City of Charlotte, North Carolina Charlotte Douglas International Airport Turn Over Review Table of Contents Transmittal Letter .................................................................................................................................... 1 Background ........................................................................................................................................ 2 - 5 Objectives and Approach ................................................................................................................... 6 - 8 Observation Matrix ............................................................................................................................ 9 - 33 • • • • • • Billing and Revenues, to include Rental Agreements and Contract Management Internal Controls, and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting Contract Facility Charges Airport Special Statements Reconciliation with the Comprehensive Annual Financial Report Expense Reimbursements to the City Debt Management Process Maps ................................................................................................................................. 34 - 39 McGladrey LLP 4725 Piedmont Row Drive Suite 300 Charlotte, North Carolina 28210-4280 O 704.367.6250 www.mcgladrey.com June 11, 2014 City of Charlotte, North Carolina th 600 East 4 Street Charlotte, NC 28202 Pursuant to the approved engagement letter dated September 25, 2013 with the City of Charlotte, North Carolina (the “City”), we hereby present the Turn Over Review of the Charlotte Douglas International Airport (the “Airport”), an enterprise fund of the City. Fieldwork commenced October 2013 and was completed January 2014. From the completion of the fieldwork through present, we have been working and collaborating with the Aviation Department and City Management regarding their remediation plan of the identified observations. This review targeted the following high-risk core areas identified by management: • Billing and Revenues to include Rental Agreements and Contract Management • Internal Controls, and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting • Contract Facility Charges • Special Statements Reconciliation with the Comprehensive Annual Financial Report • Expense Reimbursements to the City • Debt Management Our report is organized in the following sections: Background This provides an overview of operations and the core high-risk focus areas as identified by management for this Turn Over Review. Objectives and Approach The Turn Over Review objectives and focus are expanded upon in this section as well as a review of the various aspects of our approach. Observation Matrix This section gives a description of the observations noted during our review, recommended actions as well as management’s responses and action plans. Process Maps This section provides process maps depicting the best practice flow of the identified processes. This engagement was conducted for the limited purpose described in the Objectives section of this report and was not designed to identify fraud, including fraud involving employees, management, those charged with governance, or external entities. Given these limitations, during our engagement we did not identify any such fraud. However, such fraud may exist that has not been identified. While the Airport has been one of the nation’s fastest growing and most cost effectively operated airports for 2 decades, we noted matters, including those indicative of the operational stresses that could occur from high growth and “lean” operations and management over an extended period, which we have included in the following Observation Matrix. We would like to thank all those involved from the City and the Aviation department in assisting us with this Turn Over Review. Respectfully Submitted, McGladrey 1 Background Background Charlotte Douglas International Airport has been owned and operated by the City of Charlotte for 78 years. The Airport provides service to 142 destinations throughout the world and averages 703 daily departures. The 1.8-million square-foot terminal building contains five concourses and 95 gates. It has th th more than quadrupled in size since opening in 1982. The Airport is 8 nationwide and 25 worldwide in passengers. US Airways operates its largest hub at the Airport. The Airport is a major employment center, with nearly 20,000 workers on site. The majority (6,637) are employed by US Airways, with nearly 8,500 additional workers employed by other airlines, tenants and businesses. In addition, there are more than 300 Aviation department employees. This Turn Over Review focused on the following 6 high-risk core areas identified by Management: Billing and Revenues to include Rental Agreements and Contract Management The primary sources of revenue at the Airport are fees and charges paid by the airlines and revenues paid by concessionaires providing services to the general public. Signatory airline terminal and airfield rates and charges are governed by 25 or 30 year lease agreements and concession revenues are established by leases of varying methodologies and terms. The airlines are assessed the following categories of fees and charges: rent, airport services, maintenance and operation fees and landing fees. Airline fees and charges are established at a level to recover the related service and facilities costs. Concession revenues are generated either through fixed annual charges or on the basis of a percentage of sales generated by the tenants’ operations. The Airport distinguishes operating revenues and expenses from non-operating items. Operating revenues, (such as terminal, airfield, concessions, parking and other) and expenses generally result from providing services and producing and delivering goods in connection with the Airport’s principal ongoing operations. Non-operating revenues, such as passenger facility charge, contract facility charge and investment earnings result from non-exchange transactions or ancillary services. Airport operating revenues are derived primarily from the terminal area, concessions and parking (~84% as of June 30, 2013) and airport non-operating revenues are derived primarily from passenger facility charges (~61% as of June 30, 2013). Total revenues amounted to $234.9M and $224.2M in fiscal years 2013 and 2012, respectively. The Aviation department recently went through a system conversion to PROPworks®, in order to effectively manage their revenue contacts. PROPworks® is a comprehensive software program designed to manage the lease, property, and revenue information needed to operate complicated businesses and transportation facilities of all sizes, like the Airport. PROPworks® will allow the Aviation department to track agreements and leases, to compile information about business relationships, to bill and invoice tenants or concession operators (collectively “lessee(s)”), and to track service providers and concessionaires for compliance with agreements. Currently, the Airport is under agreement with ~200 plus active revenue generating contracts/leases. The Aviation department has one (1) employee, the Revenue Contracts Manager who is responsible for administration of the revenue contracts. 2 Background - continued Internal Controls and Project Accounting and Capital Asset Accounting to include Grant Budgeting & Accounting The Aviation department maintains a 5-year capital improvement plan covering all areas of airport infrastructure that is updated on an ongoing basis to reflect the changing physical needs of the Airport. The plan is reviewed by the engineering and planning teams, approved by Airport management, and included in the City’s overall capital plan. The Aviation Development department drives the initial capital project process, with the Aviation Finance team involved in some planning aspects, including review of assumptions and identification of funding sources. The City’s Central Finance team also consults on the completed project funding plan and pro forma funding analysis. The Aviation Development department includes three project managers, five inspectors, and trade workers. There are two external consultants under contract who work as project managers. The general arrangement is that horizontal projects are handled by the internal project managers, while vertical projects are handled by the external project managers. The project managers’ responsibilities include: review of monthly pay applications, inspection of work in progress, resolution of contractor billing issues, in-field monitoring of progress and quality, assistance with negotiations, recommendations in areas of expertise, and monitoring compliance with the critical path and other schedules. The types of contracts entered by the Aviation department include professional