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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
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COMBAT & OTHER
COUNTY DEPARTMENTS
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| Sales Tax Revenue Projections & Budgeting |
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Recommendation Summaries:
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| COMBAT Operations & Procedures |
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| COMBAT Funding Formula |
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| Other Departments' Use Of Anti-Crime Funds |
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| Employee Salaries & Benefits |
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| Capital Improvements & 'Emergencies' |
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| COMBAT-FUNDED AGENCIES |
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| Program Monitoring & Evaluation |
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| Expense Reports |
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| Sales Tax Revenue Projections & Budgeting |
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| 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
UPDATES
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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.
Verbatim From BKD Report (PDF) • Page 8
Recommendation: We recommend that COMBAT management take over the estimation of sales tax revenue, then provide to Finance for the necessary approvals. All changes to the estimate provided by COMBAT should be approved by COMBAT management.
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.
Verbatim From BKD Report (PDF) • Page 8
Recommendation: We recommend that Finance ensure that 100% of the prior year’s fund balance be budgeted for appropriations to the entities referenced in Resolution 10950.
| COMBAT Operations & Procedures |
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| These recommendations cover a wide array of issues, from accounting practices to the suggestion COMBAT "formally separate financial operations from the county." |
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IMMEDIATE FOLLOW-UP
UPDATES
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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.
Verbatim From BKD Report (PDF) • Page 11
Recommendation: With the recent change in Director and new Assistant Director of COMBAT, now is an ideal time to redesign the accounting portion and complete remaining office procedures. During the process of updating the existing policies and procedures, we recommend that COMBAT management analyze the actual “practices” that are taking place, and determine if those practices should be policy, or if modifications should be made.
Recommendation: With the recent change in Director and new Assistant Director of COMBAT, now is an ideal time to redesign the accounting portion and complete remaining office procedures. During the process of updating the existing policies and procedures, we recommend that COMBAT management analyze the actual “practices” that are taking place, and determine if those practices should be policy, or if modifications should be made.
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.
Verbatim From BKD Report (PDF) • Page 24
Recommendation: Chapter 93 on the Anti-Crime Tax indicates that the administration of the COMBAT tax and the COMBAT Commission shall be under the day-to-day supervision of the Prosecuting Attorney. The Prosecuting Attorney is responsible for the selection of the COMBAT Director/Administrator. We noted that given the current structure of COMBAT, there is not sufficient support to oversee all of the COMBAT tax funds and the allocation of those funds. To effectively execute their responsibilities to the tax payer, the COMBAT Director and the Prosecuting Attorney should be informed as to how the funds are being used, the success of the various programs and the development of other programs.
Recommendation: Chapter 93 on the Anti-Crime Tax indicates that the administration of the COMBAT tax and the COMBAT Commission shall be under the day-to-day supervision of the Prosecuting Attorney. The Prosecuting Attorney is responsible for the selection of the COMBAT Director/Administrator. We noted that given the current structure of COMBAT, there is not sufficient support to oversee all of the COMBAT tax funds and the allocation of those funds. To effectively execute their responsibilities to the tax payer, the COMBAT Director and the Prosecuting Attorney should be informed as to how the funds are being used, the success of the various programs and the development of other programs.
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.
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.
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.
Verbatim From BKD Report (PDF) • Page 26
Recommendation: The County should consider whether it makes sense for COMBAT to formally separate financial operations from the County. Utilizing a similar process as the JCCCSF, the County could collect the tax revenue, COMBAT could collect and approve grant applications, and COMBAT would act as its own paymaster. COMBAT would have a better understanding and assurances that the tax revenue was being utilized as intended by the taxpayers, and the full amount of tax revenue would be utilized for COMBAT’s mission. COMBAT would need to evaluate the additional resources needed to be the paymaster, including accounting personnel, equipment, training and technology.
Recommendation: The County should consider whether it makes sense for COMBAT to formally separate financial operations from the County. Utilizing a similar process as the JCCCSF, the County could collect the tax revenue, COMBAT could collect and approve grant applications, and COMBAT would act as its own paymaster. COMBAT would have a better understanding and assurances that the tax revenue was being utilized as intended by the taxpayers, and the full amount of tax revenue would be utilized for COMBAT’s mission. COMBAT would need to evaluate the additional resources needed to be the paymaster, including accounting personnel, equipment, training and technology.
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.
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.
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.
