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1. Audit of Procurement Card Process ABSTRACT Controls over $6 Million resources need improvement. Recommended changes and Administration's actions during the 1 audit will improve controls. / Umesh Dalal, City Auditor AUDIT OF PROCUREMENT CARD PROCESS I n» DENTON Table of Contents Description Executive Summary 1 Detailed Report ❖ Introduction 3 ❖ Management Responsibility 3 ❖ Background 3 ❖ What Works Well? 4 ❖ Compliance with Procurement Regulations 5 ❖ Excessive Number of Cards 10 ❖ Supervisory Approvals 13 ❖ P-Card Administration 15 ❖ Internal Controls Weaknesses 15 ❖ Need for Training 17 ❖ Opportunity for Savings 18 The City of Denton Procurement Card Audit Report June 2019 Executive Summary Honorable Mayor and members of the City Council, The City Auditor's office has completed an audit of the Procurement Card (P-Card) management process. The City's P-Card program is expected to improve efficiency and expediency of purchasing certain products or services which are either low dollar items or needed for emergency operational needs. However, P-Cards are vulnerable to misuse and therefore, adequacy of internal controls over this process is critical. During the audit period from July 1, 2017 through July 31, 2018, the City incurred about $6 million in charges on P-Cards. The objective of the audit was to verify internal controls over City resources and procedures and evaluate efficiencies in the Division's processes. It should be noted that during the audit, the Compliance Officer was assigned responsibility to manage P- Card purchases. The Compliance Officer has made progress in resolving some of the control deficiencies. The following are the salient findings of the audit: • Overall, the controls over this program appear to need improvement. Significant concerns are related to lack of compliance with procurement regulations. The absence of established processes and Purchasing Division's (Purchasing) previous interpretation of statutes resulted in non-compliance with procurement regulations for P-card purchases. The audit identified seven vendors from whom more than $50,000 in merchandise was purchased without inviting sealed bids (Appendix 1). These purchases totaled about $674,000. In addition, the City purchased approximately$2.7 million in merchandise exceeding$3,000 but less than $50,000 from each of 327 vendors but did not request the required quotes from two underutilized businesses. In addition, we observed that the City has not complied with procurement regulations related to food purchases. City employees could incur significant liability for non-compliance with procurement regulations. Purchasing has taken measures to comply with the statutes and has agreed to implement monitoring process to mitigate the above deficiency. We have conducted a detailed assessment of compliance with the procurement regulations in the subsequent audit of the Purchasing Division. We have issued a separate report on the Procurement Process. • Value contributed by the audit: a� an a The City of Denton Procurement Card Audit Report June 2019 o Implementation of recommendations will improve the City's compliance with the City and State procurement regulations. o Enhanced monitoring recommended in this report could help the City look for opportunities for additional savings due to economy of scale and to reduce costs incurred in the procurement of products and services. The amount of potential savings cannot be estimated as relevant data is not available. o Currently, the City is incurring retail costs of about $412,000 for air travel, rental cars and hotel accommodations incurred for City business. The audit identified an opportunity to either save costs or obtain rebates to reduce these expenditures. The attached detailed report includes additional information. The City Auditor's Office appreciates the cooperation of the City staff during this audit. This audit made 14 recommendations. The Purchasing Division has concurred with all of them. Implementation of 8 recommendations is already completed. If you have any questions or comments, please contact me at(940) 349-8158 or at umesh.dalal@cityofdenton.com. Umesh Dalal, City Auditor N a The City of Denton Procurement Card Audit Report June 2019 Introduction The City Internal Auditor is responsible for providing: (a)an independent appraisal of City operations to ensure policies and procedures are in place and complied with, inclusive of purchasing and contracting; (b) information that is accurate and reliable; (c) assurance that assets are properly recorded and safeguarded; (d) assurance that risks are identified and minimized; and (e) assurance that resources are used economically and efficiently and that the City's objectives are being achieved. The City Auditor's Office has completed an audit of the P-Card program managed by the Procurement Department. The objectives of the audit wereto evaluate internal controls in the Division's procedures. The audit was conducted in accordance with the Generally Accepted Government Auditing Standards promulgated by the Comptroller General of the United States.Those Standards require that the auditors plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for