services and construction contracts. The contract terms vary and may include fixed rates, lump sum amount, cost plus fixed amount, and unit pricing. All pay applications are approved by the Aviation department’s Assistant Director for Development. Change orders are approved based on an established authority matrix which requires City Council approval of all change orders of $100,000 or more, and City Manager approval for change orders over $50,000. The Aviation department’s capital assets, net of accumulated depreciation, totaled approximately $1.01B as of June 30, 2012. These capital assets consist primarily of land, buildings, and runways. Recent project additions include land acquisition, runway improvements, and ticket lobby renovations. The Airport currently has several improvement projects underway, including construction of a new hourly parking deck and rental car facility. Capital assets are depreciated using the straight-line method over the below useful lives assigned based on the asset category: Category Useful life Buildings 25 years Runways 33 years Other Improvements 25 years Machinery and Equipment 4-30 years The Aviation department currently maintains a redundant capital assets system using an Access database program. Aviation department maintains that this is required because the current general ledger system (GEAC) does not provide sufficient detail for reporting. The Aviation department has planned to utilize the City’s new ERP system to avoid the need for a redundant database. The Aviation department has received grants from the Federal Aviation Administration, Transportation Security Administration, and the American Recovery and Reinvestment Act. These grants are subject to review by the grantor agencies and there are various reporting requirements and compliance aspects associated with each grant. 3 Background - continued Contract Facility Charges In May 2007, City Council adopted an ordinance imposing a CFC of $3.50 per rental car contract per transaction day for all vehicles rented at the Airport, which can be periodically adjusted. On June 2, 2011 the City raised the CFC from $3.50 to $4.00 per transaction day to fund construction, maintenance and operation of current and future car rental facilities. The Airport is in the process of constructing a consolidated rental car facility, with an estimated cost of $85 million, intended to enhance customer service, provide savings to the concessionaires and eliminate rental car concessionaire bus trips to/from the Airport terminal. In November 2011, the Airport issued bonds secured by CFC and rental car concessionaire guarantees with which to build this facility. The agreement requires that the rental car th concessionaires remit the monthly CFCs collected on or before the 10 day of the next succeeding month to U.S Bank National Association, the bond Trustee. CFC’s are applied each month in amounts and priority as defined by the automobile rental concession agreements with the concessionaires. CFC revenue amounted to $9.5M and $8.9M in fiscal years 2013 and 2012, respectively. Airport Special Statements Reconciliation with the CAFR Like all government agencies, the City is required to prepare an audited Comprehensive Annual Financial Report (CAFR) for all of its governmental and business-type activities. The CAFR is generally due within 180 days of fiscal year end. In addition to the CAFR, the City files a special set of financial statements for only the City of Charlotte Airport, and submits those annually to the Federal Aviation Authority (FAA). The special statements are prepared after the CAFR, and are based upon CAFR inputs. However, there are differences in the format the information is presented, as well as there are additional schedules included in the special statements that are not required in the CAFR. In addition to these audited financial reports, the FAA requires filing of the following forms on an annual basis: • Form 5100-126, Financial Governmental Payment Report. The FAA requires sponsors to file Form 5100-126 as the annual report on revenue paid to other units of government and on compensation the airport received for services and property provided to other units of government, including in-kind services. • Form 5100-127, Operating and Financial Summary. The FAA requires sponsors to file Form 5100-127 as the annual report of their revenues, expenses, and other financial information. These forms are to be filed within 120 days after the end of their fiscal year. For the City, whose fiscal year ends on June 30, the filing deadline is October 31 of each year. The FAA may grant an extension of 60 days after the filing date if audited financial information is not yet available by the filing due date. No extensions can be granted past June 30 of the calendar year following the sponsor’s fiscal year end. 4 Background - continued Expense Reimbursements to the City The City prepares an annual Cost Allocation Plan (CAP) in order to allocate general and administrative overhead costs to the other departments of the City. The support departments and other designated costs that are allocated include the following: • • • • • • Budget and Evaluation Shared Services City Attorney City Manager Engineering Building Maintenance Engineering CMGC • • • • • • Finance Human Resources Equipment Depreciation/Financing Facility Costs Employee Costs and Retiree Insurance Road Use Tax These costs are allocated in a two-step process, first distributing the total support costs to all departments, and then distributing the allocations from step one to the support departments to the service departments. The method used to allocate the costs and calculate the amount allocated varies for each support department, and is notated within the approved CAP. The Airport is considered a service department, and support costs are allocated to the Airport as stipulated in the CAP. The CAP for FY2013 allocated $84.7 million in costs to all City Departments. Debt Management The Airport, in conjunction with the City, issues bonds in order to fund capital expansion and improvement projects. These projects can also be partially funded by grants and other revenue sources. As of June 30, 2012, the Airport had $860.1 million in revenue bonds outstanding. There were 15 different series of bonds outstanding, several with unspent proceeds for ongoing and future projects. Debt payments each year for the Airport are approximately $59 million. There are multiple levels of debt issued, with varying interest rates and allowable uses. The City and the Airport work very closely with bond counsel and governing bodies, including the IRS, to ensure that the bond proceeds are used properly and in accordance with all governing documents and regulations. 5 Objectives and Approach Objectives and Approach Objectives The overall objective of the Turn Over Review was to gain an understanding of the processes, procedures and the control environment of high-risk core areas identified by management. We performed a high level analysis and review, and made recommendations for improvement where considered necessary. Approach Our audit approach consisted of the following phases: Understanding and Documentation of the Process This phase of our review consisted primarily of inspection and inquiry in an effort to obtain a foundational understanding of the high-risk core areas. We met with representatives from the Aviation department and the City to discuss the scope and objectives of the Turn Over Review, obtained preliminary data, and established working arrangements. We also obtained copies of reports and other documents deemed necessary. We then conducted facilitated sessions and interviews with representatives from the Aviation department and City within the high-risk core areas identified by management. We documented our understanding of the high-risk core areas in a process map/flowchart, where applicable, which was subsequently validated by the parties noted above. Process and Control Review During this phase we assessed whether the controls are properly designed and made recommendations on how to improve internal controls where deficiencies were identified. The following procedures were conducted as a part of this phase of our review: • Control design gap identification, where applicable; • Identification of opportunities for new/modified controls for process improvement and/or efficiency gains; and • Development of recommendations for additional or improved controls. Compliance and Controls Review During this phase, we performed high-level sample testing of compliance and processes. Our procedures included the following: Revenue and Billing Our review was limited to sampled terms and conditions of the selected contract, as well as the revenue terms and conditions as it applied to the invoices selected. Not all revenue aspects and terms and conditions of each selected contract were tested in this review. • We selected a sample of eight revenue contracts and two invoices from each revenue contract (one invoice from FY 2013 and one invoice from FY 2014) for testing. We developed a testing matrix based on the relevant terms and conditions of the agreements; • Reviewed lessees’ performance compliance with the certain terms and conditions of the contract; • Conducted walkthroughs with the respective contract owners to obtain an understanding of their contract monitoring process; and • Compared the selected invoices to the contract to review for completeness and accuracy. 