the procedures to be taken in the event of a duplicate payment. RISK ADVISORY SERVICES Page 4 of 23 weaver HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 Recom mendation: 1. We recommend HoustonWorks update policies and procedures to clearly state the payroll review and approval process that would ensure the H-GAC and Texas Workforce Commission salary cap requirements are met. In addition, the policies and procedures should indicate how payments are to be tracked in order to avoid duplicate payments. 2. We recommend HoustonWorks design, implement, and document standard procedures for the review and approval of all salaries and merit bonuses to be conducted annually that would ensure maximum salary and bonus amounts do not exceed H-GAC contract requirements. B. Procedure: We completed a Risk Control Matrix for the Purchasing, Accounts Payable, Cash Disbursements, Fixed Assets, Payroll, and Financial Close and Reporting processes to identify inherent risks not addressed by internal controls. Findings: High - (FIN RCM-1) For the areas of Purchasing, Accounts Payable, Cash Disbursements, and Fixed Assets, we identified risks that are not addressed by the internal controls to ensure the critical activities are covered: 1. Purchasing and Accounts Payable: a. Fictitious vendors are not setup. b. Only expenditures that have available budget are approved. 2. Cash Disbursements: a. Cash disbursements are recorded in the proper period. 3. Inventory/Fixed Assets: a. Recorded assets have future benefits. b. Access to the inventory tracking system is restricted. Recommendations: We recommend that HoustonWorks design, implement, and document standard procedures that would ensure the following: 1. Purchasing and Accounts Payable - all vendors have been verified to be legitimate prior to being added to the vendor list. Additionally, prior to approving purchase orders in MIP, availability of budgeted funds has been verified. 2. Cash Disbursements - All cash disbursement transactions are recorded in the proper period. 3. Inventory/Fixed Assets - All recorded assets are assessed to have future benefits to the Workforce Solutions program. Additionally, access to the inventory (fixed asset) tracking sheet should be restricted to those employees who are responsible for the accuracy of the data. The access level should be based on the job responsibilities of each employee. C. Procedure: We reviewed policies and procedures for cash disbursement, cash receivable, fixed assets, payroll, financial closing and financial reporting to determine if they address adequate internal controls that would ensure appropriate segregation of duties, access controls, and accurate classification of costs. Finding: Medium - (FIN RCM-2) Based on gaps identified in internal control coverage, adequate controls to ensure appropriate segregation of duties and access controls are not in place. weaver RISK ADVISORY SERVICES Page 5 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 Recommendation: We recommend that HoustonWorks review its job description documentation for employees and ensure that the assigned duties are aligned with job titles and descriptions. Additionally, based on this review, access to MIP, Microix and the assets tracking spreadsheet should be revised to ensure appropriate access rights . Accounting Policies and Procedures Results Summary: HoustonWorks policies and procedures are adequately documented. However, they do not address areas of risk that would ensure appropriate salary amounts are paid to meet H-GAC and Texas Workforce Commission salary cap requirements. Further, they do not address areas of risk that funds would be obligated without available budget amounts. 2. Accounting Information System A. Procedure: We performed a system walkthrough and interviewed appropriate staff to gain an understanding of the accounting system utilized by the organization. We verified that internal controls exist over the accounting system to provide reasonable assurance over the following: i. That the accounting system is used to capture all program transactions. ii. Access to data is restricted to appropriate personnel and access rights are established. iii. A back-up process exists to ensure that complete and accurate information is available for financial reporting . iv. Posted data cannot be altered after posting. Observation: (OB AIS-5) After invoices have been received, the Contracts and Billing Assistant will obtain receipt documentation, such as the packing slip on an email documenting the amount and quantity received. This documentation should be signed and forwarded by the receiver when received . Findings: 1. High - (FIN AIS-1) The Director of Finance handles all requests to create MIP accounts for new users, prepares the workflow assignments, and assigns access rights based on his personal judgment and expectation of job duties which is a segregation of duties issue. If the employee changes roles or leaves Houston Works at any time, the Director of Finance will alter his MIP profile or remove them from the system. 2. High - (FIN AIS-2) We identified that while there are systematic controls available to ensure that the accounting system is used to capture all program transactions, has an appropriate back-up system, and the access rights and access to data is appropriately restricted. We identified multiple segregation of duties issues with the assigned rights and profiles as identified below: There were four users with access to MIP that are not listed in the employee directory. The Executive Administrative Assistant can add/edit invoices, enter cash receipts, enter cash disbursements, add/edit payroll, and perform General Ledger transactions. The Contract and Billing Assistants can enter Accounts Payable Credits, select Accounts Payable invoices to pay, prepare the Check Register, and process manual checks. The Director of Finance is responsible for assigning access, can edit his own access rights, and has the ability to alter posted data. weaver RISK ADVISORY SERVICES Page 6 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 Recommendations: 1. We recommend the Director of Finance either has administrative rights to MIP or processing access only, but not both. He may have the ability to approve requests for new users, as well as prepare workflows assignments; however, the administrative ability to implement changes should be assigned to another management level employee so as to maintain appropriate segregation of duties. 