their findings and conclusions based on the audit objectives.The auditors believe that the evidence obtained during this audit provides a reasonable basis for their findings and conclusions based on the audit objectives. Management Responsibility The City management is responsible for ensuring resources are managed properly and used in compliance with laws and regulations; programs are achieving their objectives;and services are being provided efficiently, effectively, and economically. Management is responsible for establishing and maintaining a system of internal accounting and management controls. In fulfilling this responsibility, management is required to assess the expected benefits and related costs of control procedures. Background P-Cards are used to gain one or more of the following benefits: • Improvement in accounts payable and accounting efficiencies as follows: Usually it takes significant effort and expense to issue a check for expenses incurred. Since a number of transactions incurred on P-Cards are paid with one wire transfer; it saves effort and expense of issuing multiple checks. Transactions are generally summarized, which help in the accounting process. • Emergency needs or the necessity to purchase a small item with low cost avoid an extended delay of processing, purchasing and accounts payable paperwork. • Since all the transaction data is electronically available from the bank for better analysis, there is improved management reporting. m The City adopted the P-Card program in 2007. This program is administered by the Procurement Division. During the audit period of July 1, 2017 through July 31, 2018 the following departments are the major users of P-Cards: The City of Denton Procurement Card Audit Report June 2019 P Card Spending L� Parks $425,680 �ILibrary $201,008 Lul Water $251,061 Dev. Svcs/Plan. *1 DME $134,017 LIHR Lol Waste Water Mat. Mgmt. • 8,439 *1 Fire $74 Tech Services Lol Fac. Mgmt Police . 135,955 *Solid Waste Airport/Fleet • •: L]Others $192,955 $ 38,950 The Parks department spent more than a million dollars on P-Cards during the audit period. Each of the City's utilities and the public safety departments also spent substantial amount on P-Cards respectively. What Works Well? Timely cancellation of cards upon employee terminations, recovering for fraud against the City, and transaction audit processes are working as expected. The auditors found that the P-Card Administrator in the Procurement Department had a good understanding of the P-Card process. The auditors found the following: • All employee terminations have been recorded in a timely manner and the cards assigned to these positions were canceled immediately. This prevented the potential for abuse. • All transactions involvingfraud by the third parties were successfully followed up. The City received credits for all of the transactions that were charged on the City's cards but did not belong to the City. • P-Cards transactions audit process represents a control mechanism, which would identify abuse of cards and noncompliance with the established procedures. These audits were conducted as expected. However, the results need to be summarized and reported to management. aA �a a. The City of Denton Procurement Card Audit Report June 2019 Opportunities for Improvement: Compliance with Procurement Regulations Major Purchases more than $50,000. Compliance with State Procurement Regulations including sealed bidding, is needed. What we found? The City's procurement of goods and services must comply with City Charter, State law, and City ordinances, supplemented by City Council resolutions and administrative policies. Unless a purchase is otherwise exempt from competitive bidding, Texas Local Government Code ("State Statute') Section 252.021 requires, "(a) Before a municipality may enter into a contract that requires an expenditure of more than $50,000 from one or more municipal funds,the municipality must: (1) comply with the procedure prescribed by this subchapter and Subchapter C for competitive sealed bidding or competitive sealed proposals; ... Sec. 252.043. AWARD OF CONTRACT. (a) If the competitive sealed bidding requirement applies to the contract for goods or services, the contract must be awarded to the lowest responsible bidder or to the bidder who provides goods or services at the best value for the municipality." It should be noted that the State Statute applies to the municipality, as a whole. It does not recognize separate departments or transactions for complying with the requirements. During the audit period, significant P-Cards transactions were incurred in the following categories,which is about 86%of the total P-Card expenditures during the audit period: Categories Services $1,727,485 Supplies $1,769,688 Electronics $312,541 Materials $381,060 Furniture,Equipment $637,483 Food $268,917 Tota 1 $5,097,174 Lf') a� c� a The City of Denton Procurement Card Audit Report June 2019 During the audit period, the City made purchases exceeding $50,000 each from seven vendors (Appendix 1).These purchases totaled about$674,000 and were made without inviting formal sealed bids. This occurrence represents non-compliance with procurement regulations. It should be noted