Verbatim From BKD Report (PDF) • Page 26
Recommendation: If COMBAT decides to remain under Jackson County Purchasing, it is recommended that the County consider an approved agency listing. This listing would require agencies looking to receive tax funds of any kind to apply and submit required documents to be considered for the approved agency listing. The Purchasing group would perform their due diligence steps to validate that the agency meets the County’s requirements for grant funding. The agency list should be evaluated and updated on an annual basis for agency’s completing reapplication forms, submitting updated audit reports and other relevant documentation. If the agency is on the approved list, they can complete the COMBAT application form for the various programs that COMBAT is looking for fill. This will allow COMBAT to verify status of the agency on the list and effectively identify agencies that can serve community needs quickly enough to be effective to the changing community environments while still managing and mitigating the risk of taxpayer funds going to inappropriate or unauthorized agencies.
Recommendation: If COMBAT decides to remain under Jackson County Purchasing, it is recommended that the County consider an approved agency listing. This listing would require agencies looking to receive tax funds of any kind to apply and submit required documents to be considered for the approved agency listing. The Purchasing group would perform their due diligence steps to validate that the agency meets the County’s requirements for grant funding. The agency list should be evaluated and updated on an annual basis for agency’s completing reapplication forms, submitting updated audit reports and other relevant documentation. If the agency is on the approved list, they can complete the COMBAT application form for the various programs that COMBAT is looking for fill. This will allow COMBAT to verify status of the agency on the list and effectively identify agencies that can serve community needs quickly enough to be effective to the changing community environments while still managing and mitigating the risk of taxpayer funds going to inappropriate or unauthorized agencies.
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 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."
Verbatim From BKD Report (PDF) • Page 30
Recommendation: COMBAT should analyze their existing costs, take into account increases in costs related to trainings, marketing, salaries, and administrative costs and these costs should be taken off the top of the fund before they’re allocated to the various organizations/agencies. If the method identified is a percentage allocation, it should be evaluated annually to substantiate the appropriateness of the allocation. Through this analysis, COMBAT should define a clear method to provide support for administrative costs associated with the administration of the COMBAT tax. This should be allocated across all groups receiving COBMAT tax for their programs and not just the program that are currently managed as COMBAT. COMBAT should have insight into how the Anti-Crime Tax is being spent by County departments in order to be able to report compliance with Chapter 93 requirements. The Prosecuting Attorney is responsible for the overall use of the Anti-Crime Tax and should be relying on internal resources to validate that funds are being appropriated as designed. This oversite is substantiation for the fee being applied to all groups, including County departments.
Recommendation: COMBAT should analyze their existing costs, take into account increases in costs related to trainings, marketing, salaries, and administrative costs and these costs should be taken off the top of the fund before they’re allocated to the various organizations/agencies. If the method identified is a percentage allocation, it should be evaluated annually to substantiate the appropriateness of the allocation. Through this analysis, COMBAT should define a clear method to provide support for administrative costs associated with the administration of the COMBAT tax. This should be allocated across all groups receiving COBMAT tax for their programs and not just the program that are currently managed as COMBAT. COMBAT should have insight into how the Anti-Crime Tax is being spent by County departments in order to be able to report compliance with Chapter 93 requirements. The Prosecuting Attorney is responsible for the overall use of the Anti-Crime Tax and should be relying on internal resources to validate that funds are being appropriated as designed. This oversite is substantiation for the fee being applied to all groups, including County departments.
| COMBAT Funding Formula |
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| The COMBAT funding formula was last approved in 1995 and needs to be updated. |
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IMMEDIATE FOLLOW-UP
UPDATES
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The COMBAT funding formula was last updated in 1995:
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.
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.
Verbatim From BKD Report (PDF) • Page 10
Recommendation: There was a 2019 Budget Adjustment of $700,000 for anti-violence programs, moving funds from account 9999-2810 Undesignated Fund Balance to account 4402-56005 Community Crime Prevention. We agree with this movement of budgeted funds for anti-violence programs, but note that this initiative is separate from Community Crime Prevention. In order for COBMAT to continue to allocate funds specifically for anti-violence, we recommend that COMBAT formalize an anti-violence program by updating the percentages in a new funding resolution for legislative approval.
