BKD Recommendations

The BKD Report about COMBAT finances listed among its primary findings "a pattern of COMBAT funds being spent without the approval or knowledge of COMBAT management," chronic underbudgeting of Anti-Crime Tax revenues by the Jackson County Finance Department, and a lack of formal agreements regarding how county departments use COMBAT funds. The report, released Sept. 18, 2019, features 37 recommendations to address these and other issues. 

While the recommendations are scattered throughout the 41-page report, we have summarized each on this page and attempted to group them in categories to provide greater clarity. (To read each recommendation in its entirety, click on the FULL RECOMMENDATION tabs.)

This page will be continually updated as COMBAT and the Prosecutor's Office follow up on each of the recommendations made.

LAST UPDATE: THURSDAY, JANUARY 16, 2020

COMBAT & OTHER 
COUNTY DEPARTMENTS
Sales Tax Revenue Projections & Budgeting
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Recommendation Summaries:

  1. Rather than the County Finance Department continuing to estimate annual revenue figures for the quarter-cent Anti-Crime sales tax, BKD recommends COMBAT management assume performing this task.

  2. Any Anti-Crime Fund balance from the prior year (e.g. 2019) should be budgeted in its entirety—100%—for the following year (e.g. 2020) to go toward COMBAT-supported agencies.
COMBAT Operations & Procedures
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Recommendation Summaries:

  1. COMBAT's accounting practices and office procedures should be "redesigned" and finalized, with an emphasis on updating these procedures and practices and determining which ones should be established as official policy.

  2. Chapter 93 of the Jackson County Code places responsibilities for the "day-to-day supervision" of COMBAT under the Prosecuting Attorney. BKD, however, stressed that currently COMBAT lacks "sufficient support to oversee all of the COMBAT tax funds." Therefore, the firm emphasized the need for the COMBAT Director and Prosecutor to be fully informed about how Anti-Crime Tax fund dollars are being use and about the successes of the various programs COMBAT funds.

  3. BKD recommends that Jackson County "consider whether it makes sense for COMBAT" to be set up similarly to the Jackson County Children's Services Fund (CSF). The CSF is funded by an eighth-cent sales tax, but operates very much like a non-profit, responsible for handling all its own financial matters under the direct supervision of its own board.

  4. Agencies requesting COMBAT funding should be required to apply for an approved agency list. They would have to provide documentation to assure they meet the county's guidelines for being eligible to acquire grant funding.

  5. ◦COMBAT administrative costs should be accounted for prior to other fund dollars being appropriated.

    ◦COMBAT should have "insight" into how other county department's use Anti-Crime Tax dollars.

    ◦The Prosecuting Attorney should be able to relying on "internal resources to validate that funds are being appropriated as designed."
COMBAT Funding Formula
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Recommendation Summaries

  1. BKD noted that with anti-violence being added to COMBAT's mission in 2014, this formula should be revised to include anti-violence programs and be re-submitted to the County Legislature for approval.

  2. The funding formula should be review regulalry to assure funds are allocated in a way that meets what could be the county's shifting needs.
Other Departments' Use Of Anti-Crime Funds
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Recommendation Summaries:

  1. There should be a Memorandum of Understanding (MOU) between COMBAT and each Jackson County Department that receives Anti-Crime tax funding. The MOU should state how department's use of these funding fits within COMBAT's purpose and mission. It should also establish a list of eligible expenses, require the department to provide COMBAT quarterly reports and prohibit allotting additional funds to a department with COMBAT management's prior approval.

  2. BKD recommends each county department receiving Anti-Crime funding give both COMBAT management and the COMBAT Commission annual presentations to demonstrate, in detail, how the department has utilized the funding.

  3. The County Finance Department needs to create reports that would all COMBAT management to closely monitor the use of non-departmental funds on a monthly basis.

  4. COMBAT should establish and enforce an approval process for County Departments requesting to "borrow" Anti-Crime funds.