6 Objectives and Approach - continued Approach - continued Internal Controls and Project Accounting and Capital Asset Accounting to include Grant Budgeting & Accounting • • • • • • • Obtained the contracts for a sample of two construction projects and verified the contracts were properly executed; Conducted walkthroughs with the project managers of the two selected projects to understand their monitoring and review processes; For the two selected projects, verified that all pay applications were on file, supported with documentation, and contained proper approval documentation; For a sample of two pay applications under each selected project, agreed amounts to the contract and schedule of values and recalculated mathematical accuracy of the pay application; For one pay application under each selected project, recalculated the mathematical accuracy of the schedule of values; Reviewed one change order for each of the selected construction projects to verify: proper approval, mathematical accuracy of underlying schedules, compliance with contract terms and conditions, and that the change order amounts were properly reflected in the pay applications in our sample; and Reviewed the closeout file for one selected completed construction project for completeness of documentation. Contract Facility Charge • • • • Obtained and reviewed a sample of CFC payments made by the rental car concessionaires into to the trust accounts; Tested selected rental car concessionaires’ compliance with the CFC terms and conditions of the contract; Tested payments received into the City’s CFC trust account as compared to the rental car concessionaires’ monthly activity reports; and Performed a walkthrough of CFC revenue payments/transfers from the CFC fund account to an approved use of the CFC fund. Airport Special Statements Reconciliation with the CAFR • • • • • Reviewed FAA Compliance Manual for financial reporting requirements; Discussed reconciliation process or lack thereof with City and Aviation department personnel; Obtained and reviewed fiscal year ended June 30, 2012, audited Comprehensive Annual Financial Report (“CAFR”); Obtained and reviewed fiscal year ended June 30, 2012, City of Charlotte Airport Enterprise Fund financial statements (“special statements”); Compared CAFR and special statements for accuracy and developed listing of reconciling items. Expense Reimbursement to the City • • • • Interviewed City Budget personnel on the process for developing the Cost Allocation Plan (“CAP”); Obtained copy of the CAP for FY 2013 and selected three departments for additional testing; Interviewed the sampled departments to understand how their charges are accumulated and the methodology for allocation in the CAP; Obtained support for the FY2013 CAP for the selected departments and compared to the CAP for accuracy, as well as evaluated the allocation methodology for reasonableness. 7 Objectives and Approach - continued Approach - continued Debt Management • • • • Interviewed City Finance and Aviation department staff to understand the process for issuing debt, setting up projects funded by debt, and tracking those projects; Obtained a copy of the Financial, Debt Management and Accounting Policy for the Airport and discussed the 2011 series debt in relation to that policy with personnel; Obtained a listing of all projects funded by the debt, selecting one for additional testing; For the selected project, obtained copy of project cost listing and support for all invoices coded to that project, to determine whether the support was properly coded to that project. Reporting For each of the high-risk core areas reviewed, we identified observations and recommendations for improvement where considered necessary. The observation matrix section provides the detail of the observations identified and recommendations for remediation. We have assigned relative risk factors to each observation identified. This is the evaluation of the severity of the concern and the potential impact on the operations. There are many areas of risk to consider including financial, operational, and/or compliance as well as public perception or ‘brand’ risk when determining the relative risk rating. Items are rated as High, Moderate, or Low. • • • High Risk Items are considered to be of immediate concern and could cause significant operational issues if not addressed in a timely manner. Moderate Risk Items may also cause operational issues and do not require immediate attention, but should be addressed as soon as possible. Low Risk Items could escalate into operational issues, but can be addressed through the normal course of conducting business. We have reviewed the results with the City’s Finance Director, Deputy Finance Director, Aviation Director, Aviation Finance Director and other members of the City and the Aviation department’s management. Included within the observation matrix is Management Response with the targeted implementation date for remediation of recommended action items. We recommend that the City have follow-up procedures performed for those observations where the remediation target dates have been reached, and ample time has passed under the new process/control to verify and report the implementation status of the recommendations to the previously reported observations. Follow-up is meant to validate, on a sample basis, the effectiveness of the remediated controls of the previously reported observations. 8 Observation Matrix City of Charlotte, North Carolina Turn Over Review Billing and Revenue, to include Rental Agreements and Contract Management Rating High Observation 1. Contract Administration Aviation records show that over 200 revenue contracts are administered. The Aviation department has one (1) employee, the Revenue Contracts Manager who is responsible for administration of the revenue contracts. We selected a sample of eight revenue contracts and two invoices from each revenue contract (one invoice from FY 2013 and one invoice from FY 2014) for testing. We also reviewed a sample of required periodic reporting documentation as stipulated in the revenue contracts. Our review was limited to sampled terms and conditions of the selected contract, as well as the revenue terms and conditions as it applied to the invoices selected. Not all revenue aspects and terms and conditions of each selected contract were tested in this review. We noted the following: Independent Validation Through discussions with the Aviation management and staff, we noted that they do not independently validate or verify the underlying supporting documentation received from the lessee, which is the basis of invoicing for some lease terms. For example, some lessee invoices are based on a percentage of sales or profits. Monitoring Through our sample testing we noted the following contract compliance issues in three of the eight contracts tested: Hertz Rent-A-Car and Enterprise Rent-A-Car: • The contract stipulates that the lessee is to provide year to date gross revenues on a monthly basis. Per review of the lessee’s monthly statements, only the previous month’s results are provided. • The contract requires that the lessee submit certified annual statements of gross revenues and compliance with CFC provisions. The Aviation department could not provide documentation of receipt of these 2 reporting requirements. Recommendation Management’s Response As previously noted, the Aviation department recently went through a system conversion to PROPworks®, in order to effectively manage their revenue contacts. PROPworks® will allow the Aviation department to effectively track agreements and leases, to compile information about business relationships, to bill and invoice tenants or concession operators, and to track service providers and concessionaires for compliance with agreements. Response: Aviation agrees with recommendation. As a point of clarification, the Aviation department has one dedicated revenue contract manager, but multiple other employees responsible for managing certain revenue contracts. The Aviation department is evaluating procedures for its revenue contracts based, in part, on the recommendations contained herein. The Aviation department is currently moving to a centralized model for managing its revenue contacts. In response to this initiative, Aviation is creating an Airport Business Office which will be responsible for revenue contract management, leasing, tenant negotiations, economic and business development, among other things. The total scope of the Airport Business Office is under development. We recommend the Aviation department perform the following: • Inventory active revenue contracts to determine completeness of contract document files and followup on identified issues. • Review contracts for outdated, irrelevant, or unenforceable terms, conditions, or clauses and consider them for removal. • Compare the active contracts to invoicing parameters to determine accuracy and completeness of invoices and follow-up on identified issues. • Utilizing PROPworks®, populate contract terms, timing of price escalations, and timing of periodic review of contracts. 