Recommendation: There was a 2019 Budget Adjustment of $700,000 for anti-violence programs, moving funds from account 9999-2810 Undesignated Fund Balance to account 4402-56005 Community Crime Prevention. We agree with this movement of budgeted funds for anti-violence programs, but note that this initiative is separate from Community Crime Prevention. In order for COBMAT to continue to allocate funds specifically for anti-violence, we recommend that COMBAT formalize an anti-violence program by updating the percentages in a new funding resolution for legislative approval.
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.
Verbatim From BKD Report (PDF) • Page 30
Recommendation: We recommend that on a regular basis the allocation be reviewed to determine whether it is appropriate, meets the County’s goals, and provides the right resource for the right members of the community with respect to the tax’s overall objective.
Recommendation: We recommend that on a regular basis the allocation be reviewed to determine whether it is appropriate, meets the County’s goals, and provides the right resource for the right members of the community with respect to the tax’s overall objective.
| Other County Departments' Use Of Anti-Crime Funds |
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| 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. |
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IMMEDIATE FOLLOW-UP
UPDATES
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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.
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.
Verbatim From BKD Report (PDF) • Page 8
Recommendation: We recommend that a Memorandum of Understanding (MOU) be put in place between COMBAT and each County department that receives a percentage of the Anti-Crime Tax. The MOU should renew upon each renewal of the Anti-Crime Tax by the voters. BKD suggests that the MOU include:
We recognize that it will take time and effort to assemble these MOUs. However, we believe the benefit of having a “meeting of the minds”, and increased confidence regarding the use of the Anti-Crime Tax funds outweighs the investment of resources to create these documents.
Recommendation: We recommend that a Memorandum of Understanding (MOU) be put in place between COMBAT and each County department that receives a percentage of the Anti-Crime Tax. The MOU should renew upon each renewal of the Anti-Crime Tax by the voters. BKD suggests that the MOU include:
- Stated purpose of the Anti-Crime Tax and COMBAT’s mission
- How the operations of the County department fit within COMBAT’s purpose and mission
- List the operating expenses that are eligible to be covered by the Anti-Crime Tax
o This should be more specific than account categories, such as “other contractual services”. For example, drug testing, (program name) expenses, parking for victims, etc.
- County department agrees to provide quarterly reports to COMBAT regarding how the funds are being spent and the resulting accomplishments made.
- County department agrees to an annual presentation to the COMBAT Commission, presenting a year in review, describing how funds were spent and the accomplishments made using the Anti-Crime Tax
- Any additional Anti-Crime Tax funds used beyond the percentage assigned, such as for capital improvements, must be approved by COMBAT management before they are committed to be used.
We recognize that it will take time and effort to assemble these MOUs. However, we believe the benefit of having a “meeting of the minds”, and increased confidence regarding the use of the Anti-Crime Tax funds outweighs the investment of resources to create these documents.
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.
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.
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.
Verbatim From BKD Report (PDF) • Page 9
Recommendation: We recommend that on a yearly basis, representatives from each of the County departments, individually, hold a one to two hour meeting with COMBAT management, followed by an abbreviated presentation to the COMBAT Commission. The County department could use their discretion on the format of the presentation, but in general, we suggest that the presentation include:
These meetings will allow COMBAT to be able to relay to stakeholders, Jackson County residents, other cities, the Legislature, and others the achievements made with the Anti-Crime Tax.
Recommendation: We recommend that on a yearly basis, representatives from each of the County departments, individually, hold a one to two hour meeting with COMBAT management, followed by an abbreviated presentation to the COMBAT Commission. The County department could use their discretion on the format of the presentation, but in general, we suggest that the presentation include:
- Overview on how the 008 funds were spent
- Programs that were funded, and related success stories
o i.e., We had xx number of participates go through our drug court program
- Operating expenses that were funded and how those operating expenses support the mission of COMBAT
o i.e., Remediated the asbestos in the SVU area in order for SVU personnel to continue their work on sexually violent crimes
- Other accomplishes and achievements made using 008 funds
These meetings will allow COMBAT to be able to relay to stakeholders, Jackson County residents, other cities, the Legislature, and others the achievements made with the Anti-Crime Tax.
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.
Verbatim From BKD Report (PDF) • Page 10
Recommendation: We recommend that COMBAT work with Finance to create a report from the FMS system that would allow COMBAT management to monitor activity within the 008 Non-Departmental line item. COBMAT should closely monitor the use of such funds on a monthly basis, and make inquiries into the use of funds as appropriate.