that a limited analysis to verify compliance with state statutes was conducted during this audit. More comprehensive analysis has been performed during the subsequent audit of the purchasing function. Other purchases included in the table need to be analyzed to determine the City's compliance with procurement regulations. We observed that the City does not have a contract for food purchases. As depicted in the above table, the City spent $268,000 during the audit period. Therefore, the City did not comply with procurement regulations related to food purchases. Purchasing previously interpreted the statutes to only require sealed bids/proposals for a single purchase exceeding $50,000. Therefore, they were not monitoring cumulative purchases that exceed $50,000. According Procurement Statutes, if separate purchases of items that in normal purchasing practices would be purchased in one purchase cumulative exceed the$50,000 threshold, compliance with the required sealed bidding/proposals provisions is required. The Procurement statutes do not specify a timeframe for combining separate purchases in order to determine compliance with the required sealed bidding/proposals provisions. The P-Card Administrator may need to improve efforts to monitor and enforce compliance with procurement statutes or policies. The Compliance officer acknowledged this need. Purchases less than $50,000. What we found? The City did not comply with the Procurement regulations. Section 252.0215 of State Local Government Code requires, "A municipality, in making an expenditure of more than $3,000 but less than $50,000,shall contact at least two historically underutilized businesses on a rotating basis, based on information provided by the comptroller pursuant to Chapter 2161, Government Code." During the audit,we found at least 327 instances where purchases exceeding$3,000 were made as single or multiple purchases. These purchases totaled about$2.7 million. Quotes from historically underutilized �10 businesses as required by the State Statute were not obtained on these purchases. a The City of Denton Procurement Card Audit Report June 2019 We were informed that the default card limits were set at $3,000 as a proactive safeguard. This limit prevents cardholders from purchasing items or services in excess of the amount that requires quotes. However, on three of the above occasions, the P-Card Administrator increased card limit beyond $3,000 to enable these purchases. At least 17 cards have a pertransaction limit of more than$3,000. Therefore, these card holders potentially could make purchases exceeding $3,000 and not comply with procurement regulations. This occurrence will not be prevented prior to the employee's action. In this case, non-compliance with procurement regulations will not be detected or corrected in a timely manner. As described before, Purchasing interpreted statutes to only require two or more HUB quotes with a single purchase of$3,000 or more. According to Procurement Statutes, if separate purchases of items that in normal purchasing practices would be purchased in one purchase cumulative exceeds the $3,000 threshold, compliance with the required HUB provisions is required. Purchasing indicated that they will conduct the same review process as described above and comply with HUB statutory requirements when applicable. Why does it matter? Without verification, it is not possible to assure the City's compliance with the Procurement Statutes.The City employees could incur significant liability for non-compliance with procurement regulations. According to the State Statute, "If a person fails to comply with the competitive bidding or competitive proposal procedures required by Chapter 252, that person may be convicted of a Class B misdemeanor. This includes a situation in which a person makes or authorizes separate, sequential or component purchases in an attempt to avoid competitive bidding requirements. A Class B misdemeanor may be punished by a fine of up to $2,000, confinement in jail for up to 180 days, or both the fine and confinement." The current expectations from the departments to verify compliance with procurement requirements appear to be unreasonable. As a result of these expectations, the compliance may not be currently verified. This issue is highlighted in subsequent observations. Recommendations: 1. The Purchasing Division needs to satisfy its responsibility of monitoring purchases made by using P-Cards and enforcing compliance with State procurement statutes. Currently, this task may not be accomplished effectively due to lack of dedicated resources.The Purchasing Division may need help in this area. 2. Educate the department personnel responsible for verifying P-Card transactions regarding their duty for and information to verify compliance with procurement regulations. a� an �a a. The City of Denton Procurement Card Audit Report June 2019 City Management Response June 6, 2019: The City is implementing a new p-card system which has enhanced reporting capabilities and will allow Purchasing staff to monitor cumulative purchases over a 12-month period to ensure compliance with procurement statutes. Training for cardholders and supervisors is scheduled for July 2019 with