2. We recommend HoustonWorks review job responsibilities and access level as follows: Implement procedures to review the user access list and ensure that all employees that appear on the list are current and have appropriate access levels. Additionally, a procedure to immediately terminate access when an employee is no longer employed should be implemented as part of the exit process. Assign appropriate access levels to employees based on their job description and responsibilities. Reassigns the responsibilities of the Contract and Billing Assistant and ensure there is no conflict in duties performed where the recording of accounts payable and processing of checks are being performed by the same individual. Director of Finance duties should be updated to where he would not have the responsibility of preparing, approving and editing MIP profiles while at the same time having processing rights. B. Procedure: We interviewed key staff to understand if key accounting, procurement, accounts payable, payroll, coding classification, cost allocation policies are understood and followed. Observation: (OB AIS-6) The payroll allocation is based on Time Study reports that are performed monthly and are used to allocate shared costs to different funding streams. However, the Time Study reports are performed after the fact as the previous months' report is what is used to perform the allocation of payroll hours to contract funding streams. Finding: High - (FIN AIS-3) There are no formal processes in place for the late payment of selected invoices due to shortage of cash flow that comply with H-GAC policies and procedures. However, there appears to be appropriate understanding of key accounting, procurement, accounts payable, payroll, coding classification and cost allocation among accounting staff. Recommendation: We recommend HoustonWorks follow documented processes and pay all invoices timely when they are due. Any informal procedures performed that circumvent documented policies and allow for late invoice payments should be eliminated. C. Procedure: We documented the management information system used to record all program transactions, who the users are and access levels. Findings: High - (FIN AIS-2) We identified that while there are systematic controls available to ensure that the accounting system is used to capture all program transactions, has an appropriate back-up system, and the access rights and access to data is appropriately restricted . We identified multiple segregation of duties issues with the assigned rights and profiles as identified below: There were four users with access to MIP that are not listed in the employee directory. The Executive Administrative Assistant can add/edit invoices, enter cash receipts, enter cash disbursements, add/edit payroll, and perform General Ledger transactions. RISK ADVISORY SERVICES Page 7 of 23 weaver HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 The Contract and Billing Assistants can enter Accounts Payable Credits, select Accounts Payable invoices to pay, prepare the Check Register, and process manual checks. The Director of Finance is responsible for assigning access, can edit his own access rights , and has the ability to alter posted data. Recommendations: We recommend HoustonWorks review job responsibilities and access level as follows : We recommend HoustonWorks implement procedures to review the user access list and ensure that all employees that appear on the list are current and have appropriate access levels. Additionally, a procedure to immediately terminate access when an employee is no longer employed should be implemented as part of the exit process. We recommend HoustonWorks assign appropriate access levels to employees based on their job description and responsibilities. We recommend HoustonWorks reassigns the responsibilities of the Contract and Billing Assistant and ensure there is no conflict in duties performed where the recording of accounts payable and processing of checks are being performed by the same individual. We recommend that the Director of Finance duties should be updated to where he would not have the responsibility of preparing, approving and editing MIP profiles while at the same time having processing rights. D. Procedure: We obtained the chart of accounts utilized by the organization and determined if contract funding can be monitored and tracked sufficiently, transactions can be recorded in sufficient detail to permit proper classification, all budget line items are included and can be identified, and sources can be adequately identified for each fund application . Observations: 1. (08 AIS-1) The budgeting and tracking module in MIP is available but not in use because of improper implementation . 2. (08 AIS-7) Purchasing transactions are entered through a purchase order process. This process also includes the submission and approval of employee reimbursements. 3. (08 AIS-6) The payroll allocation is based on Time Study reports that are performed monthly and are used to allocate shared costs to different funding streams. However, the Time Study reports are performed after the fact as the previous months' report is used to perform the allocation of payroll hours to contract funding streams. 4. (08 AIS-8) Coding is currently structured to apply costs to "cost pools" rather than directly to a specific fund . Accounting Information System Results Summary: HoustonWorks does not have procedures in place that ensure all transactions are adequately identified and recorded. The inappropriate access levels that are assigned to staff raises the risk of transactions being altered or deleted. 3. Procurement A. Procedure: We obtained and reviewed the HoustonWorks Procurement Policies and Procedures to determine if policies and procedures address the following procurement guidelines: i. Purchasing methods, including bidding ii . Request For Proposal solicitation, submission and Evaluation iii . Vendor selection iv. Purchase Requests Processing v. Conflict of interest vi . Standards of conduct weaver RISK ADVISORY SERVICE S Page 8 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 vii. Historically Underutilized Businesses (HUB) viii. Vendor list ix. Procurement records x. Small purchase methods for goods with an aggregate cost of $100,000 or less xi. WIA Adult and Dislocated Worker Training Providers List xii. Suspension and Debarment xiii. Cost Analysis Finding: No issues noted. B. Procedure: We reviewed Procurement policies and procedures to determine if they adequately address internal controls that would ensure appropriate review and approval of purchase requests and Purchase orders, use of approved vendors only, appropriate and accurate receipt of goods. Findings: 1. High - (FIN PP-1) The Procurement Policies and Procedures do not fully address the use of the Request for Purchase Review form to obtain prior approval from H-GAC for inventory purchases over $5,000. 