Recommendation: We recommend that COMBAT work with Finance to create a report from the FMS system that would allow COMBAT management to monitor activity within the 008 Non-Departmental line item. COBMAT should closely monitor the use of such funds on a monthly basis, and make inquiries into the use of funds as appropriate.
COMBAT should establish and enforce an approval process for County Departments requesting to "borrow" Anti-Crime funds.
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.
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.
Verbatim From BKD Report (PDF) • Page 15
Recommendation: We recommend that COMBAT update their policy to specifically address the appropriateness and approval process for County departments “borrowing” funds.
Recommendation: We recommend that COMBAT update their policy to specifically address the appropriateness and approval process for County departments “borrowing” funds.
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.
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.
Verbatim From BKD Report (PDF) • Page 15
Recommendation: We recommend that management consider procedures to properly analyze transactions recorded to the 008 funds in FMS, looking for spending by County departments over their allocated percentage, accuracy of vendor names, shipping information, and other important attributes.
Recommendation: We recommend that management consider procedures to properly analyze transactions recorded to the 008 funds in FMS, looking for spending by County departments over their allocated percentage, accuracy of vendor names, shipping information, and other important attributes.
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.
Verbatim From BKD Report (PDF) • Page 17
Recommendation: We recommend that COMBAT monitor the use of COMBAT funds by County departments to identify if/when the County departments exceed their allocation. If that situation arises, COMBAT should work with Finance and the Budget Office to identify and suggest reclassifications for the use of 008 funds.
Recommendation: We recommend that COMBAT monitor the use of COMBAT funds by County departments to identify if/when the County departments exceed their allocation. If that situation arises, COMBAT should work with Finance and the Budget Office to identify and suggest reclassifications for the use of 008 funds.
| Employee Salaries & Benefits |
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| 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? |
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FOLLOW-UP
UPDATES
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The County Finance Department should receive written approval from COMBAT before any county employee is paid partially or in full with COMBAT funds.
Sept. 24, 2019: COMBAT will only approve those positions that support COMBAT's anti-drug, anti-crime and anti-violence mission.
UPDATES
Sept. 24, 2019: COMBAT will only approve those positions that support COMBAT's anti-drug, anti-crime and anti-violence mission.
Verbatim From BKD Report (PDF) • Page 21
Recommendation: We recommend that Finance receive written approval from COMBAT management for all employees who will be paid, fully or partially, from 008 funds before modifying the payroll system for change.
Recommendation: We recommend that Finance receive written approval from COMBAT management for all employees who will be paid, fully or partially, from 008 funds before modifying the payroll system for change.
Finance should provide a quarterly payroll report listing employees whose salaries are paid, in part or full, with Anti-Crime funds.
Sept. 24, 2019: COMBAT believes such a report should be provided monthly, rather than just quarterly.
UPDATES
Sept. 24, 2019: COMBAT believes such a report should be provided monthly, rather than just quarterly.
Verbatim From BKD Report (PDF) • Page 21
Recommendation: We recommend that Finance provide COMBAT with a summary payroll report on a quarterly basis which lists the employee name, title, department and the allocation percentage of 008 funds that has been assigned.
Recommendation: We recommend that Finance provide COMBAT with a summary payroll report on a quarterly basis which lists the employee name, title, department and the allocation percentage of 008 funds that has been assigned.
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.
UPDATES
Sept. 24, 2019: Such an analysis would necessitate the full cooperation of both the county's Finance and Human Resources Departments.
Verbatim From BKD Report (PDF) • Page 21
Recommendation: We recommend that COMBAT management perform a proactive analysis of the payroll, now and on a periodic basis (i.e. twice a year), for all individuals being paid from 008 funds to determine if there are any individuals being paid who have a job title that does not promote the mission of COMBAT or the purpose of the Anti-Crime Tax and/or works for a department that does not receive and allocation of COMBAT’s funds.
Recommendation: We recommend that COMBAT management perform a proactive analysis of the payroll, now and on a periodic basis (i.e. twice a year), for all individuals being paid from 008 funds to determine if there are any individuals being paid who have a job title that does not promote the mission of COMBAT or the purpose of the Anti-Crime Tax and/or works for a department that does not receive and allocation of COMBAT’s funds.
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.
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.
Verbatim From BKD Report (PDF) • Page 21
Recommendation: We recommend that COMBAT management consider implementing guidelines as to who should be approving the ECA and Personnel Requisition forms for 008 funds. COMBAT should have knowledge for which individuals have wages allocated to 008 funds.