implementation in September 2019. Staff is currently reviewing cumulative p-card purchases over the past one (1) year to identify opportunities for formal solicitations and contracts. Staff will continue this practice moving forward. It should be noted the reviews will be retrospective and will not prevent future purchases from taking place by individual card holders. Prior to the audit, staff interpreted the statute as single transactions exceeding $3,000 and less than $50,000, require extending the opportunity to quote from 2 Historically Underutilized Businesses and no documentation was required by the P-card Program Administrator. As of October 2018, p-card holders are required to provide documentation verifying compliance with the State's statute to extend the opportunity to quote from 2 HUB vendors in Denton County for purchases between $3,000 and $49,999. Staff has implemented a "P-card Increase Form" that requires card holders to affirm their responsibility in requiring the opportunity to quote from 2 Historically Underutilized Businesses for purchases between $3,000 and $50,000 when requesting a p-card limit increase over$3,000.There are currently 13 card holders, of a total 422 card holders, with a single transaction limit greater than $3,000. Staff will monitor for compliance with the procurement statutes related to HUB vendors moving forward. The City has already contracted with four (4) of the seven (7) vendors identified in Appendix I in order to bring expenditures into compliance with procurement statutes. Staff will be bringing forward another two (2) contracts for Council consideration in the upcoming months. One (1) vendor is not available through a cooperative purchase agreement and the products routinely purchased will be made available in the City's Distribution Center. The City purchases food for a variety of events, departments, programs and meetings. Additionally, many purchases are made ad-hoc as the need arises. Staff is working to establish a qualified list of food vendors for planned programs and events.The application has been made available on the City's website and is open to all food vendors. Beginning March 5, 2019, a "Food Purchase Justification Form" is required for any food purchases made on a p-card.The form requires the cardholder to justify the purchase, explain the selection process and requires Department Director approval. Food purchases will be reported to the City Manager on a quarterly basis. 00 a) aA a a The City of Denton Procurement Card Audit Report June 2019 Lack of monitoring P-Cards purchases could result in missing cost saving opportunities The P-Card manual states: "At the end of each billing cycle, the Purchasing Card Administrator will review the master JP Morgan Chase bank statement and request clarification of purchases to determine: • Monthly or multi-months purchase trends, which may indicate split or combined Purchasing Card purchases to circumvent competitive quoting/bidding requirements • Purchase trends indicating the need to bid and establish annual contracts for repetitively obtained goods and services • Purchases that exceed the established per transaction ceiling or exceed the designated per month expenditure limit(card usage violations)" Upon inquiry, the Compliance Officer informed auditors that due to high P-Card transaction volume, the P-Card Administrator is unable to review purchases for compliance. In addition, the Purchasing Division does not evaluate purchases to determine if entering into a contract will result in better pricing and lower cost for the City. Regular audits are also a method used to prevent contract or procurement violations. Currently, the Compliance Officer is working on finding a solution that will make it easier for cardholders to check for active contracts. We had the following observations: • Currently neither Purchasing staff nor Departments are monitoring P-Card purchases to identify consolidation and seek volume discounts. • Several Department Directors were unaware of how to access to the City contract list.The P-Card manual also indicates that P-Cards are not to be used for the purchase of items available from the Distribution Center and Fleet Services. However, the departments do not have access to the inventory to search for parts and supplies that are available at these locations. Why does it matter? The City may be purchasing similar commodities from different vendors. Consolidation of these purchases and negotiating contracts to receive volume discounts could result in cost savings. For example, we noticed that during the audit period, the City purchased about$83,000 in products a The City of Denton Procurement Card Audit Report June 2019 from Lowes and $61,000 in products from Home Depot. Both businesses sell similar merchandise. The City does not have a contract with either of them. There are other examples of similar purchases made from different vendors. If a thorough analysis of purchases made from different vendors is performed to identify bulk purchasing opportunities to seek volume discounts, the City's costs may be reduced. The potential savings from these procedures cannot be identified as the procedures don't exist and relevant information is not available. In addition, due to lack of information, there is a risk that the departments could be buying merchandise that they should be obtaining from the City's warehouse or from vendors with which the City has contracts. Recommendations: 3. The Purchasing Division needs to work with departments for the monitoring of purchases made on P-Cards and attempt to identify consolidation opportunities to obtain lower prices through contracting or receiving discounts. 