2. Medium - (FIN PP-2) The Procurement Policies and Procedures do not address maintenance of the vendor list, as recommended by the Texas Workforce Commission's Federal Guidelines for Contract Management to ensure that vendors selected are from qualified sources. Recommendations: 1. We recommend HoustonWorks update the Procurement Policies and Procedures to indicate when it is required to utilize a Request for Purchase Review form to get prior approval from H-GAC for any purchases greater than $5,000. 2. We recommend that HoustonWorks update the Procurement Policies and Procedures to address the method in which the vendor list will be maintained including how vendors will be added and deleted as well as the employees who will be responsible for that function . Procurement Results Summary: HoustonWorks policies and procedures are adequately documented. However, formal procedures are not being adhered to ensure that H-GAC related purchases are allowable and valid. Additionally, procurement related responsibilities are informally distributed which allows for inappropriate segregation of duties. This raises the risk of fake vendors being added to the list and items being procured and received without verification. 4. Accounts Payable A. Procedure: We obtained and reviewed the Accounts Payable Policies and Procedures to determine if accounts payable policies address fund obligations and commitments, obligations and encumbrances, cost coding and classification, and duplicate payments Finding: Low - (FIN AP-2) The Cash Disbursement Policies and Procedures do not address the actions to prevent, or to be taken in the event of a duplicate payment. Recommendation: We recommend that HoustonWorks document standard procedures that clearly state appropriate action to be taken which would prevent duplicate payments. RISK ADVISORY SERVICES Page 9 of 23 weaver HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 B. Procedure: We reviewed Accounts Payable policies and procedures in place to determine if they addressed adequate internal controls that would ensure the following: i. Invoice review and approval ii. Appropriate segregation of duties iii. Check signing authority iv. Payments are tracked to ensure that they are not duplicated v. Payment obligations are appropriately identified and processed. Observations: 1. (OB AIS-1) The budgeting and tracking module is available but not in use because of improper implementation. 2. (OB AIS-2) The submission and approval of employee reimbursements is handled through a purchase order process where employees are entered into the accounting system as vendors, rather than through payroll. 3. (OB AIS-3) Coding is currently structured to apply costs to "cost pools" rather than directly to a specific grant, making it difficult to track expenditures according to funding stream. 4. (OB AIS-4) After invoices have been received, the Contracts and Billing Assistant often obtains receipt documentation, such as a packing slip on an email documenting the amount and quantity received, rather than receiving a signed copy from the person receiving the inventory. Findings: 1. High - (FIN AIS-1) The Director of Finance handles all requests to create MIP accounts for new users, prepares the workflow assignments, and assigns access rights based on his personal judgment and expectation of job duties which is a segregation of duties issue. If the employee changes roles or leaves HoustonWorks at any time, the Director of Finance will alter his MIP profile or remove them from the system. 2. High - (FIN SOD-1) We identified two instances of inappropriate segregation of duties 1) were the IT Manager is responsible for the purchase and record IT assets and 2) were the Director of Finance prepares and approves employee MIP profiles. 3. High - (FIN-AIS-4) The Accounts Payable Aging Report shows $497,340.09 in outstanding payables for the review period ending May 31, 2012 of which $410,930.77 is attributable to the H-GAC contract expenditures. Only $39,397.35 is current and the remaining amount, or 81.9%, is past due as presented in the table below. We also noted that is a total of $51,462 .00 which is attributed to rental delinquency of Comercio Properties which is the leasing company for the building in which the headquarters is located. HoustonWorks Tolal H-GAC Portion Current $ 39,397.35 7.9% $ 37,946.95 9.2% 130 Days Past Due $ 277,213.56 55.7% $ 214,463.88 52.2% 3160 Days Past Due $ 130.233.32 26.2% $ 123,317.97 30.0% 6190 Days Past Due $ 23,468.38 4.7% $ 10,384.49 2.5% I ~ Over 90 Days Past Due $ 27,027.48 5.4% $ 24,817.48 6.0% Total $ 497,340.09 100.0% $ 410,930.77 100.0% weaver RISK ADVISORY SERVICES Page 10 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 Recommendations: 1. We recommend the Director of Finance either has administrative rights to MIP or processing access only, but not both. He may have the ability to approve requests for new users, as well as prepare workflow assignments; however, the administrative ability to implement changes should be assigned to another management level employee so as to maintain appropriate segregation of duties. 2. We recommend that the IT Manager duties be separated as to remove the ability to add, delete or edit the inventory (fixed asset) tracking sheet. 3. We recommend HoustonWorks design, implement and document standard procedures to ensure that all payment obligations are appropriately and accurately identified as well as paid timely to avoid additional fees, penalties and negative credit rating. c. Procedure: We obtained a population of all non-payroll transactions for the monitoring scope period of October 1, 2011 to May 31, 2012 and selected a sample that includes all transaction types and verify all transactions are identified and classified according to the chart of accounts, transactions are recorded in proper accounting period in which the transaction occurred, records are maintained to the level of detail that establishes funds have been used in compliance with contract requirements, and all items have appropriate supporting documentation and approval. Findings: 1. Medium - (FIN EX-8) We found one issue out of a sample of eight, or an error rate of 12.5%, with mileage reimbursement transactions. There was one instance where the required Travel Expense Report detailing mileage incurred was not signed and approved by an appropriate employee prior to being paid, as required by HoustonWorks. 