Recommendation: We recommend that COMBAT management consider implementing guidelines as to who should be approving the ECA and Personnel Requisition forms for 008 funds. COMBAT should have knowledge for which individuals have wages allocated to 008 funds.
| Capital Improvements & 'Emergencies' |
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| 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." |
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FOLLOW-UP
UPDATES
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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.
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.
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.
Verbatim From BKD Report (PDF) • Page 10
Recommendation: We understand the County Executive is concerned with need for emergency funds or reserves. However, we recommend that COMBAT minimize the amount left in Non-Departmental line item. As identified with the Correction’s use of 008 funds for cell doors, when funds are needed for emergency, the County is able to identify and use funds from other departments. Therefore, we see little need for a reserve operation fund; rather, COMBAT should maximize program funds in direct support of its mission.
Recommendation: We understand the County Executive is concerned with need for emergency funds or reserves. However, we recommend that COMBAT minimize the amount left in Non-Departmental line item. As identified with the Correction’s use of 008 funds for cell doors, when funds are needed for emergency, the County is able to identify and use funds from other departments. Therefore, we see little need for a reserve operation fund; rather, COMBAT should maximize program funds in direct support of its mission.
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."
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."
Verbatim From BKD Report (PDF) • Page 10
Recommendation: When capital improvement projects require Anti-Crime Tax funds beyond a County department’s yearly allocation, approval should be received from COMBAT management before 008 funds are committed. We recommend County departments obtain written approval from COMBAT before the contract is signed or the project receives approval by the legislature. This will allow COMBAT management to discuss the status of their current budget, discuss the applicability of the proposed use to the purpose of the Anti-Crime Tax, and be able to make internal adjustments to programs as needed. As suggested in Observation 2, this policy should be included in the MOU.
Recommendation: When capital improvement projects require Anti-Crime Tax funds beyond a County department’s yearly allocation, approval should be received from COMBAT management before 008 funds are committed. We recommend County departments obtain written approval from COMBAT before the contract is signed or the project receives approval by the legislature. This will allow COMBAT management to discuss the status of their current budget, discuss the applicability of the proposed use to the purpose of the Anti-Crime Tax, and be able to make internal adjustments to programs as needed. As suggested in Observation 2, this policy should be included in the MOU.
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.
Verbatim From BKD Report (PDF) • Page 24
Recommendation: Amended in December 2018, Chapter 93 Section 04 relating to the Anti-Crime Sales tax states that capital improvements type expenses cannot be expended outside of funds specifically authorized in the County’s annual budget. However, given the historical use of specifically Non-Departmental funds without COMBAT knowledge, we recommend that before Non-Departmental funds are spent for any purpose, Finance should require a memorandum, contract, or document some type of approval linkage to the intent of the Anti-Crime Tax, with the documented approval from COMBAT for the use of those funds.
Recommendation: Amended in December 2018, Chapter 93 Section 04 relating to the Anti-Crime Sales tax states that capital improvements type expenses cannot be expended outside of funds specifically authorized in the County’s annual budget. However, given the historical use of specifically Non-Departmental funds without COMBAT knowledge, we recommend that before Non-Departmental funds are spent for any purpose, Finance should require a memorandum, contract, or document some type of approval linkage to the intent of the Anti-Crime Tax, with the documented approval from COMBAT for the use of those funds.
| COMBAT FUNDED-AGENCIES |
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| Program Monitoring & Evaluation |
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| These recommendations relate to COMBAT conducting on-site visits to agencies that already receive COMBAT funding or new agencies applying for funding. |
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FOLLOW-UP
UPDATES
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BKD stressed that COMBAT was "already working" to hire program monitors to begin conducting site visits with all agencies seeking COMBAT funding.
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
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
Verbatim From BKD Report (PDF) • Page 26
Recommendation: Internally within COMBAT, site visits should be scheduled for all new agencies that COMBAT has not previously reviewed, and are not already part of the normal site visit rotation, for evaluation before approval for funding. This will require the additional resources that COMBAT is already working on hiring to assist the Program Manager in the evaluation process.
Recommendation: Internally within COMBAT, site visits should be scheduled for all new agencies that COMBAT has not previously reviewed, and are not already part of the normal site visit rotation, for evaluation before approval for funding. This will require the additional resources that COMBAT is already working on hiring to assist the Program Manager in the evaluation process.