  5. COMBAT should establish procedures to analyze the spending of Anti-Crime fund dollars and other transactions related to the fund, including overspending by County Departments.

  6. COMBAT should monitor how County Department's use COMBAT funds, with an emphasis on if/when these department exceed what has been budgeted for them.
Employee Salaries & Benefits
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Recommendation Summaries:

  1. The County Finance Department should receive written approval from COMBAT before any county employee is paid partially or in full with COMBAT funds.
  2. Finance should provide a quarterly payroll report listing employees whose salaries are paid, in part or full, with Anti-Crime funds.

  3. COMBAT should do its own "proactive analysis" of all employees being paid with Anti-Crime funds to determine if their jobs do, indeed, "promote the mission of COMBAT" or that the departments in which they work are supposed to receive COMBAT funds.

  4. COMBAT should implement guidelines regarding who has the authority to approve/sign Employment Change Authorization (ECA) and Personnel Requisition forms that would transfer employees' salaries/benefits to COMBAT.
Capital Improvements & 'Emergencies'
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Recommendation Summaries:

  1.  Although BKD noted "the County Executive is concerned with [the] need for emergency funds or reserves," the firm cited "little need for a reserve operation fund." Instead, BKD recommends funds be "maximized...in direct support" of COMBAT's mission.

  2. When a county department wants to pay for a capital improvement projects with Anti-Crime funds—beyond what was allotted for the department's use—COMBAT management should approve use of the funds for the project BEFOREHAND.

  3. BKD recommends that before any county department uses COMBAT non-departmental funds for "any purpose" the Finance Department should require a contract or other documentation reflecting COMBAT's prior approval for using those funds.

COMBAT-FUNDED AGENCIES
 Program Monitoring & Evaluation
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Recommendation Summaries:

  1. BKD stressed that COMBAT was "already working" to hire program monitors to begin conducting site visits with all agencies seeking COMBAT funding.

  2. Site-visit evaluations should be based on a formal criteria to assure agencies can comply with COMBAT's objectives.

  3. Site visit reports should be formally documented and included in the applications agencies submit for COMBAT funding. This documentation should include a formal funding recommendation by COMBAT staff based on the on-site visit.

  4. More resources need to be provided to assure site visits are being made to all COMBAT-funded agencies through the year.

  5. Specific criteria should be established for evaluating treatment and prevention programs, so that program providers can understand how they are being evaluated. The FULL RECOMMENDATION includes "suggested criteria COMBAT should consider."

  6. Recovery houses and treatment providers offering similar services should be required in their contracts to meet certain safety requirements for their clients and for the community. Furthermore, COMBAT staff should be able to, if concerned about safety, obtain "police escort to visit facilities."

  7. Use "specific data measures" when evaluating programs for funding renewals or when considering a new application for funding.

  8. COMBAT should clearly define what are "acceptable costs" for which funded agencies can expect reimbursement.

  9. COMBAT should consider capping the amount of "administrative" costs for which a grant recipient can be reimbursed.
Expense Reports
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Recommendation Summaries:

  1. Full documentation should be obtained and reviewed prior to paying expenses submitted to COMBAT.
  2. COMBAT should "redefine" what "approval" means with regard to monthly expense reports, nothing that expenses should be "proper [and] in accordance with the contract." Furthermore, expenses should fall within the amount of funding available in the contract with the agency.

  3. COMBAT should implement a formal process for receiving, reviewing and approving expenses reports.

  4. A current monthly expense report should not be paid if reports from previous months have not yet be submitted for review.

  5. Each contract with an outside agency should include documenting what are allowable expenses that can be submitted for reimbursement.