9 City of Charlotte, North Carolina Turn Over Review Billing and Revenue, to include Rental Agreements and Contract Management - continued Rating High Observation 1. Contract Administration – continued Contract Approval and Documentation We noted the following contract approval and documentation issues with three of the eight revenue contracts reviewed: • Hertz Rent-A-Car: The 2nd Amendment to the contract, dated August 2005, was not signed by the Aviation department or the lessee. • Continental Airlines: The Aviation department was unable to locate the contract or amendment to substantiate the housekeeping services billings. • The Paradies Shops, LLC: The trash removal costs are not documented in the contract or amendments. The trash removal costs are documented in a letter signed by the Aviation department and sent to the lessee. The absence of consistent, periodic monitoring and validation of underlying support by the Aviation department limits their ability to comply with responsibilities under lease and concession terms and conditions. Failure to perform monitoring and validation opens the opportunity for control weakness and prevents the deterrent effect such tests would have. Recommendation • • • • Utilizing PROPworks® tickler system functionality, populate the documents and timing of lessee reporting required per the contract terms. Utilizing PROPworks®, if possible, maintain copies of required lessee reporting documentation, including evidence of review by the contract administrator. Enforce lessee reporting and documentation requirements, and performance of timely follow-up. Establish contract administration procedures. Implementation of the above recommendations will enhance monitoring of contract activities and help determine that terms of contracts are adhered to. Management’s Response Validation/Monitoring & Contract Approval/Documentation: As noted in the recommendation, Aviation recently implemented PROPworks®, which is a contract management and invoicing system in connection with the City’s ERP initiative. PROPworks® was activated on July 1, 2013 and is being utilized to enhance contract management and for all Airport invoicing. Aviation is currently populating PROPworks® with contract terms including price escalations and reporting requirements. Aviation will also utilize PROPworks® tickler system to maximize contract management functionality. 10 City of Charlotte, North Carolina Turn Over Review Billing and Revenue, to include Rental Agreements and Contract Management - continued Rating High Observation 1. Contract Administration – continued Invoicing We noted the following billing discrepancies per our review of the lessee invoices as compared to the associated revenue contracts: DHL Global Business Services: • Section 4.02(b) of the revenue contract states that facility rent shall be an amount equal to the annual amortization of the total cost of the Airport’s improvements over an amortization period of 20 years. Per our re-calculation, the monthly rental amount should be ~$35,397 (~$424,766 annually). The City’s rental calculation used a 25-year amortization period, under which rentals have been billed at $31,760 monthly ($381,120 annually) since the contract inception date of June 21, 2006. This amounts to an estimated monthly difference of ~$3,634. The estimated shortage in billings to date is ~$323,700, which would result in ~$1,032,078 in over billings at the end of the contract. • Section 4.01(c) of the contract states that the ground rent amount will escalate every 5 years on the anniversary date of building occupancy, which was June 21, 2006. The ground rent has not been updated since the original occupancy date of June 21, 2006. We re-performed the rent calculation using historical Consumer Price Index figures (CPI-U), and estimated the shortage in billings to be ~$7,000 for the period from June 21, 2011 to November 21, 2013. Recommendation Management’s Response It is our understanding the Aviation department is in process of followingup on these identified invoicing issues. Invoicing: Noted observation regarding DHL contract has been confirmed and resolved. Aviation has invoiced DHL for ground rent identified in Observation. Furthermore, DHL has executed a letter of acknowledgement confirming 25 year amortization term used to calculate facility rental. Estimated Completion Date: The creation of the Aviation Business Office; establishment of contract administration procedures; and completion of PROPworks® contract management module updates are anticipated to be complete by the end of Calendar Year 2014. Responsible department Party: Aviation 11 City of Charlotte, North Carolina Turn Over Review Billing and Revenue, to include Rental Agreements and Contract Management - continued Rating High Observation 2. Right to Audit Clause Through our testing of the revenue contracts we noted that three of the eight revenue contracts sampled did not include a right to audit clause and the Aviation department has not previously exercised their right to audit. . A right to audit clause is a good business practice for all types of organizations, of all sizes. They support compliance Carrying out and allow for business partner oversight. regular audits tends to build greater trust with contract relationships. Also, it sends the message that the Aviation department will be monitoring to determine compliance with the contracting entity’s ethics or business standards and that the entity is complying with the agreed upon contractual relationship. Recommendation Management’s Response We recommend that the Aviation department perform the following: • Review all active revenue contracts to determine which revenue contracts are lacking a right to audit clause and modify where deemed necessary. • Work with Airport Counsel to determine if a right to audit clause can be executed on revenue contracts that have expired and are currently month to month. • Consider exercising right to audit clauses on a periodic basis. Response: Aviation agrees with proposed recommendation. All revenue contracts will include a right to audit clause. Aviation Revenue Management/Airport Business Office will conduct annual review and sample of revenue contracts for consideration of exercising right to audit. Estimated Completion Date: Effective Immediately Responsible department Party: Aviation 12 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting Rating High Observation 3. Policies & Procedures Based on interviews with Aviation management and staff, we noted that there are no formal, documented policies and procedures for the following: • Pay application review process. • Project Management • Bidder selection Process • Grant Compliance Reporting • Change Order Process Lack of documented policies and procedures increases risk of errors and omissions, which could jeopardize the grant funding. Further, centralized, standardized, and documented policies and procedures provide vital information to employees in the event of absences, employee turnover, or other occurrences. • Grant application / funding process, which includes requiring / facilitating Aviation Finance department’s involvement early in the process with development in the identification and analysis for funding the respective “live” and “ready” capital projects. Including Aviation Finance department earlier in the grant funding / budgeting process is vital in providing a full and detailed funding analysis to determine the financial viability of the respective projects. This is especially vital since for most grant (AIP) funded projects, Aviation is responsible for 25% of the project cost. Further, centralized, standardized, and documented policies and procedures provide vital information to employees in the event of absences, employee turnover, or other occurrences. Recommendation Management Responses