Site-visit evaluations should be based on formal criteria to assure agencies can comply with COMBAT's objectives.
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
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
Verbatim From BKD Report (PDF) • Page 27
Recommendation: Site visits for applying agencies/programs should be evaluated based on formal criteria to ensure they will meet COMBAT objectives. This includes the existing criteria, including location, facility appearance, program participation, etc. The criteria should be set so evaluations can be made consistently across these agencies to give the reviewers a sufficient sense of how these agencies should place in their evaluation. For example, if there is an applying agency locate outside the community it would be serving, this should be taken into account when comparing an application for an agency within close proximity and easily accessible to the community it will serve.
Recommendation: Site visits for applying agencies/programs should be evaluated based on formal criteria to ensure they will meet COMBAT objectives. This includes the existing criteria, including location, facility appearance, program participation, etc. The criteria should be set so evaluations can be made consistently across these agencies to give the reviewers a sufficient sense of how these agencies should place in their evaluation. For example, if there is an applying agency locate outside the community it would be serving, this should be taken into account when comparing an application for an agency within close proximity and easily accessible to the community it will serve.
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.
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
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
Verbatim From BKD Report (PDF) • Page 27
Recommendation: The site visits of applying agencies/programs should be formally documented and a formal recommendation regarding funding should be made by COMBAT personnel. The memo should be incorporated into the application process and be part of the criteria that the evaluators incorporate into their scores. If the site visit results do not support funding, funding should only be approved following documentation of the reasons to override the site visit evaluation and should require the written approval of the COMBAT Director.
Recommendation: The site visits of applying agencies/programs should be formally documented and a formal recommendation regarding funding should be made by COMBAT personnel. The memo should be incorporated into the application process and be part of the criteria that the evaluators incorporate into their scores. If the site visit results do not support funding, funding should only be approved following documentation of the reasons to override the site visit evaluation and should require the written approval of the COMBAT Director.
More resources need to be provided to assure site visits are being made to all COMBAT-funded agencies through the year.
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
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
Verbatim From BKD Report (PDF) • Page 27
Recommendation: Currently, COBMAT does not have sufficient staff to make site visits to all agencies throughout the year, the site visits really only take place for agencies that are showing red flags indicating that they may not be providing the services/programs they applied for, which includes not turning in timely reports and having low participation. In addition to the monthly reporting, we affirm and recommend additional resources be brought in to complete site visits to be able to evaluate the programs in person.
Recommendation: Currently, COBMAT does not have sufficient staff to make site visits to all agencies throughout the year, the site visits really only take place for agencies that are showing red flags indicating that they may not be providing the services/programs they applied for, which includes not turning in timely reports and having low participation. In addition to the monthly reporting, we affirm and recommend additional resources be brought in to complete site visits to be able to evaluate the programs in person.
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."
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
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
Verbatim From BKD Report (PDF) • Page 27
Recommendation: For site visits, there should be documented criteria for both treatment and prevention programs. By using set criteria, agencies can understand how they are being evaluated. Also, COMBAT can understand how the programs measure up against each other and communities may see enhanced programs. Some suggested criteria COMBAT should consider, noting that not all of this criteria will be applicable for all program types, based on criteria obtained in other similar program evaluations across the country would include:
Recommendation: For site visits, there should be documented criteria for both treatment and prevention programs. By using set criteria, agencies can understand how they are being evaluated. Also, COMBAT can understand how the programs measure up against each other and communities may see enhanced programs. Some suggested criteria COMBAT should consider, noting that not all of this criteria will be applicable for all program types, based on criteria obtained in other similar program evaluations across the country would include:
• Treatment Programs (general)
o Immediate and long term safety of clients, agency resources, and the local community
o Sign of unhealthy/inappropriate content (i.e. beer cans, needles near recovery houses)
o The sufficiency of counseling programs being offered
o How the agency evaluates patient awareness (surveys, etc.)
o Peer support
• Treatment Programs (Recovery Houses specifically – from Substance Abuse and Mental Health Services Administration)
o The sufficiency of counseling
o Peer support
o Availability of health and wellness programs
o Availability of legal assistance
o Availability of job and job readiness programs
o Availability of education and vocational skills
o Availability of life and recovery skills
o Sign of unhealthy/inappropriate content (i.e. beer cans, needles near recovery houses)
o How the agency measures sense of belonging and purpose
o How the agency evaluates patient readiness and comfort with current place (surveys, etc.)
o Does the agency have appropriate emergency procedures established?
o Does the program invest in training and technical assistance opportunities for recovery housing operators and staff?
o Is the agency accredited and carry the appropriate certifications?