4. Educate the department personnel responsible for verifying P-Card transactions regarding their duty for and information to verify compliance with procurement regulations. City management response: During the audit period, staff reviewed purchases on a monthly basis with no cumulative review of prior months' transactions until the end of the fiscal year. The City is implementing a new p-card system which has enhanced reporting capabilities and will allow Purchasing staff to monitor cumulative purchases over a 12-month period to ensure compliance with procurement statutes.Training for cardholders is scheduled for July 2019 with implementation in September 2019. As of October 2018,training material for new p-card users includes more information regarding the p-card holder's responsibilities when verifying transactions and compliance with procurement regulations. Excessive Number of Cards Many cards are used sparingly. Eliminating these cards will reduce the City's exposure to risk of misuse and improve controls. O The available P-Card list showed that the City had 445 credit cards during the audit. The City has �a a The City of Denton Procurement Card Audit Report June 2019 1,445 employees. This means every third employee in the City had a P-Card. Some of these cards were used infrequently. What we found? There were 126 P-Cards that were used either once a month or less. There were at least 24 cards that were not used for at least three months. Seven of these cards were not used for a year or more. Subsequently,the Department informed auditors that 12 of these cards had increased use in subsequent period and 39 cards were terminated but the records erroneously depicted them as active. Fifteen additional cards were terminated after the audit period. Each department used the remaining cards as follows: -.. UnderUsed Cards -. CITY MANAGER 3 8 38% DEVELOPMENT SERVICES 2 12 17% DME 14 60 23% ECONOMIC DEVELOPMENT 1 6 17% FACILITIES MANAGEMENT 0 16 0% FIRE 9 49 18% FLEET SERVICES 1 5 20% HUMAN RESOURCES 1 6 17% LEGAL 1 4 25% LIBRARY 3 23 13% MATERIALS MANAGEMENT 6 16 38% MUNICIPALCOURT 1 3 33% PARKS 3 54 6% POLICE 5 32 16% REALESTATE 4 4 100% SOLID WASTE 3 18 17% STREETS 1 6 17% TECH SERVICES 12 31 39% WASTEWATER 2 30 7% WATER 3 34 9% Total 75 We found the following six cards had significantly higher limits compared to their use: a� aA �a a The City of Denton Procurement Card Audit Report June 2019 1 $10,000 $20,000 1 $75 $6 2 $10,000 $20,000 1 $1,211 $93 3 $10,000 $20,000 3 $962 $74 4 $10,000 $20,000 6 $323 $25 5 $10,000 $20,000 10 $8,896 $684 6 $25,000 $100,000 13 $9,825 $756 *Legend for Table Titles: A: Cardholder designated by number B:Authorized amount per transaction C: Maximum authorized amount per month D: Number of transactions during the audit period E:Total spending during audit period F:Total Spending per month Why does it matter? These observations indicate that frequency of utilization of P-Cards is not being reviewed or monitored. Elimination of these cards and using other cards available in the department to carry out these purchases will not hinder the City's operation. In some Departments such as Real Estate and Solid Waste, a significant proportion the of cards are seldom used. This presents an opportunity for additional consolidation. Several Directors indicated the possibility of consolidating P-Cards in their Departments. The current situation empowers certain City employees to incur liability for the City. The sparingly used P-Cards are associated with per transaction and aggregate monthly credit limits totaling $300,000 and $353,000 respectively. In addition, having unnecessary cards increases the potential for abuse. Generally, a limited number of cards assigned to fewer employees helps in administration and monitoring compliance. This process may encourage involving more than one individual in making required purchases, which in turn, will improve controls. Recommendations: 5. Eliminate sparingly used cards and use other cards available to the respective Departments for making necessary purchases. N 6. Look for additional opportunity for consolidation of cards to facilitate better administration of P- a� Cards. a The City of Denton Procurement Card Audit Report June 2019 City management Response: As of February 20, 2019, there are 422 cardholders due to elimination of several sparingly used cards. Staff continues to collaborate with departments to identify sparingly used cards that can be eliminated. Supervisory approval process could be improved. What we found? P-Card purchases typically involve an employee unilaterally deciding and carry out purchasing activity. In this process, if there has been supervisory involvement, it is not documented, and available evidence does not support it. Under these circumstances, the