  6. When multiple funds are being used to pay expenses, the funds used should be documented.

COMBAT & OTHER COUNTY DEPARTMENTS
Sales Tax Revenue Projections & Budgeting
BKD recommends that COMBAT begin estimating/monitoring sales tax revenue figures directly, rather than being entirely dependent on the County Finance Department to provide data. Furthermore, the firm recommends 100% of fund balances be allocated for COMBAT-supported programs.
IMMEDIATE FOLLOW-UP
  • These recommendations are in line with needed changes the Jackson County Prosecutor's Office and COMBAT administrators had already identified prior to the release of the Sept. 18,2019 releases of the BKD Report
  • Among the steps being taken to implement the following recommendations is the creation of a new COMBAT Budget Coordinator, who will work independently of the County Finance Department and report directly to COMBAT's Director and Deputy Director.
  • The Budget Coordinator's responsibilities will entail acting upon these recommendations.
  • Sept. 24, 2019: The Jackson County Legislature unanimously approved creating the position.
UPDATES
  • Dec. 17, 2019: Keron Hopkins is now COMBAT's Budget Coordinator.
  • Jan. 16, 2020: In making its 2020 funding recommendations to the COMBAT Commission today, the COMBAT staff recommend using the fund balance to allocate more funding to agencies in 2020.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION

Rather than the County Finance Department continuing to estimate annual revenue figures for the quarter-cent Anti-Crime sales tax, BKD recommends COMBAT management assume performing this task. 

UPDATES

Sept. 24, 2019: For the Budget Coordinator to accurately estimate annual revenue figures for the quarter-cent sales tax, COMBAT management believes he/she must be given full and unfettered access to the sales tax reports the Missouri Department of Revenue provides Jackson County.

  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION

Any Anti-Crime Fund balance from the prior year (e.g. 2019) should be budgeted in its entirety—100%—for the following year (e.g. 2020) to go toward COMBAT-supported agencies.

UPDATES

Jan. 16, 2020: In making its 2020 funding recommendations to the COMBAT Commission today, the COMBAT staff recommend using the fund balance to allocate more funding to agencies in 2020.

COMBAT Operations & Procedures
These recommendations cover a wide array of issues, from accounting practices to the suggestion COMBAT "formally separate financial operations from the county."
IMMEDIATE FOLLOW-UP
  • While the scope of these recommendations go beyond what this individual will do, a new COMBAT Budget Coordinator, who will work independently of the County Finance Department and report directly to COMBAT's Director and Deputy Director, will assure that COMBAT management and the Prosecuting Attorney are fully informed about how Anti-Crime funds are being used.
  • The Budget Coordinator's responsibilities will also include establishing and enforcing financial procedures and policies.
  • Sept. 24, 2019: The Jackson County Legislature unanimously approved creating the position.

UPDATES


  • Dec. 17, 2019 Update: Keron Hopkins is now COMBAT's Budget Coordinator.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT's accounting practices and office procedures should be "redesigned" and finalized, with an emphasis on updating these procedures and practices and determining which ones should be established as official policy. 
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Chapter 93 of the Jackson County Code places responsibilities for the "day-to-day supervision" of COMBAT under the Prosecuting Attorney. BKD, however, stressed that currently COMBAT lacks "sufficient support to oversee all of the COMBAT tax funds." Therefore, the firm emphasized the need for the COMBAT Director and Prosecutor to be fully informed about how Anti-Crime Tax fund dollars are being used and about the successes of the various programs COMBAT funds. 
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
BKD recommends that Jackson County "consider whether it makes sense for COMBAT" to be set up similarly to the Jackson County Children's Services Fund (CSF). The CSF is funded by an eighth-cent sales tax, but operates very much like a non-profit, responsible for handling all its own financial matters under the direct supervision of its own board.

UPDATES



Sept. 24, 2019: Such a major restructuring of the COMBAT program would likely require changes to the Jackson County Charter. County voters approved a ballot measure in 2018 placing COMBAT under the day-to-day supervision of the Prosecuting Attorney.