2. High - (FIN EX-g) We were unable to verify the validity of the monetary amount of the transfer from the General account to the Chase Payroll account on February 29, 2012 in our selected sample or the amount of vacation pay covered by the transfer to the Payroll account on May 3, 2012 due to a lack of sufficiently detailed support. 3. High - (FIN EX-10) FIN EX-10 We identified one SOD issue for an account transfer from the General to Payroll account. We confirmed with Irma Soledad, Accounting Manager, that the transaction was performed on December 23, 2011 by Rudy Martinez, Director of Finance, to reconcile a mathematical error on his part. He initially transferred $282,745.05 to the Payroll account and the correct amount should have been $287,745.05, so there are two transfers to Payroll documented for December 23, 2011 and no documented approval for the second transfer. Recommendations: 1. We recommend HoustonWorks ensures that all mileage reimbursement requests are appropriately reviewed and approved prior to payment as required by the HoustonWorks Accounting Policies and Procedures. 2. All account transfers to the Payroll account from an H-GAC funded account should be supported by sufficient documentation to document the amount of the transfer along with supporting details such as documentation of the number of hours included in the transfer amount, the total expense represented by those hours by person, and the allocation of the cost of those hours and the method behind the allocation. 3. The ability for the Director of Finance to initiate and approve transactions in the banking system should be immediately segregated whereby the transactions must be reviewed and approved by a second member of management. RISK ADVISORY SERVICES Page 11 of 23 weaver HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 D. Procedure: We obtained a population of all employee reimbursable transactions for the monitoring scope period of October 1, 2011 to May 31, 2012 and selected a sample to verify that for each transaction, all reimbursed items have supporting documentation such as approved purchase order and receipts and all transactions have been paid prior to reimbursement by ensuring that reimbursement date is after receipt date. Observation: (OB EX-1) We observed one instance where the Purchase Order for a transaction was miscoded to a different General Ledger account than the one the transaction was actually posted under. The selected reimbursement was coded to the Tuition account, 6845, under the Indirect Cost Pool, 911, but the corresponding General Ledger entry for the reimbursement was coded under the Billings Payable - Vendors account, 2130, in the H-GAC Career Office Cost Pool, 944. This error was self-corrected by HoustonWorks and appropriate documentation exists to document the approval of the correction by HoustonWorks senior management. Findings: 1. Medium - (FIN EX-5) We found one instance where the required application for reimbursement of tuition costs through the Educational Assistance benefit was not signed and approved at time of payout. 2. High - (FIN EX-6) There were five instances where no Purchase Requisition or Expense Report, as required by HoustonWorks' Policies and Procedures, was submitted prior to reimbursement. 3. High - (FIN EX-7) While the policies point to the use of expense reports, in practice HoustonWorks does not follow documented policies and procedures. HoustonWorks relies on purchase orders for employee reimbursements. We found one instance where an employee was reimbursed for expenses, but no purchase order was submitted. Recommendations: 1. We recommend that HoustonWorks implement procedures to ensure that all education tuition reimbursements be approved prior to payment and empower the employee's in the cash disbursement function to delay payments until appropriate supporting documentation is available. 2. We recommend that the responsibility for the completeness and accuracy of all expense reports be assigned to a single employee in the accounting department to ensure there is appropriate documentation for all expense reports and that all the costs included in those reports are allowable. Furthermore, we recommend that no payments be made to employees for expenses that were not approved or lack sufficient supporting documentation. 3. We recommend that HoustonWorks implement an expense report process to comply with the formal policies and procedures currently documented. Accounts Payable Results Summary: HoustonWorks does not adhere to documented policies and procedures related to accounts payable. The informal process being performed does not ensure that outstanding obligations are paid timely. The process currently in place allows for increased debt as payable amounts accumulate late fees and interest charges. Additionally, processing of invoices without adequate supporting documentation raises the risk of unallowable items being charged to H GAC funding streams. RISK ADVISORY SERVICES Page 12 of 23 weaver HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 5. Personnel (Human Resources and Payroll) A. Procedure: We obtained and reviewed the Personnel Policies and Procedures to ensure that they address the following: i. Employee classification and organizational structure ii. Equal Employment Opportunity iii. Hiring and termination procedures iv. Drug testing for new employees v. Background checks vi . Compensation and payroll vii. Benefits viii. Absences , vacations and holidays ix. Harassment x. Substance abuse xi. Employee evaluation xii. Dispute procedures and employee appeals Finding: No issue noted. B. Procedure: We reviewed policies and procedures to determine if they addressed adequate controls that would ensure accurate background checks are performed prior to hiring, a drug free workplace environment exists, employee roles are appropriately classified, and that no individual may be placed in a WIA employment activity if a member of that person's immediate family is directly supervised by or directly supervises that individual. Observatio ns: 1. (OB HR-1) We documented three instances where an IT Work Request was not submitted for completion prior to a terminated employee's last day worked . HoustonWorks, does not currently have polices for the removal of logical access of terminated employees. 