We recommend that the Aviation department develop policies and procedures for the following: • Pay application review process, to facilitate the collaborative participation of both Development and Aviation Finance staff in the process. Further, management and staff should utilize a checklist to document reviews and reconciliations performed throughout the pay application review process. This checklist will serve both as documentation of work performed and as a reference to employees, helping ensure proper review and support of all payments pursuant to contract terms and conditions. See also recommendations #5. • Project management process. Further, management and staff should utilize a checklist to document key procedures from project initiation to project closeout. This checklist will serve both as documentation of work performed and as a reference to employees, helping ensure proper compliance with project management requirements and duties as outlined in internal policies and in compliance with the Owner’s project management responsibilities stipulated in the contract. Response: Aviation concurs with the recommendation that it should develop policies and procedures governing the processes identified herein to ensure efficient and effective operations and minimize the impact of staff absences and/or turnover. The Aviation department has recently implemented a contract procurement process which tracks the flow of all Aviation department contracts from inception to execution. Aviation Development has integrated this form into its contract workflow. Aviation also agrees with the continued collaborative participation with both Development and Aviation Finance departments and to develop and utilize a checklist to document reviews and reconciliations performed throughout the workflow process. 13 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Rating High Observation 3. Policies & Procedures - continued Recommendation • • Bidder selection process that require the collaborative participation from the following Aviation departments including Development, Finance, Procurement and Legal staff in the process. Further, management and staff should utilize a checklist to document bid process milestones performed throughout the bidder selection process. This checklist will serve both as documentation of work performed and as a reference to employees, helping ensure proper compliance with internal policies and applicable procurement state statutory and federal and / or state grant requirements. Grant compliance reporting process. Further, management and staff should utilize a checklist to document key procedures from grant pre-application to grant closeout. This checklist will serve both as documentation of grant monthly and quarterly reporting timeline with key activities performed and as a reference to employees, helping ensure proper compliance with grant reporting required data criteria and deadlines. Management Responses Estimated Completion Date: Aviation estimates development and implementation of recommended checklists by the end of calendar year 2014. Responsible department Party: Aviation 14 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Rating High Observation 3. Policies & Procedures - continued Recommendation • • Management Responses Change order process which documents the key steps of the process and also comply with the changes in work provision in the contract documents. These change order policies and procedures should take into account recommendations #6. Further, management may want to establish a checklist as part of the change order form, that includes, but not limited to: o Nature/purpose of the change o Entitlement Determination o AE drawings / input as needed o Engineer input, as needed o Cost, including support o Impact on project schedule Grant application / funding process that facilitate the collaborative participation of both from the Aviation department’s Development and Finance staff in the decisionmaking process. Further, management and staff should utilize a checklist to document reviews and cash flow and other analysis performed. This checklist will serve both as documentation of work performed and as a reference to employees, helping to ensure the financial viability of the respective projects to be funded. 15 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Rating High Observation Recommendation 4. Capital Projects & Grants – Shadow Capital Projects Cost Report Based on interviews with Aviation management and staff, due We recommend that in collaboration to various limitations of the City’s general ledger system with appropriate City management and (“GEAC”), Aviation management and staff developed a staff and the ERP implementation duplicative, redundant system - their own “shadow” system team that Aviation management and (with ACCESS) to track capital project expenditures and appropriate staff should continue to be funding. included and significantly involved in this ERP implementation process. This For example, GEAC has limitations as it relates to the tracking is especially vital as it relates to the of grant funding vs. budgeted and actual disbursements by capability and configuration of the project. GEAC does not allow for the tracking of multiple grants capital project accounting and grants to one project. Further, GEAC does not provide Aviation module to ensure that it best meets the management and staff with the visibility needed to track project functionality Aviation management disbursements / expenditures real time in terms of measuring needs to avoid continuing to run a actual expenditures vs. budget etc. duplicate, redundant and costManagement indicated that the amounts as manually input into consuming capital cost projects this shadow project cost system do not reconcile to the system. amounts recorded in the GEAC system due to various factors including timing differences and expenditures directly charged to GEAC that are not communicated to Aviation Finance department as well as various accrual and reversing journal entries. Based on conversations with Aviation management, we understand that a new ERP system (MUNIS) is being implemented and is projected to go live during calendar year 2014. Management Responses Response: Aviation is fully integrated with City Finance and the ERP team in connection with the implementation of the City’s ERP initiative. Aviation participates in regular ERP coordination meetings and conducts internal weekly review and status meetings and maintains a Readiness Checklist to ensure successful project implementation. Aviation is involved with the development and configuration of the capital project and grant accounting module to be implemented in connection with the ERP initiative. The implementation of Munis ERP will negate the need for Aviation to avoid running a duplicate project capital cost report. Estimated Completion Date: ERP Munis is currently projected to ‘go-live’ in July 2014. Responsible department Party: Aviation 16 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Rating High Observation 5. Pay Applications Review and Approval Pay Application Review Based on interviews with Aviation management and staff, management does not review the mathematical accuracy of the monthly pay applications as part of the review process. In our review of two pay applications for the Rental Car Facility (“RCF”) and Hourly Parking Deck project, we noted that there is a complex detailed schedule of values that includes multiple funding sources that need to be allocated based on contractually agreed upon percentages. We did note some mathematical inaccuracies in the four pay applications selected for the two construction projects tested, as follows: RCF and Hourly Parking Deck: Pay Application 7: • The percent complete calculations on the schedule of values do not include the stored material amounts. This caused the percent complete to be understated for 8 line items. • On the schedule of values, the "Work completed This Period," "Balance to Finish," and "Retainage" totals do not include the last line item on the original contract section (Gasoline Fueling System Labor, under Division 33 Utilities). This caused the retainage amount to be understated by $683.57, which affected the total amount due by this same amount. Recommendation Management Responses Pay Application Review/Approval/ Sign Off’s We recommend that the Aviation department implement controls in the pay application review process that includes: • Recalculating the roll-up of the schedule of values for each monthly pay application for accuracy of the amounts being billed; • In the case of multiple funding sources, this will mitigate the risk of misappropriation of funds to the relevant costs; and • Documentation of the review and approval steps in the pay application review process. Response: Pay Application Review: Aviation agrees with this recommendation. After approval of the Schedule of Values submitted by the contractor, the final format for pay applications will be created individually for each project by the Aviation project manager. To ensure that formulas and or change order work is not edited by the contractor, the project manager will create an excel pay application with all line items and formulas and password protect the pay application for contractor use. If the pay application needs to be edited, the Aviation project manager will revise the pay application, password protect it, and resend to contractor for their use. Retainage Percentage not Consistent with Contract Terms We recommend that the Aviation department implement a control in the pay application review process that includes reviewing the retainage amount for each monthly pay application for accuracy and consistency with the contract terms. 