risk of abuse of P-Card privilege increases. The established procedures require P-Card purchases to be reviewed and approved by a supervisor. This is the only, ongoing effective control that ensures appropriateness and reasonableness of purchases made. The auditors found that 862 transactions were not approved by supervisors as follows: Department •- of Total'---,, amountTransactions Airport 11 $2,791 City Manager 45 $10,761 Dev.Services 41 $8,013 DME 90 $24,451 Economic Dev. 39 $11,312 Fire 16 $3,594 Fleet Services 34 $8,640 Legal 23 $2,783 Library 11 $1,074 Materials Mgt. 33 $10,895 Parks 252 $73,785 Police 10 $470 Real Estate 4 $351 Solid Waste 121 $28,221 Streets 8 $5,138 Tech.Services 25 $11,867 Waste Water 56 $18,131 M Water 43 $16,635 r—I Total 862 $238,912 a The City of Denton Procurement Card Audit Report June 2019 The P-Card Administrator audits 20 card accounts per month. This process is effective; however, it will allow some of the P-Card transactions to go as long as two years before being audited. Why does it matter? Employees are empowered to make purchases on Amazon.com or Walmart.com. This is acceptable as the City can find some better deals on these websites. However, these websites offer many types of merchandise. Some of which could be used for personal consumption of employees. Therefore, there are vulnerabilities associated with these types of purchases. The procedures require employees to document the nature and purpose of the purchase and supervisors are expected to verify them. The risk increases if the supervisors do not approve these purchases. We found that the above transactions included 178 transactions with Amazon with a total value of $20,850. These transactions were not approved by the supervisors. Fifty-five of these transactions did not have the description of items purchased.The City does not require P-Card holders to upload their receipts to the J P Morgan system. This situation further hinders verification of these purchases. In addition, supervisors not approving a significant number of transactions for almost $238,000 may lead to the risk that P-Card abuses that may not be detected and addressed in a timely manner. Recommendation: 7. Suspend P-Cards for which transactions are not approved by the supervisors after giving adequate warning. 8. Require employees to upload their receipts in J P Morgan system. City management response: The aforementioned recommendations have been addressed as of October 26, 2018. As of October 2018, p-card holders are required to upload receipts in the JP Morgan system. Staff monitors for compliance monthly. All 862 outstanding supervisory approvals identified in the audit period were approved as of October 26, 2018.There are currently no outstanding supervisory approvals. —I a� aA �a a The City of Denton Procurement Card Audit Report June 2019 P-Card Administration The P-Card Administrator had the responsibility to administer card use but did not have authority to enforce compliance. What we found? We observed that the Administrator sent e-mails to several employees repeatedly (up to four email reminders)for reconciling and approving P-Card transactions.The P-Card policy provides for cancellation of the card. However, the Administrator had no authority to cancel the card. During the audit, the auditors were informed that Administration has escalated follow-up process to the City's compliance officer, who will be responsible for taking action for non-compliance. Why does it matter? Lack of enforcement of P-Card policy may encourage non-compliance as employees may give lesser priority to these tasks. Recommendation: 9. The Compliance Officer needs to establish a process for monitoring compliance and enforce the City's policy for non-compliance with P-Card procedures. City management response: The aforementioned recommendation has been addressed effective October 5, 2018; all outstanding approvals were completed. Internal Control Weakness Both the City's P-Card Administrator and the alternate Administrator had P-Cards.Abuse of any of these cards will not be detected in a timely manner. The City's P-Card Administrator is an associate buyer in the Procurement Department. The Department has assigned an alternate Administrator to fill in when the Administrator is not available. a� aA �a a The City of Denton Procurement Card Audit Report June 2019 What we found? Both the Administrator and alternate Administrator had P-cards assigned to them in addition to the ability to: set up an account, reconcile, review, approve transactions, and recommend transactions for payment. In addition, they had an enhanced level of access to the J P Morgan system. We were informed that during the audit, the cards assigned to both these individuals were cancelled. Why does it matter? It was possible to set up additional an account, reconcile and approve transactions on that account, and make recommendations for payments without involvement of any other individual. Recommendations: 10. The P-Card policies and procedures need to be updated prohibiting assigning cards to individuals responsible for administering the program. 