2. (OB HR-2) HoustonWorks, H-GAC and Texas Workforce Commission do not currently have any policies in place regarding credit checks for fiscal employees. c. Procedure: We obtained and reviewed job descriptions and the organizational chart to verify that they match current roles being performed by employees. Finding: Medium - (FIN HR-1 ) We were unable to verify the assignment of job responsibilities and reporting structure because accurate job descriptions and a current organizational chart were not made available at the time of the engagement fieldwork . Recommendation: We recommend that HoustonWorks document and maintain current job descriptions that would be made available upon request. D. Procedure: We obtained a population of all payroll related transactions for the monitoring scope period of October 1, 2011 to May 31, 2012 and selected a sample to verify the payee is a documented employee per the approved staff listing, payroll is calculated at the documented pay rate, and the payroll amount is supported by approved timesheet. weaver RISK ADVISORY SERVICES Page 13 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 Findings: 1. Medium - (FIN EX- 1) There were three instances where an employee's time sheet was prepared or approved, but the employee did not certify or approve the prepared timesheet prior to payment. 2. Medium - (FIN EX-2) There were two instances where an employee's time sheet was prepared and submitted, but never approved prior to payment. 3. High - (FIN EX-3) We identified three instances where the employee's time sheet was not available. One transaction in the amount of $1,807.84 was for merit pay and two transactions, in the amounts of $3,667.45 and $4,823.23, were for vacation pay. Without the completed timesheet, there is no documented approval for the merit payout amount and no validation for the vacation hours paid. 4. High - (FIN EX-4 ) We noted two instances where HoustonWorks provided payroll information for the selected employee for the wrong time period. We were unable to verify payroll details for these transactions due to a lack of sufficiently detailed support. Recommendations: 1. Employees should certify their timesheets as correct when submitted for payment. Furthermore, procedures should be developed to ensure timesheets are prepared in a timely manner prior to the distribution of that cycle's payroll . 2. Timesheets should be approved on a regular and consistent basis by the employee's direct supervisor. Furthermore, procedures should be developed to ensure approval by the employee's direct supervisor prior to that payroll cycle and include procedures to escalate the approval to the next level supervisor in the event that the employee's direct supervisor is unavailable. 3. We recommend that HoustonWorks evaluate the current archival methods for payroll data to identify procedures which would ensure that the payroll data is accurate, complete, and readily available for review. 4. HoustonWorks should maintain complete and accurate support documentation for all payroll expenses. These should be available for review upon request as required by the H-HGAC contract. E. Procedure: We reviewed the Quarterly payroll tax returns (941 and TEC) for the organization and the Annual payroll tax returns (940, W-3 and W-2) to verify they were current. Finding: No issues noted. Personnel (Human Resources and Payroll) Results Summary: HoustonWorks personnel procedures do not sufficiently describe how job responsibilities would be adequately distributed in order to lower the risk of inappropriate segregation of duties. Additionally, we were not provided with a documentation that indicated what the job descriptions are currently and therefore we could not verify that employees where performing their intended responsibilities. 6. Cash Management A. Procedure: We interviewed appropriate staff and performed a walkthrough of the cash management process to gain an understanding of the cash management process utilized by the organization and determine if checks are retained securely under lock and key, who has access to checks, who has check signing authority, and how many signatures required to authorize a check. Finding: No issues were noted. weaver RISK ADVISORY SERVICES Page 14 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 B. Procedure: We judgmentarry selected a sample of monthly bank reconciliations for the Operating, Payroll, and accounts for the period of October 1, 2011 to May 31, 2012 and verified that each reconciliation is mathematically the unadjusted balance on the reconciliations agree to bank statement, each reconciliation ending balance agrees to the general and bank reconciliations were performed timely (within 30 days). Observation: (OB BR-1) The April 2012 bank reconciliation for the Chase General account showed a negative balance of $32,789.25 for the month due to checks issued on April 2012 being held in of of H-GAC funding on May 3,2012, rather than being properly voided and reissued. 1. High - (FIN BR-1) There were five instances of bank reconciliations not performed within 30 carendar of the bank statement as required by H-GAC Contract Management Policies and Procedures. Reconciliations for November for the General, Payroll, and Non-Federal accounts were performed 1 86 and 139 days, respectively, after the statements closed. Reconciliations for December for the General and Non Federal accounts were performed 72 and 78 respectively, after the statements closed. 2. (FIN BR-2) The November 2011 Chase General account bank reconciliation ending balance did not match the General Ledger. An un-reconciled difference of $29.95 was documented for the month. 1. We recommend HoustonWorks perform all bank reconciliations within 30 days of the bank statement date as required by the HoustonWorks Accounting Policies and Procedures. This would ensure that any variances are noted and resolved timely. 2. We recommend HoustonWorks perform procedures to ensure that any bank reconciliation variances are investigated and resolved. Cash Management Results Summary: HoustonWorks is in compliance with the minimum requirements regarding the security and authorization of checks. However, we identified instances of non-compliance regarding the appropriate identification and processing of payment obligations which raises the risk that will be beyond an time frame or will be incurred. 7. Property Management and Inventory We obtained and reviewed Property (Inventory) Policies and to determine if policies and procedures address H-GAC property procedures for property purchase and property property property tagging, annual inventory property safeguards and maintenance. Finding: No issues noted. B. We reviewed policies and procedures to determine if address adequate controls that would ensure proper segregation of duties, access to inventory management system, accurate identification and classification of capital and that all and equipment disposal is appropriately reviewed and approved prior to disposal. A. ADVISORY SERVICES 15 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 Observations: 1. (08 INV-1) The annual inventory at HoustonWorks is performed via a manual sheet to shelf count, even though they have the devices necessary to scan the barcodes printed on each asset tag, they are not currently being used due to lack of proper maintenance. 