Jan. 15, 2020: There are no plans at this time to implement the type of sweeping changes BKD suggests be "consider[ed]" here.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Agencies requesting COMBAT funding should be required to apply for an approved agency list. They would have to provide documentation to assure they meet the county's guidelines for being eligible to acquire grant funding.

UPDATES



Sept. 24, 2019: 
COMBAT has stressed to all agencies applying for 2020 funding that applications from non-compliant agencies will be automatically rejected.

Jan. 16, 2020: Funding applications from agencies unable to meet compliance guidelines were automatically rejected and not passed along for the COMBAT Commission's recommendation during today's meeting of the Commissioners.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
This is a difficult recommendation to summarize in a few words, but this is an attempt to sum up the FULL RECOMMENDATION in three bullet points:

• COMBAT administrative costs should be accounted for prior to other fund dollars being appropriated.

• COMBAT should have "insight" into how other county department's use Anti-Crime Tax dollars.

• The Prosecuting Attorney should be able to relying on "internal resources to validate that funds are being appropriated as designed."



COMBAT Funding Formula
The COMBAT funding formula was last approved in 1995 and needs to be updated.
IMMEDIATE FOLLOW-UP
  • These recommendations are in line with needed changes the Jackson County Prosecutor's Office and COMBAT administrators had already identified prior to the release of the Sept. 18,2019 releases of the BKD Report
  • Among the steps being taken to implement the following recommendations is the creation of a new COMBAT Budget Coordinator, who will work independently of the County Finance Department and report directly to COMBAT's Director and Deputy Director.
  • The Budget Coordinator's responsibilities will include working with COMBAT manage to revision the funding formula.
  • Sept. 24, 2019: The Jackson County Legislature unanimously approved creating the position.

UPDATES


  • Dec. 17, 2019 Update: Keron Hopkins is now COMBAT's Budget Coordinator. 
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
The COMBAT funding formula was last updated in 1995:

COMBAT Funding Pie Chart
BKD noted that with anti-violence being added to COMBAT's mission in 2009, this formula should be revised to include anti-violence programs and be re-submitted to the County Legislature for approval.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
The funding formula should be review regularly to assure funds are allocated in a way that meets what could be the county's shifting needs.

Other County Departments' Use Of Anti-Crime Funds
BKD has made these recommendations that COMBAT be given access to all necessary data to directly monitor and approve the use of COMBAT funds by other Jackson County departments.
IMMEDIATE FOLLOW-UP
  • These recommendations are in line with needed changes the Jackson County Prosecutor's Office and COMBAT administrators had already identified prior to the release of the Sept. 18,2019 releases of the BKD Report
  • Among the steps being taken to implement the following recommendations is the creation of a new COMBAT Budget Coordinator, who will work independently of the County Finance Department and report directly to COMBAT's Director and Deputy Director.
  • The Budget Coordinator's responsibilities will entail acting upon these recommendations.
  • Sept. 24, 2019: The Jackson County Legislature unanimously approved creating the position.

UPDATES


  • Dec. 17, 2019 Update: Keron Hopkins is now COMBAT's Budget Coordinator.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
There should be a Memorandum of Understanding (MOU) between COMBAT and each Jackson County Department that receives Anti-Crime tax funding. The MOU should state how the department's use of this funding fits within COMBAT's purpose and mission. It should also establish a list of eligible expenses, require the department to provide COMBAT quarterly reports and prohibit allotting additional funds to a department without COMBAT management's prior approval.

UPDATES

Sept. 24, 2019: The creation of these MOU's would require input from the County Counselor's Office and possibly also the County Legislature. Also, the BKD report calls for the departments to provide quarterly reports to COMBAT, when more frequent reports would be preferred.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
BKD recommends each county department receiving Anti-Crime funding give both COMBAT management and the COMBAT Commission annual presentations to demonstrate, in detail, how the department has utilized the funding.