11. Periodically, the Compliance Officer needs to review active cards to determine appropriateness and business needs for the charge card accounts. City management response: The aforementioned recommendations will be addressed in the revised P-Card Manual, expected to be completed when the audit is finalized. P-Card Audit Process: The Audit process is working as intended. What we found? The established practice requires the P-Card Administrator to select and audit 20 card accounts each month. This means that the Administrator would need 22 months to audit 445 cards. The P-Card administrator is conducting audits as intended. The Administrator follows up with the user to correct discrepancies observed. However, no report of her work is being made to the Compliance officer. 110 —I an �a a. The City of Denton Procurement Card Audit Report June 2019 Why does it matter? This process is generally working well. Recommendation: 12. Notify results of audits to the Compliance Officer. City management response: Management agrees with the recommendation and will begin reporting monthly audit report findings to management. Training Currently, P-Card training is not provided to the supervisors who approve the transactions but are not cardholders. What we found? Current procedures require that all the employees receiving P-Cards must go through training to understand the City's policies and rules related to P-Card. However, the supervisors that do not have cards but are required to review the card transactions do not get such training. These individuals are required to enforce the P-Card rules but may not have thorough knowledge of these rules. Why does it matter? The approval process is the only ongoing, effective control in the process. Without proper training this control may not be as effective. Recommendation: 13. Provide training on P-Card policies and procedures to all supervisors who approve P-card transactions. -I an �a a. The City of Denton Procurement Card Audit Report June 2019 City management response: Staff is in process of revising the P-Card Manual and will be addressing supervisory training upon completion of the manual.The P-Card Manual is expected to be complete when the audit is finalized. All supervisors responsible for P-card approvals were notified of their responsibilities via email on October 11, 2018. New p- card holders and their supervisors are required to complete training before p-cards are issued. Opportunity for Saving Travel and other Costs During the audit period of July 1, 2017 through July 31, 2018, the City paid $411,957 for travel costs. This amount mostly consists of airline and hotel costs. The City employees generally pay commercially available prices for airline tickets. For hotels, either commercially available room costs or negotiated rates for conference are paid. What we found? The State of Texas (State) has a travel management program which is available for counties and municipalities in Texas.This program at the State Comptroller's office ensures that taxpayer dollars are used more efficiently by providing discounted travel services through vendor contracts and monitoring state travel activity. They have negotiated the following travel contracts that the City may be able to use: • Airline • State Travel Card • Hotels • Rental Car Airline Costs: The State has contracts with American and Jet Blue airlines. Using information available on the State website, it appears that the rates available underthis contract are cheaper than commercial rates. During the audit period,the City paid $144,795 for air travel. This would mean that during this period, if the City was using the State's program, it would have recognized savings. Travel Card rebates: 00 The State has a contract with City Bank for travel cards that can also be used as P-Cards. The State's negotiated rebate and early payment incentive is 2.005% compared to the City's negotiated rate of a. The City of Denton Procurement Card Audit Report June 2019 1.6625%. At the volume noted during the audit period, the City would have received a larger amount in rebates and early payment incentives compared to the City's current rebates and incentives program. Hotel Costs: The State Program uses an organization called Hotel Engine. The State website indicated that the program guarantees booking hotels at or below GSA rates. The City incurred $256,000 during the audit period. The Hotel Engine representative could not provide an estimate of savings as the program is new and does not have adequate history. However, the representative was confident that substantial savings could be generated. Using this program would add to the previously quantified savings. We selected a sample of 30 hotel payments incurred by the City employees and compared them with the corresponding GSA rates and found GSA rate to be 25.40% less expensive. This means that based on current spending, the City could have some savings. Why does it matter? The City has opportunity to save travel costs using the State travel management program. Recommendation: 14. The Procurement and Compliance Office needs to evaluate feasibility of participating in the State's travel Management Program. If found beneficial, consider participating in the program. City management response: The Director of Procurement and Compliance will work with the Finance