2. (08 INV-2) There is no formal process for inventory disposals. The IT and non-IT disposals are managed separately and at different times, creating inconsistency in the overall disposal process. Finding: High - (FIN INV-1 ) The HoustonWorks inventory database is not secure. HoustonWorks maintains an Excel spreadsheet to track inventory which the Property Control Officer, Procurement Manager, and Director of IT all have write access to this spreadsheet allowing them to change or edit the inventory listing at will. Recommendation: We recommend that HoustonWorks secure the inventory spreadsheet by restricting access only to those whose job responsibilities will not be in conflict such as having custody to the inventory and having read and write access. C. Procedure: We obtained a population of all property and equipment (inventory) purchased or in service from October 1, 2011 to May 31, 2012 and selected a sample from all items with a unit acquisition cost of $500 and greater. We used the sample to verify the inventory records contain the purchase price, brand name, make and model, serial number, model or other identifying number, purchase date, physical location, funding source and percent of funding, and prior H GAC approval for any purchases with a unit price of $5,000 and greater. Observation: (08 ITT-1 ) The purchase price for a Dell OptiPlex computer purchased in 2008 and still in use was documented as $0 in the Inventory Spreadsheet. Findings: 1. High - (FIN ITT-1) The percentage of purchase price covered by H-GAC or other funding streams was not documented for any of the 40 items in our sample and there is currently no area in the Inventory Spreadsheet to record this data. 2. Medium - (FIN ITT-2) The make, model, and/or serial number was not recorded for two inventory items in use during the review period, one being a set of hand dryers, and the other a Sony TV. Recommendations: 1. We recommend that for any items to be shared between funding streams, HoustonWorks develop procedures to document the percentages allocated to each funding stream and include that information in the inventory database. 2. We recommend that procedures be implemented to ensure the accuracy and completeness of each item entered or within the inventory database including the make, model, and serial number. D. Procedure: We verified that any inventory purchases greater than $5,000 were approved by H GAC prior to purchase. Finding: No issues noted . weaver RISK ADVISORY SERVICES Page 16 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 E. Procedure: We verified that a Notice of Inventory Transfer was completed and approved by appropriate organizational personnel and H-GAC staff per contract requirement for a sample of equipment transfers. Finding: High - (FIN ITT-3) There were two instances out of a sample of fifteen transfers, or 13.2%, where Notice of Transfer forms for equipment moved between locations were not signed and approved by the releasing or receiving manager at the time of transfer. Recommendation: We recommend that Notice of Transfer forms are approved by the involved Center Managers prior to the item transfer. Furthermore, we recommend that all items found during the annual inventory in the incorrect physical location, as documented in the inventory database, be returned to the documented physical location until a Notice of Transfer has been properly approved. F. Procedure: For any disposal of property and equipment we verified that a written request was submitted to and an approval was obtained from H-GAC prior to disposal. Finding: There were no identified disposals during our scope period. G. Procedure: For disposed equipment with a market value of greater than $5,000 we verified that the state or federal portion was accurately reimbursed to H-GAC. Finding: There were no identified disposals during our scope period. H. Procedure: We verified that an inventory count has been performed within the last 12 months for each item of non-expendable property with an acquisition cost of $500 or more. Observations: 1. (OB-INV-1) The document we received from the Property Control Officer includes all inventory and is a current, active document. However we cannot verify or attest to the completeness and accuracy of this inventory as it is not a system-generated report, but an Excel Spreadsheet accessed and modified by several individuals at HoustonWorks. Additionally, Houston Works does not have a systematic methodology of tracking inventory. Changes are not adequately tracked from period to period and tied back to the General Ledger. 2. (OB INV-2) HoustonWorks stores all inventory data in an Excel spreadsheet. There have been various process owners in charge of editing and updating the Inventory spreadsheet in the past three years. While H-GAC does not require that HoustonWorks use a specific method of maintain inventory records, using an Excel spreadsheet that has not been consistently maintained creates a risk inaccurate quantities being used in inventory counts and reported to H-GAC. 3. (OB INV-5) The annual inventory for HoustonWorks is coordinated by the Property Control Officer and conducted by one other employee. This year, the inventory count was taken in April and the Property Control Officer has already made plans to re-perform the count because the counts did not appear reasonable to the Property Control Officer during her review. weaver RISK ADVISORY SERVICES Page 17 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 Property Management and Inventory Results Summary: HoustonWorks is not in compliance with the inventory database or transfer documentation requirements identified by H-GAC, Texas Workforce Commission, federal and state guidance which raises the risk that inventory records will be inaccurate, incomplete, or insufficiently documented. However, our procedures concluded that HoustonWorks is in compliance with the requirements for inventory purchases greater than $5,000 and the annual inventory count. There were no property disposals during our testing period so we were unable to verify HoustonWorks' compliance with the documentation requirements of inventory disposal. 