UPDATES



Sept. 24, 2019: While the FULL RECOMMENDATION notes each department could "use their discretion on the format of the presentation," COMBAT management would prefer providing a template for the departments to assure uniformity in these presentations.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
The County Finance Department needs to create reports that would allow COMBAT management to closely monitor the use of non-departmental funds on a monthly basis.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT should establish and enforce an approval process for County Departments requesting to "borrow" Anti-Crime funds.

UPDATES



Sept. 24, 2019: This recommendation also includes the word "appropriateness," suggesting whether or not it is ever appropriate for departments to "borrow" funds not originally allotted to them during the normal budgetary process. The COMBAT administration and Prosecuting Attorney's Office will consult with the new Budget Coordinator to establish rigid, transparent guidelines to restrict any "borrowing" of Anti-Crime funds by other Jackson County Departments.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT should establish procedures to analyze the spending of Anti-Crime fund dollars and other transactions related to the fund, including overspending by County Departments.

UPDATES

Sept. 24, 2019: The Budget Coordinator will be assigned this task to assure the accuracy of information and to assure fund dollars are being spent appropriately.

  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT should monitor how County Department's use COMBAT funds, with an emphasis on if/when these department exceed what has been budgeted for them.



Employee Salaries & Benefits
BKD has made several recommendations regarding the need for COMBAT management to be empowered to approve paying any county employees with the Anti-Crime fund, whether it be their partial salary or full. These recommendations address a basic questions: Are employees being paid with the fund actually doing work that aligns with COMBAT's mission? 
FOLLOW-UP
  • These recommendations are in line with needed changes the Jackson County Prosecutor's Office and COMBAT administrators had already identified prior to the release of the Sept. 18,2019 releases of the BKD Report
  • After the Prosecutor's Office assumed control over COMBAT in 2018, BKD observed a 45% decrease in payroll being charged to COMBAT and a 35% drop in benefits being paid with COMBAT funds.
  • Among the steps being taken to implement the following recommendations is the creation of a new COMBAT Budget Coordinator, who will work independently of the County Finance Department and report directly to COMBAT's Director and Deputy Director.
  • The Budget Coordinator's responsibilities will entail acting upon these recommendations.
  • Sept. 24, 2019: The Jackson County Legislature unanimously approved creating the position.

UPDATES


  • Dec. 17, 2019 Update: Keron Hopkins is now COMBAT's Budget Coordinator.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
The County Finance Department should receive written approval from COMBAT before any county employee is paid partially or in full with COMBAT funds.

UPDATES



Sept. 24, 2019: COMBAT will only approve those positions that support COMBAT's anti-drug, anti-crime and anti-violence mission.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Finance should provide a quarterly payroll report listing employees whose salaries are paid, in part or full, with Anti-Crime funds.

UPDATES



Sept. 24, 2019: COMBAT believes such a report should be provided monthly, rather than just quarterly.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT should do its own "proactive analysis" of all employees being paid with Anti-Crime funds to determine if their jobs do, indeed, "promote the mission of COMBAT" or that the departments in which they work are supposed to receive COMBAT funds.

UPDATES


Sept. 24, 2019: Such an analysis would necessitate the full cooperation of both the county's Finance and Human Resources Departments. 
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT should implement guidelines regarding who has the authority to approve/sign Employment Change Authorization (ECA) and Personnel Requisition forms that would transfer employees' salaries/benefits to COMBAT.

UPDATES

Sept. 24, 2019: As BKD cited in its report "there was not one set individual authorized to approve" these forms. While this may require amending Jackson County's Personnel Rules, COMBAT and the Prosecutor's Office believe the authority for signing/approving these forms should rest completely with the COMBAT Director and Prosecuting Attorney. No one in another department should have exclusive "appointing authority" regarding positions that will be funded through COMBAT.