17 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Rating High Observation 5. Pay Applications Review and Approval – continued Pay Application Review - continued RCF and Hourly Parking Deck - continued: Pay Application 7 - continued: • The cost allocation calculations were not completed for the last line item of the original contract section (Gasoline Fueling System Labor, under Division 33 - Utilities). • The percent complete is not calculated correctly for two change order line items (“ASI-001 Owner Contingency” and “Bulletin-007 Revisions to RCF deck fueling system”). • The “balance to finish” is not correct for the last line item of the change order section ("Bulletin-007 Revisions to RCF deck fueling system"), which also affected the total change orders amount. Recommendation Management Responses Estimated Completion Date: Aviation estimates development and implementation of recommended checklists by the end of calendar year 2014. Missing review/approval sign-offs and retainage percentage recommendations will be effective immediately. Responsible department Party: Aviation We noted that the above errors were corrected on the subsequent pay application in our sample (22).Pay App 22: • Retainage was not calculated on the change orders. This caused the retainage to be understated by $46,732. Runway Reconstruction: Pay App 9: • The Schedule of Values shows the total contract sum as shows $24,602,357.68; the pay application $24,099,003.68. We were not able to reconcile these two figures. Lack of review of mathematical accuracy in the Schedule of Values or inaccurate allocation of the costs among funding sources can lead to inaccurate billings and / or misappropriation of funding sources. 18 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Rating High Observation 5. Pay Applications – continued Missing Review/Approval Sign-Off’s We noted the following approval or review sign-offs were not documented on the pay applications for the 2 selected projects: • Rental Car Facility and Hourly Parking Deck pay applications 5 and 9 did not contain evidence of Project Manager approval or review. • Runway Reconstruction pay applications 2 and 9 did not contain evidence of Assistant Director for Development approval or review. Lack of required sign-offs prevents accountability and represents a weakness in internal controls over review and verification of the pay application accuracy. Retainage Percentage Not Consistent with Contract Terms The retainage percentage on application and certificate for payment 9 for the Runway Reconstruction project was 2%, which is not consistent with the contract terms. Section 90-06 of the contract Terms and Conditions covers retainage, and states the following: "From the total of the amount determined to be payable on a partial payment, ten (10%) percent of such total amount will be deducted and retained by the Owner until the final payment is made. When not less than 95 percent of the Work has been completed the Engineer may, at his/her discretion and with the consent of the surety, prepare an estimate from which will be retained an amount not less than twice the Contract value or estimated cost, whichever is greater, of the Work remaining to be done." Withholding retainage at the contractually stipulated percentages provides the Owner with financial leverage to ensure the project is completed timely and according to plans and specifications. By forgoing this practice and electing to significantly reduce the percent retained, the Owner weakens its overall position with respect to its fiscal and operational relationship with the Construction Manager. Recommendation Management Responses Response - continued: Missing Review/Approval Sign-offs: Aviation agrees with recommendation. Aviation will address this observation as follows: (1) once finalized by the project manager and contractor, the project manager will sign the pay application signifying her review and approval of the contracts; and (2) the pay application will then be forwarded to either the Assistant Aviation Director – Development, Deputy Aviation Director or Aviation Director (depending on availability) for final review and execution. Retainage Percentage no Consistent with Contract Terms: Aviation acknowledges the tested contract’s retainage provision was misapplied in this instance. Development, in cooperation with Legal, will ensure that the retainage provision is properly applied moving forward. Furthermore, in November 2013 Aviation has hired a full-time project cost and grant accountant who will assist in the review and accurate confirmation of retainage. Estimated Completion Date: Effective immediately. Responsible department Party: Aviation 19 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Rating High Observation 6. Change Order Process Approval Thresholds We noted that City Council review and approval is required for change orders greater than $100,000. Mark-up not specified in contract We selected 2 projects for review. For the RCF and Hourly Parking Deck project, we reviewed the 5 change orders executed or proposed to date. We noted that for all proposed change orders, mark-up was included, but no amount or percentage was specified in the contract Lack of documentation related to mark-up for additive change orders can lead to unauthorized and / or excessive charges. Recommendation Management Responses Approval Thresholds We recommend that the requirement of City Council review and approval of change orders greater than $100,000 be increased to a threshold amount more appropriate to maintain efficiency of operations. Response: The Aviation Department will work with the City regarding the City Council threshold requirement. Mark-up not specified in contract We recommend that the Aviation department require the documentation of contractor and subcontractor markups in the contract documents. If the change order enlarges the project budget by adding additional scope, labor or materials, Aviation would present the Change Order to the City Manager or Charlotte City Council as required by the City’s procurement policy. This will mitigate the risk of unauthorized and / or excessive markup fees for change orders. 20 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Rating High Observation 6. Change Order Process - continued Proposed Change Order - Purpose, Entitlement and Supporting Documentation We selected 2 projects for review. For the RCF and Hourly Parking Deck project, we reviewed the five change orders executed or proposed to date. We noted that for all proposed change orders, the entitlement determination, cost support, including AE review and input is not included in the proposed change order (“PCO”) documentation reviewed by the Aviation Assistant Director and / or Deputy Director, Aviation Director, City Manager and City Council as applicable for authority threshold approval requirements. Lack of documentation related to entitlement and detailed cost support for additive change orders can lead to unauthorized and / or inappropriate charges. Recommendation Management Responses Proposed Change Order - Purpose, Entitlement and Supporting Documentation We recommend that the Aviation department require the following as part of the change order forms and process: • Inclusion of clear description and documentation as to the purpose and nature of the change in the determination of entitlement • Making the PCO support related to submittal of the proposed change order available electronically (such as via Sharepoint,etc) for the various levels of review from the Aviation Assistant Director and / or Deputy Director, Aviation Interim Director, City Manager and City Council as required by the approval thresholds Response - continued: Mark-Up: Aviation agrees with the recommendation. Aviation will include a suitable mark-up provision consistent with the recommendation. This will mitigate the risk of unauthorized and / or unsupported charges through the review and approval by the appropriate authority from Aviation Interim Director to City Council. Change Order Process: Aviation’s standard form change order requires a brief description of the work captured in the change order. Failure to include a description in this case would have been an oversight. Aviation agrees that entitlement determination, cost support and AE review are necessary in connection with change orders. However, Aviation does not believe that change orders include back up documentation when delivered to management for execution. All backup documentation is filed for easy access in the event additional information is required. The project manager (who has the greatest knowledge of the project) prepares each change order and serves as a staff resource for the Aviation Director, City Manager or Charlotte City Council prior to consideration and approval of the change order. 