8. Cost Allocation and Budget A. Procedure: We obtained and reviewed the Cost Allocation Plan for the current contract year, contract number 103-12, to ensure the following : i. Cost Allocation Plan was submitted to H-GAC within 30 days of the contract date. ii. Cost Allocation Plan addressed rationale for how costs are allocated among various funding streams and cost categories. iii. Cost Allocation Plan addressed the rationale for how costs are allocated to an H-GAC contract as opposed to other funding sources. iv. Cost Allocation Plan addressed indirect, pooled costs, direct charging and facilities costs. v. Cost Allocation Plan was certified by an authorized official of the organization certifying that the plan has been prepared in accordance with authorizing legislation and regulations, and state or other applicable requirements. vi. Any changes to the cost allocation plan or methodology was submitted to H-GAC within 10 days of implementation, and the cost allocation complies with Texas Workforce Commission (TWC) Financial Manual for Grants and Contracts, Chapter 11, Cost Allocation and includes Organization information and current budget or financial statement. Finding: No issues noted. B. Procedure: We compared the Cost Allocation Plan to the approved budget and ensured that category amounts matched . Finding: High - (FIN CA-1) We identified that there were differences in the Cost Allocation Plan and the most current approved budget. See Table 1 below for additional information on the results: weaver>-RISKADVISORY SERVICES Page 18 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 T bl 1 C t All f B d t A a e : os oca Ion u Ige versus lpprovedB d U t e LINE ITEM EXPENSE Cost Allocation Total Budget Total Variance Between Cost Allocation Line Item and Budget Line ltem* Personnel Wages & Salaries $ 9,444,471.00 $ 9,472,607.00 $ 28,136.00 0.3% Personnel Fringe Benefits $ 2,773,841.00 $ 2,782,105.00 $ 8,264.00 0.3% AudiULegal/Non Staff Services $ 137,800.00 $ 137,800.00 $ - 0.0% Consulting Services Only $ 67,550.00 $ 67,550.00 $ - 0.0% Facilities - Career Offices Only $ 2,193,102.00 $ ,416,924.00 $ 223,822.00 10.2% Facilities - other than Career $ 211,329.00 $ 211,329.00 $ - 0.0% Offices Equipment - IT $ 135,838.00 $ 135,838.00 $ - 0.0% Equipment - Other Equip. & Fum $ 849,230.00 $ 849,230.00 $ - 0.0% Communications - IT /Network $ 31,430.00 $ 31,430.00 $ - 0.0% Communications - Other than IT $ 398,933.00 $ 362,533.00 $ (36,400.00) -9.1% Travel - In Region $ 57,801.00 $ 57,801 .00 $ - 0.0% Travel - Out-of-Region $ 11,645.00 $ 11 ,645.00 $ - 0.0% Insurance $ 123,532.00 $ 123,532.00 $ - 0.0% Office Supplies $ 148,647.00 $ 148,647.00 $ - 0.0% Printing/Photocopying $ 45,300.00 $ 45,300.00 $ - 0.0% Public Info/Outreach $ 30,010.00 $ 30,010.00 $ - 0.0% Subscriptions - Assoc dues $ 7,500.00 $ 7,500.00 $ - 0.0% Subscriptions - Resource Room $ 8,283.00 $ 8,933.00 $ 650.00 7.8% Subcontracts $ 51,650.00 $ 51,650.00 $ - 0.0% Total $ 16,727,892.00 $ 16,952,364.00 $ 224,472.00 1.3% 'Varlance = (Budget Total - Cost Allocation Total)/Cost Allocation Total Recommendation: We recommend that HoustonWorks develop procedures to ensure the most current approved budget accurately reflects the approved budget in the Cost Allocation Plan. c. Procedure: We performed a walk forward process based on a judgmentally selected sample of budget months to verify that monthly fund balances and accumulative fund balances are accurate within budget line items. Finding: High - (FIN CA-2) We were unable to verify that the accumulative fund balances are accurate within line items because we were not provided with all financial billing reports submitted to H-GAC. We identified three instances out of a sample of five where the actual expenditures for the month exceeded the budgeted expenditures for that month. See Table 2 below for additional information on the results: RISK ADVISORY SERVICES Page 19 of 23 weaver HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 Month Table 2: Cost Allocation Variances from Selection 1 2 3 4 5 Month Budget Line Item Period Spend Billing Allocation Variance ratio Plan ratio Recommendation: We recommend that HoustonWorks develop procedures to review the billing ratios against the Cost Allocation Plan on a monthly basis to ensure the accumulated amounts do not exceed the budgeted ratio. Cost Allocation and Budget Results Summary: HoustonWorks is in compliance with the contractual requirements regarding the required items to be included in the Cost Allocation Plan as well as the authorization, submission and change notification requirements identified by H-GAC. However, we identified instances of non-compliance regarding the included budget in the approved Cost Allocation Plan which increases the risk that HoustonWorks will be unable to accurately track the allocated funds. We also identified instances of non-compliance regarding the allocation of expenses in comparison to the budgeted amounts which increases the risk that HoustonWorks will exceed the budgeted line items without prior H-GAC approval. 9. Financial Reporting A. Procedure: We interviewed appropriate staff and performed a walkthrough to gain an understanding of the cost allocation and financial reporting process. We obtained all monthly financial reports from October 1, 2011 to May 31, 2012 and proof of submission to H-GAC to verify financial reports match supporting documentation submitted to H-GAC, total expenditure line item amounts are within the budgeted monthly funding streams amounts by comparing the corresponding submitted financial reports and GL expenditure amounts for the period, any budget amount variances are approved by appropriate organizational staff and H-GAC, reports were submitted to H-GAC no later than the close of business on the ninth of the month for expenditures through the end of the previous month, and that financial reports were reviewed and approved prior to submission to H-GAC. Findings: 1. High - (FIN FR-1) Financial reporting for the sampled periods of October 2001, December, 2011, February 2012 and April 2012 did not have variances in the total amounts reported to H-GAC . However, there was a variance within cost allocation category in Administration costs for WIA Adult funding stream for the month of December 2012 of $2,977.52. weaver RISK ADVISORY SERVICES Page 20 of23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17,2012 2. Medium - (FIN FR-2) There is not a documented review and approval process. Reports submitted to H-GAC for the months of March, April and May do not indicate that the Director of Finance reviewed the reports prior to submission. These reports were submitted by the Contract and Billing Assistant. Recommendations: 1. We recommend that all financial reports submitted to H-GAC be reviewed to ensure that all cost allocations categories as well as the totals are mathematically accurate and representative of the General Ledger. Furthermore this review should be formally documented and archived. 