Capital Improvements & 'Emergencies'
These recommendations relate to need to tightly control attempts to use Anti-Crime fund dollars for capital improvements and expenses that have been classified as "emergencies."
FOLLOW-UP
  • These recommendations are in line with needed changes the Jackson County Prosecutor's Office and COMBAT administrators had already identified prior to the release of the Sept. 18,2019 releases of the BKD Report
  • Among the steps being taken to implement the following recommendations is the creation of a new COMBAT Budget Coordinator, who will work independently of the County Finance Department and report directly to COMBAT's Director and Deputy Director.
  • The Budget Coordinator's responsibilities will entail acting upon these recommendations.
  • Sept. 24, 2019: The Jackson County Legislature unanimously approved creating the position.

UPDATES


  • Dec. 17, 2019 Update: Keron Hopkins is now COMBAT's Budget Coordinator.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Although BKD noted "the County Executive is concerned with [the] need for emergency funds or reserves," the firm cited "little need for a reserve operation fund." Instead, BKD recommends funds be "maximized...in direct support" of COMBAT's mission.

UPDATES



Sept. 24, 2019: In making this recommendation, BKD pointed to the use of more than $2 million in COMBAT funding to repair cell doors at the Jackson County Detention Center—without the prior knowledge of COMBAT management. Going forward, use of COMBAT funds for such purposes, without the prior approval of COMBAT management and the Prosecutor's Office, will be prohibited.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
When a county department wants to pay for a capital improvement project with Anti-Crime funds—beyond those funds allotted for the department's use—COMBAT management should approve use of the funds for the project BEFOREHAND. 

UPDATES

Sept. 24, 2019: BKD emphasized COMBAT management should only approve use of Anti-Crime funds if the department can demonstrate how the project fits within the "purpose of the Anti-Crime tax."
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
BKD recommends that before any county department uses COMBAT non-departmental funds for "any purpose" the Finance Department should require a contract or other documentation reflecting COMBAT's prior approval for using those funds.



COMBAT FUNDED-AGENCIES

Program Monitoring & Evaluation
These recommendations relate to COMBAT conducting on-site visits to agencies that already receive COMBAT funding or new agencies applying for funding.
FOLLOW-UP
  • These recommendations are in line with needed changes the Jackson County Prosecutor's Office and COMBAT administrators had already identified prior to the release of the Sept. 18,2019 releases of the BKD Report
  • Among the steps being taken to implement the following recommendations is the creation of three new COMBAT Community Engagement Program monitors.
  • These monitors will be charged conducting on-site visits, collecting and analyzing data, and writing reports.
  • BKD noted due to "limited resources" COMBAT has previously not been able to on-site visits for all agencies.

UPDATES


  • Dec. 17, 2019 Update: All three COMBAT Community Engagment Program monitors have started working and conducting on-site visits at agencies currently receiving or applying to receive COMBAT funding. 
  • Jan. 15, 2020: COMBAT Community Engagment Program monitors use a standardized form when conducting site visits. They also have the funding applications each agency submitted to assess a program's performance versus the objectives set out for the program in the application.
  • Jan. 16, 2020: Seven of these nine recommendations have been implemented.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
BKD stressed that COMBAT was "already working" to hire program monitors to begin conducting site visits with all agencies seeking COMBAT funding.

UPDATES 



Dec. 17, 2019: Three COMBAT Community Engagement Program monitors are now conducting on-site visits at agencies currently receiving or applying to receive COMBAT funding. The monitors immediately began visiting agencies that applied for 2020 funding.

Recommendation Implemented
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Site-visit evaluations should be based on formal criteria to assure agencies can comply with COMBAT's objectives.

UPDATES



Jan. 15, 2020: COMBAT Community Engagement Program monitors use a standardized form when conducting site visits. They also have the funding applications each agency submitted to assess a program's performance versus the objectives set out for the program in the application.

Recommendation Implemented
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Site visit reports should be formally documented and included in the applications agencies submit for COMBAT funding. This documentation should include a formal funding recommendation by COMBAT staff based on the on-site visit.

UPDATES



Jan. 15, 2020: Formal Site visit reports were the primary basis for determining whether staff did or did not recommend accepting an agency's application for funding in 2020.