• Prevention Programs
o Trained and qualified prevention workforce that is adequately staffed
o Internal and External policies and procedures for programs and operations
o Community outreach
o Programs at appropriate age levels for the community
o Availability of one-to-one mentoring
o Training programs promote healthy, protective parent-child interactions
o Programs targets adolescents with a high-risk of substance abuse and dependency issues
o The program tracks outcomes and collects data to evaluate performance
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."
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
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
Verbatim From BKD Report (PDF) • Page 27
Recommendation: One of the newer treatment agency types being funded are recovery houses. Recovery houses often house recovering addicts, some with a history of violence. It is important to not only keep the individuals living in neighboring homes safe, but also keep COMBAT staff safe. It is affirmed and recommended that language be added to contracts with recovery houses and any other treatment programs that provide similar services to similar demographics regarding safety requirements and plans for facilities to implement for patients and the community. Additionally, COMBAT should create an internal policy regarding on-site visits to recovery houses. Depending on the neighborhood crime, potential issues that may be known or for ease of mind, COMBAT staff should be able to obtain a police escort to visit facilities.
Recommendation: One of the newer treatment agency types being funded are recovery houses. Recovery houses often house recovering addicts, some with a history of violence. It is important to not only keep the individuals living in neighboring homes safe, but also keep COMBAT staff safe. It is affirmed and recommended that language be added to contracts with recovery houses and any other treatment programs that provide similar services to similar demographics regarding safety requirements and plans for facilities to implement for patients and the community. Additionally, COMBAT should create an internal policy regarding on-site visits to recovery houses. Depending on the neighborhood crime, potential issues that may be known or for ease of mind, COMBAT staff should be able to obtain a police escort to visit facilities.
Use "specific data measures" when evaluating programs for funding renewals or when considering a new application for funding.
Jan. 15, 2020: Agencies are required to provide monthly reports to monitor each program's performance.
Recommendation Implemented
UPDATES
Jan. 15, 2020: Agencies are required to provide monthly reports to monitor each program's performance.
Recommendation Implemented
Verbatim From BKD Report (PDF) • Page 27
Recommendation: Expectmore.gov was developed by the U.S. Office of Management and Budget and other federal agencies. It performed a program assessment for Family Violence and Prevention Services which included specific data measures which can easily be applied for drug related programs as well. We recommended that COMBAT consider utilizing criteria when evaluating whether to renew existing funding and possibly include some of these measures in their initial application evaluations as well. The following criteria were identified as helpful performance measures:
Program Purpose and Design
Project Management
Program Results/Accountability
Recommendation: Expectmore.gov was developed by the U.S. Office of Management and Budget and other federal agencies. It performed a program assessment for Family Violence and Prevention Services which included specific data measures which can easily be applied for drug related programs as well. We recommended that COMBAT consider utilizing criteria when evaluating whether to renew existing funding and possibly include some of these measures in their initial application evaluations as well. The following criteria were identified as helpful performance measures:
Program Purpose and Design
• Is the program purpose clear
• Does the program address a specific and existing problem interest or need
• Is the program design free of major flaws that would limit the program’s effectiveness or efficiency
• Is the program effectively target, so that resources will reach intended beneficiaries and/or otherwise address the program’s purpose directly
Strategic Planning
• Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program
• Does the program have ambitious targets and timeframes for its long-term measures
• Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program’s long-term goals
• Does the program have baselines and ambitious targets for its annual measures
• Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program
• Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need
• Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program’s budget
• Has the program taken meaningful steps to correct its strategic planning deficiencies
Project Management
• Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance
• Are program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results
• Are funds obligated in a timely manner and spent for the intended purpose
• Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution
• Does the program collaborate and coordinate effectively with related programs
• Does the program use strong financial management practices
• Has the program taken meaningful steps to address its management deficiencies
• Does the program have oversight practices that provide sufficient knowledge of grantee activities
• Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner
Program Results/Accountability
• Has the program demonstrated adequate progress in achieving its long-term performance goals
• Does the program (including program partners) achieve its annual performance goals
• Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year
• Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals
• Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results
COMBAT should clearly define what are "acceptable costs" for which funded agencies can expect reimbursement.