Department to research the options available to the City through the State's travel management program. -I an �a a. The City of Denton Procurement Card Audit Report June 2019 Appendix I Non-compliance with Inviting Sealed Bidding Requirements: Vendor Purchases Amazon Marketplace $240,841 SAMS CLUB and Walmart $95,389 Dealers Electrical $82,984 Lowes $82,892 The Home Depot $60,552 Denton Tools& Fastener $56,579 Red Wing Shoe $54,431 Total $673,668 O N a The City of Denton Procurement Card Audit Report June 2019 Appendix II The following summarizes the recommendations issued throughout this report.The auditors found that staff and the Division was receptive and willing to make improvements to controls where needed. Management has provided their response to each recommendation. The Purchasing Division needs to satisfy its 1 responsibility of monitoring purchases made by Concur Expected Completion: using P-Cards and enforcing compliance with State In progress; Ongoing procurement statutes. Comments: Improved monitoring effective 10/2018; updating monitoring processes in accordance with audit. Educate the department personnel responsible for 2 verifying P-Card transactions regarding their duty Concur Expected Completion: for and information to verify compliance with In progress; Ongoing procurement regulations. Comments:Training materials revised 10/2018 for new cardholders and approvers; will update in accordance with audit;Additional training will be completed as new P-Card system is implemented—Q4 FY 18/19. The Purchasing Division needs to work with departments for the monitoring of purchases made Expected Completion: 3 on P-Cards and attempt to identify consolidation Concur opportunities to obtain lower prices through In progress; Ongoing contracting or receiving discounts. Comments: Improved monitoring and training material updates effective 10/2018; updating monitoring processes in accordance with audit; A new P-Card system will be implemented and additional training completed—Q4 FY 18/19. Educate the department personnel responsible for 4 verifying P-Card transactions regarding their duty Concur Expected Completion: for and information to verify compliance with Effective 10/2018; Ongoing procurement regulations. Comments:Training materials revised 10/2018 for new cardholders and approvers; Additional training will be completed as new P-Card system is implemented—Q4 FY 18/19. Eliminate sparingly used cards and use other cards Expected Completion: 5 available to the respective Departments for making Concur Already in progress; Ongoing necessary purchases. Comments: In progress prior to audit; will continue to review utilization and work with departments regularly 6 Look for additional opportunity for consolidation of Concur Expected Completion: cards to facilitate better administration of P-Cards. Already in progress; Ongoing Comments: In progress prior to audit; will continue to review utilization and work with departments regularly Suspend P-Cards for which transactions are not Expected Completion: 7 approved by the supervisors after giving adequate Concur Complete warning. N a The City of Denton Procurement Card Audit Report June 2019 Comments: Compliance Officer has the authority to suspend cards effective 10/2018; monitors approvals monthly and communicates with approvers accordingly 8 Require employees to upload their receipts in l P Concur Expected Completion: Morgan system. Complete Comments: Documentation required in JPMorgan effective 10/2018 The Compliance Officer needs to establish a process 9 for monitoring compliance and enforce the City's Concur Expected Completion: Effective 10/2018; Ongoing policy for non-compliance with P-Card procedures. Comments: Compliance Officer has the authority to suspend cards effective 10/2018; monitors transactions and approvals monthly; communicates with cardholders and approvers accordingly The P-Card policies and procedures need to be Expected Completion: 10 updated prohibiting assigning cards to individuals Concur Complete responsible for administering the program. _ Comments: Program administrators no longer have P-Cards Periodically, the Compliance Officer needs to review Expected Completion: 11 active cards to determine appropriateness and Concur Effective 10/2018; Ongoing business needs for the charge card accounts. Comments: In progress prior to audit; will continue to review utilization and work with departments regularly 12 Notify results of audits to the Compliance Officer. Concur Expected Completion: Effective 10/2018; Ongoing Comments:As of 10/2018,the Compliance Officer completes the audits; Results provided to Director. 13 Provide training on P-Card policies and procedures Concur Expected Completion: to all supervisors who approve P-card transactions. Effective 10/2018; Ongoing Comments:All new approvers trained effective 10/2018; Additional supervisory training will be completed as new P-Card system is implemented—Q4 FY 18/19. The Procurement and Compliance Office needs to Partially 14 evaluate feasibility of participating in the State's Expected Completion: travel Management Program. Concur Comments: Opportunities to save on travel expenses will be researched;the state program is likely not a viable option N N a