2. We recommend that a formal review and approval process be implemented for all financial reports submitted to H-GAC. We recommend that the Director of Finance and the Chief Executive Officer both be included in the review prior to the submission of the financial report and formally evidence their review. B. Procedure: We reviewed policies and procedures and interviewed appropriate staff to gain a thorough understanding of the contract close out reporting process. We also identified controls in place that ensure accurate reporting including cut off period, items are reported in the correctcost allocation categories and budget line items as well as timely submission of reports to H-GAC. Finding: Low - Policies were documented adequately but we were unable to test as the closeout procedures had not been performed as of May 31,2012. No issues noted. C. Procedure: We verified that the A-133 Single Audit has been performed and submitted to H-GAC within 30 days of completion or nine months of the end of the audit period. Finding : No issues noted. Financial Reporting Results Summary: HoustonWorks is in compliance with the minimum requirements identified by H-GAC, Texas Workforce Commission, federal and state guidance with regards to the documentation of close out procedures, the performance and reporting of an annual A 133 Single Audit, the approval of budget amount variances, adequately supported financial reports and the timely submission of financial reports. However, we identified instances of non-compliance in the financial reporting process specifically regarding the reporting of budget to actual variances and the review and approval of financial reports prior to submission to H-GAC which raise the risk of unauthorized, incorrect, or inaccurate reports will be submitted to H-GAC. 10. Customer Complaints A. Procedure: We verified that the Workforce Solutions complaint poster is posted in clear and open view of public traffic. Finding: No issues noted. Customer Complaints Results Summary: HoustonWorks is in compliance with the minimum requirements identified by H-GAC, Texas Workforce Commission, federal and state guidance. RISK ADVISORY SERVICES Page 21 of 23 weaver HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 11. Subcontracts A. Procedure: We obtained a list of all subcontracts and verified that subcontractors were not suspended or debarred by checking the Excluded Parties List at: www.elps.gov, subcontractors were approved by H-GAC if applicable, subcontractors certified that they are current with State franchise taxes or that they are a non-profit corporation. Additionally, we verified that subcontract contract language includes provisions as stated in Section III of H-GAC Contract Management Policies and Procedures and that all subcontractor invoice payments were timely and for allowable costs. Finding: Medium - (FIN SU8-1) HoustonWorks does not currently have a process in place to verify that subcontractors are not debarred and are current with their state franchise taxes. Recommendation: We recommend that procedures be implemented to verify that all new subcontractors are not debarred and are current with their state franchise taxes prior to the execution of any contracts with the subcontractor. Furthermore, we recommend that all subcontractors that have contracts with HoustonWorks, as well as all vendors which meet the subcontractor criteria as identified in the H-GAC financial guidance, be reviewed on an annual basis to ensure they continue to remain off the debarment list and continue to be current with their state franchise taxes. Subcontracts Results Summary: HoustonWorks cannot support their compliance with the requirements identified by H-GAC, Texas Workforce Commission, federal and state guidance because a subcontractor review and approval process does not exist. This increases the risk that contracts will be inappropriately executed, or will not provide sufficient clauses to maintain compliance with H-GAC procedures. 12. Insurance A. Procedure: We obtained certificates of insurance providing coverage on commercial general liability, worker's compensation and all equipment and inventory purchased with H-GAC funds and ensured that H-GAC is listed as loss payee for all equipment items and all minimum threshold amounts of coverage are met (10% of total contract amount) . Finding: Medium - (FIN IN-1 ) The Texas Workforce Commission's Financial Management of Grant Contracts and H-GAC's contract management policies and procedures require that HoustonWorks, as a workforce services provider, list H-GAC as the loss payee on all insurance and bonding certificates. For each of the five policies reviewed , H-GAC was not listed as a loss payee. Recommendation: We recommend that HoustonWorks immediately initiate actions to list H-GAC as a loss payee on the insurance policies as required by the H-GAC Contract Management policies and procedures. Insurance Results Summary: Insurance coverage retained by HoustonWorks meets the minimum coverage threshold criteria identified by H-GAC policies and procedures, but does not follow all minimum requirements regarding the loss payee designation clauses . This raises the risk that H-GAC will not recover their portion of the loss of fixed assets in the event of a catastrophic loss. weaver RISK ADVISORY SERVICES Page 22 of 23 HOUSTON - GALVESTON AREA COUNCIL WORKFORCE SOLUTIONS FINANCIAL MONITORING REPORT JULY 17, 2012 CONCLUSION Based on our procedures, we recommend that HoustonWorks prepare an action plan to address the identified noncompliance items, including expected timelines for completion, and submit the action plan to H-GAC for review and approval. Subsequent monitoring procedures should be performed to ensure the issues identified have been appropriately addressed. CLOSING We conducted a closing meeting to identify procedures performed and communicate results of our procedures. The closing meeting was conducted on Thursday, June 21,2012, at 10:00 AM. Attendees included: Russell Tomlin HoustonWorks Executive Director Rudy Martinez Director of Finance Monica Williams Senior Director of Administration Irma Soledad Accounting Manager Georgetta Mitchell Customer Service Supervisor Shaun Loether IT Manager Terry Hudson Consultant Mike Temple H-GAC Representative Sharron Powell H-GAC Representative Alyssa Martin Weaver and Tidwell, LLP Tamara Shepherd Weaver and Tidwell, LLP RISK ADVISORY SERVICES Page 23 of 23 weaver