Verbatim From BKD Report (PDF) • Page 33
Recommendation: As a best practice, indirect and direct costs that are acceptable should be clearly defined within COMBAT policies to assist in the validation that only appropriate costs are being reimbursed to programs.
Recommendation: As a best practice, indirect and direct costs that are acceptable should be clearly defined within COMBAT policies to assist in the validation that only appropriate costs are being reimbursed to programs.
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.
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.
Verbatim From BKD Report (PDF) • Page 33
Recommendation: COMBAT should consider developing an expectation as to the maximum administrative allowable for reimbursement. Research suggests between 3% and 6%, however. COMBAT needs to determine what makes the most sense for the goals of their grant recipients.
Recommendation: COMBAT should consider developing an expectation as to the maximum administrative allowable for reimbursement. Research suggests between 3% and 6%, however. COMBAT needs to determine what makes the most sense for the goals of their grant recipients.
| Expense Report Policies |
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| These recommendations relate to COMBAT receiving, reviewing and paying expenses reports submitted by the agencies that COMBAT funds. |
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IMMEDIATE FOLLOW-UP
UPDATES
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Full documentation should be obtained and reviewed prior to paying expenses submitted to COMBAT.
Verbatim From BKD Report (PDF) • Page 13
Recommendation: As required by COMBAT policy, we recommend obtaining “original invoices and other supporting detail to the request”, to sufficiently support the expenses before payment.
Recommendation: As required by COMBAT policy, we recommend obtaining “original invoices and other supporting detail to the request”, to sufficiently support the expenses before payment.
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.
Verbatim From BKD Report (PDF) • Page 18
Recommendation: We recommend that COMBAT management consider redefining what the “approval” indicates on the monthly expense report. Best practices would indicate that approval is made by the individual agreeing that the expenses are proper, in accordance with the contract, and there are enough funds left on the contract to allow for the payment.
Recommendation: We recommend that COMBAT management consider redefining what the “approval” indicates on the monthly expense report. Best practices would indicate that approval is made by the individual agreeing that the expenses are proper, in accordance with the contract, and there are enough funds left on the contract to allow for the payment.
COMBAT should implement a formal process for receiving, reviewing and approving expenses reports.
Verbatim From BKD Report (PDF) • Page 18
Recommendation: We recommend that COMBAT management consider implementing a formal process for receipt and review/approval of the monthly expense report, form 301, form 305, and receipts/invoices/payroll detail, such as a sign-off sheet that is attached to the monthly expense report once it is received and sent on for review and approval.
Recommendation: We recommend that COMBAT management consider implementing a formal process for receipt and review/approval of the monthly expense report, form 301, form 305, and receipts/invoices/payroll detail, such as a sign-off sheet that is attached to the monthly expense report once it is received and sent on for review and approval.
A current monthly expense report should not be paid if reports from previous months have not yet been submitted for review.
Verbatim From BKD Report (PDF) • Page 18
Recommendation: We recommend that COMBAT management consider implementing a policy where the current month’s expenses will not be paid until past month’s expense reports have been submitted and paid, as per the contract. This could also include a follow-up procedure with the agencies who have not submitted their expense reports.
Recommendation: We recommend that COMBAT management consider implementing a policy where the current month’s expenses will not be paid until past month’s expense reports have been submitted and paid, as per the contract. This could also include a follow-up procedure with the agencies who have not submitted their expense reports.
Each contract with an outside agency should include documenting what are allowable expenses that can be submitted for reimbursement.
Verbatim From BKD Report (PDF) • Page 19
Recommendation: We recommend that COMBAT management consider creating a document that details specific expenses that are allowable to be submitted for reimbursement for each contract, update the document for any changes that are pertinent to that contract and include the document with the contract that goes to through the Legislature for approval.
Recommendation: We recommend that COMBAT management consider creating a document that details specific expenses that are allowable to be submitted for reimbursement for each contract, update the document for any changes that are pertinent to that contract and include the document with the contract that goes to through the Legislature for approval.
When multiple funds are being used to pay expenses, the funds used should be documented.
Verbatim From BKD Report (PDF) • Page 19
Recommendation: We recommend that when multiple funds are being utilized to reimburse expenses, there be documentation to show which expenses, or portion of expenses, are being paid for each fund.
Recommendation: We recommend that when multiple funds are being utilized to reimburse expenses, there be documentation to show which expenses, or portion of expenses, are being paid for each fund.