21 City of Charlotte, North Carolina Turn Over Review Internal Controls and Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Rating High Observation 6. Change Order Process - continued Recommendation Management Responses Response - continued: Change Order Process - continued: Development does not believe that attaching back up documentation to the change order would be effective because the party responsible for execution does not typically have the time or depth of understanding of the relevant project to sort through voluminous back up documentation. The staff resource can answer any and all questions quickly and comprehensively as needed. Estimated Completion Date: Effective immediately. Responsible department Party: Aviation 22 City of Charlotte, North Carolina Turn Over Review Contract Facility Charge Rating Moderate Observation 7. Automobile Rental Concession Agreements Concessionaire Compliance with Contract Terms and Conditions The automobile rental concession agreements require that the rental car concessionaires remit the monthly CFCs collected on th or before the 10 day of the next succeeding month to U.S Bank National Association, the bond Trustee. We selected 2 automobile rental concession agreements and 2 months of CFC remittances to the trustee noting the following: • • • Although the rental car concessionaires currently submit monthly CFC activity summaries, this is not a requirement per review of the automobile rental concession agreements dated November 1, 2011. However, this is a requirement per review of City Ordinance Section 4-38 dated July 1, 2007. Neither rental car concessionaire selected had submitted th their remittances to the trustee on or before the 10 day of the succeeding month, as required by the automobile rental concession agreements. For one month, one rental car concessionaire did not submit their remittance to the trust nd until the 2 succeeding month. The Aviation department receives monthly CFC summaries from the rental car concessionaires; the City’s Central Finance department receives the monthly CFC trust statements, posts the CFC to the general ledger and performs the bank reconciliation. Although we did not note any exceptions of rental car concessionaire remittances to the trustee as compared to the monthly CFC activity summaries provided by the rental car concessionaires, there is no internal verification/reconciliation of the CFC activity summaries to the CFC trust statements performed by the City’s Central Finance department nor the Aviation department. Recommendation Concessionaire Compliance with Contract Terms and Conditions We recommend that the Aviation department: • Update the automobile rental concessionaire agreements, by way of letter of agreement, memorandum of understanding or the like, to include the requirement that the rental car concessionaires submit monthly CFC activity summary reports and reporting detail showing the length of the rental period for each transaction, for monthly review. • Develop a standardized concessionaire monthly reporting form that provides sufficient detail to determine if gross receipts and other necessary items are correctly reported and include the form as an appendix to the agreement with the concessionaires. • Review the CFC activity summary reports against the reporting detail provided by the rental car concessionaires and spot check to determine if CFCs are computed in accordance with the automobile rental concession agreement. Management’s Response Response: Aviation agrees with recommendation. Aviation management has discussed this with senior managers of the prospective rental car companies. These representatives expressed doubt as to whether the findings are reflective of a systemic failure to comply with reporting requirements. Given the press of time in formulating this response, Airport Management has not conducted an independent investigation to determine and document the scope of such observed irregularities. Nevertheless the Rental Car Companies agreed to execute a letter provided by Airport management reciting the reporting requirements and agreeing to strictly comply with them going forward. Airport management is in the process of preparing such a letter and will send it to the rental car concessionaires and follow up with them on its execution and return. Management will also instruct its contract manager to periodically review monthly reports for completeness and adherence to requirements and will enforce the rental car companies reporting requirements. 23 City of Charlotte, North Carolina Turn Over Review Contract Facility Charge - continued Rating Moderate Observation Recommendation 7. Automobile Rental Concession Agreements – continued Concessionaire Compliance with Contract Terms Concessionaire Compliance and Conditions – continued with Contract Terms and A full reconciliation of the supporting documentation to Conditions – continued the CFC trust statements and general ledger offers • Obtain the monthly trust checks/balances and a means to detect errors in the statement, bank reconciliation CFCs remitted. Failure to perform a timely review to and general ledger detail from supporting documentation may cause delays in the the City’s Central Finance identification of potential issues and / or irregularities. department and compare and reconcile the monthly CFC Use of CFC Per Automobile Rental Concession activity reports received from Agreement the rental car companies. Currently, remaining CFCs are used to pay the monthly facility rent charges for the rental car concessionaires. Use of CFC Per Automobile This is allowed per 6 e) of the City Ordinance. Rental Concession Agreement We recommend that the Aviation ”The City shall use the proceeds of the CFC to department modify the automobile compensate the City for any amounts due the rental concession agreements City from and not other paid by the Tenant and/or City Ordinance for CFC to RACs pursuant to the concession agreements with current correspond and facility leases in effect between the City concessionaire business and the Tenant RACs.” practices, where needed. This provision is not defined in the 2 selected automobile rental concession agreements dated November 1, 2011. Management’s Response Response - continued: (1) Management will develop a standardized monthly reporting form for the concessionaires to use in complying with their reporting requirements. (2) Management will conduct regular periodic testing of the monthly reports to measure compliance with reporting requirement and to determine whether CFCs are being calculated correctly. (3) Management will conduct regular periodic testing of the monthly reports to measure compliance with reporting requirement and to determine whether CFCs are being calculated correctly. (4) In March 2014, City Finance provided Aviation with monthly CFC deposit statements from the Trustee from July 2013 through February 2014. Finance will continue to provide copies of CFC deposit statements from the Trustee. Aviation will review the monthly Trustee statements and identify any discrepancies with CFC Reports received from the Rental Car Companies. (5) Aviation proposes to address recommendation regarding use of CFC in rental car concession agreement via letter acknowledgement rather than formal amendment to the Rental Car Concession Agreement. Estimated Completion Date: Rental car letter acknowledgement will be provided to Rental Car Concessionaires by June 30, 2014. Responsible Party: Aviation department 24 City of Charlotte, North Carolina Turn Over Review Airport Special Statements Reconciliation with the CAFR Rating Moderate Observation Recommendation Management’s Response 8. Reconciliation of CAFR to Airport Enterprise Fund Financial Statements During the course of our review, we noted that there is no We recommend that the City’s Central Finance