Recommendation Implemented
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
More resources need to be provided to assure site visits are being made to all COMBAT-funded agencies through the year.


UPDATES 



Sept. 24, 2019: BKD reiterated that COMBAT did not have "sufficient staff to make site visits." With the hiring of program monitors, COMBAT will be, for the first time, having staff dedicated solely to conducting on-site visits.

Dec. 17, 2019: Three COMBAT Community Engagement Program monitors are now conducting on-site visits at agencies currently receiving or applying to receive COMBAT funding. Each agency will be visited at least once annually, though many will receive multiple visits from more than one monitor.

Recommendation Implemented
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Specific criteria should be established for evaluating treatment and prevention programs, so that program providers can understand how they are being evaluated. The FULL RECOMMENDATION includes "suggested criteria COMBAT should consider."


UPDATES



Jan. 15, 2020: COMBAT Community Engagement Program monitors use a standardized form when conducting site visits. They also have the funding applications each agency submitted to assess a program's performance versus the goals set during the application process.

Recommendation Implemented
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Recovery houses and other treatment providers offering similar services should be required in their contracts to meet certain safety requirements for their clients and for the community. Furthermore, COMBAT staff should be able to, if concerned about safety, obtain a "police escort to visit facilities."

UPDATES



Sept. 24, 2019: The 2020 COMBAT Funding Application, through which agencies can apply for funding until Oct. 31, 2019, requires agencies operating recovery houses to have these facilities staffed 24/7.

Jan. 15, 2020: Any agency unable to meet the 24/7 staffing requirement for a recovery house will not receive COMBAT funding to operate such a facility. 

Recommendation Implemented
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Use "specific data measures" when evaluating programs for funding renewals or when considering a new application for funding.

UPDATES



Jan. 15, 2020: Agencies are required to provide monthly reports to monitor each program's performance. 

Recommendation Implemented
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT should clearly define what are "acceptable costs" for which funded agencies can expect reimbursement.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT should consider capping the amount of "administrative" costs for which a grant recipient can be reimbursed.

UPDATES

Jan. 15, 2020: COMBAT currently allows 7% for "administrative" costs, which is three percentage points lower than the federal standard for agencies receiving federal grants.



Expense Report Policies
These recommendations relate to COMBAT receiving, reviewing and paying expenses reports submitted by the agencies that COMBAT funds.
IMMEDIATE FOLLOW-UP
  • These recommendations are in line with needed changes the Jackson County Prosecutor's Office and COMBAT administrators had already identified prior to the release of the Sept. 18,2019 releases of the BKD Report
  • Among the steps being taken to implement the following recommendations is the creation of a new COMBAT Budget Coordinator, who will work independently of the County Finance Department and report directly to COMBAT's Director and Deputy Director.
  • The Budget Coordinator's responsibilities will entail acting upon these recommendations.
  • Sept. 24, 2019: The Jackson County Legislature unanimously approved creating the position.

UPDATES


  • Dec. 17, 2019 Update: Keron Hopkins is now COMBAT's Budget Coordinator
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Full documentation should be obtained and reviewed prior to paying expenses submitted to COMBAT.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT should "redefine" what "approval" means with regard to monthly expense reports, nothing that expenses should be "proper [and] in accordance with the contract." Furthermore, expenses should fall within the amount of funding available in the contract with the agency.
  1. RECOMMNEDATION SUMMARY
  2. FULL RECOMMENDATION
COMBAT should implement a formal process for receiving, reviewing and approving expenses reports.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
A current monthly expense report should not be paid if reports from previous months have not yet been submitted for review.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
Each contract with an outside agency should include documenting what are allowable expenses that can be submitted for reimbursement.
  1. RECOMMENDATION SUMMARY
  2. FULL RECOMMENDATION
When multiple funds are being used to pay expenses, the funds used should be documented.