Response: Aviation generally formal reconciliation between the City’s audited CAFR and and Aviation departments perform a agrees with recommendation. the stand-alone financial statements of the Airport (“special reconciliation between the audited CAFR and Aviation is collaborating with the Central Finance statements”), which are submitted annually to the FAA. We the stand-alone special statements of the City’s did note the City maintains a series of folders and support airport. The reconciliation should include a department in developing a plan for specific items within the CAFR and stand-alone summary of variances and where the amounts to address this recommendation. statements, and that the both statements are audited and were obtained, and any schedules that are Aviation is requesting clarification certain portions of agree in the aggregate. The key reconciling items noted included in the special statements that are not on part of the audited CAFR should be tied to the recommendation. relate to the following: • Statement of Revenues, Expenses and Changes in Net City’s final adjusted / audited trial balance. Estimated Completion Date: In Assets included in the special statements, where the This could be accomplished by utilizing the conjunction with the FY 2015 breakdown of operating expenses into service areas new ERP system’s chart of accounts to include audit. agrees in total to the CAFR (page 44) but the categories special segment codes or other designators in Aviation vary from the City’s trial balance and the differences are order to accumulate the cost allocations for the Responsible Party: not explained. We were unable to reconcile the items by special statements and reduce the need to re- department in conjunction with enter all transactions into a secondary system the City’s Central Finance reviewing the City’s trial balances. department • Schedule of Changes in Net Assets – Included and for reporting purposes. Excluded Centers is not a statement required in the CAFR but is submitted with the special statements. As Both reports include a footnote disclosure for such, the City’s trial balance activities must be parsed in the definition and calculation of the passenger order to accumulate the data. Given the variances in facility charges revenue. Due to the operating expenses noted above, the included/excluded significance and complexity of airport operations, the City should also consider amounts could not be determined. • Schedules of Cash Deposits and Withdrawals are not including a footnote disclosure in both reports statements required in the CAFR, but are submitted with related to the contract facility charges revenue terminal revenue the non-airline the special statements. As such, the City’s trial balance and expenses, for informational activity must be parsed in order to accumulate the data. distribution Total ending balances included on the schedules does purposes. not agree to the cash and investments reported on the Statement of Net Assets, which agrees to the audited CAFR. These variances should be reconciled. It should be noted that our procedures did not include reconciliation of the CAFR and special statements to the FAA required financial reports described in the next issue. 25 City of Charlotte, North Carolina Turn Over Review Airport Special Statements Reconciliation with the CAFR - continued Rating Low Observation Recommendation 9. Timing of Submission and Reconciliation of Financial Reports to the FAA We noted during our review that the FAA Compliance Manual We recommend that the Aviation requires their Forms 5100-126 and 5100-127 to be submitted department, in conjunction with the City’s Central Finance department, within 120 days of fiscal year end. evaluate the benefits of filing the FAA Per discussion with the Aviation department’s Finance required financial forms utilizing Manager, these forms are historically completed based upon unaudited statements, and then the audited CAFR and special enterprise fund financial reconciling the statements once the statements of the airport. The CAFR and the special CAFR and special statements are statements, however, are not required to be completed until issued. 180 days after fiscal year end. At a minimum, the procedures for This timing requires the airport to obtain a filing extension preparing the Forms 5100-126 and from the FAA each year. These extensions are generally for 5100-127 should be documented and 60 days. It should be noted that the FAA requires the forms reconciled to the special statements to be completed by the deadline and notated as “unaudited” if and/or CAFR each year. the audited financial statements have not been received. Later, if the audited financial statements report significant changes, there is a process for amending the forms. Management’s Response Response: Aviation agrees with recommendation. Aviation has initiated the compilation of revenue and expense data needed for FAA Financial Reports using unaudited revenues and expenses from the general ledger. Aviation will prepare reconciliation between FAA Financial Reports and the Special Statements and/or CAFR. Aviation is consulting with City’s Central Finance department and Bond Counsel to confirm whether any limitations exist with respect to posting unaudited financial information due to potential concerns from existing and prospective investors of Airport revenue bonds who may use this information for credit evaluation. Estimated Completion Date: May 12, 2014 Responsible Party: Aviation department in conjunction with the City’s Central Finance department and Bond Counsel 26 City of Charlotte, North Carolina Turn Over Review Expense Reimbursement to the City Rating High Observation 10. Methodology Documentation and Monitoring During our interviews and review of support for a selected sample of services allocated, we noted the following with respect to the City’s overall Cost Allocation Plan process: Ownership of the CAP 1. The Budget & Evaluation Department accumulates the CAP data into a final report for approval, but is not responsible for the accuracy of the data. Each allocated agency works with the Budget & Evaluation Department to establish a methodology, then calculates their own allocation on using the agreed-upon methodology. The agency enters data into the Clarity system for inclusion in the overall plan. The support for the calculation and methodology is not consistently reviewed outside of each agency, but the output is reviewed by the Budget & Evaluation Department prior to being published in the annual cost allocation plan. Consistent Documentation of Personnel Activity Costs 2. The agencies that allocate charges based upon an estimate of the staff time spent supporting each department are not consistent in the way the time estimate data is collected and documented. There is no prescribed format for time and effort tracking and there is no standardized monitoring or analysis of the amounts reported. Federal guidelines, under OMB Circular A-87, Attachment A, require an accurate tracking of staff time spent in indirect activities for the purposes of cost allocation for federal programs, and FAA guidelines require the City’s CAP follow OMB Circular A-87. Documentation of CAP Methodologies by Department 3. We reviewed the methodology and support for $20 million (24%) of the CAP for FY 2013, consisting of Finance, Information Technology and Procurement, noting that the allocation methodologies for those agencies appear to be based upon reasonable units of measurement, but that the supporting documentation, as noted above, is not consistent and not always available. The allocation amounts are based upon budgeted amounts and are also not evaluated against actual amounts, as described below. Recommendation We recommend the following related to oversight and monitoring of the CAP: 1. The CAP should be owned by the City’s Budget & Evaluation Department, to include documentation and evidence of the agreed-upon approval by Budget and each agency of how each allocation is performed, and including a description of each indirect account that is allocated. Each agency should still be responsible for calculating and entering the data into Clarity, but the support should be provided and reviewed by the City’s Budget office for reasonableness and accuracy. 2. A prescribed format and reporting period for time and effort tracking should be developed, approved and consistently implemented to provide sufficient support for staff time estimates. OMB Circular A-87 outlines how this should be done. The City’s PeopleSoft is currently used for assigning time staff time to projects and formal procedures and employee training can be used to complete these tasks. 3. CAP support should be retained under the same document retention requirements for public records requests, or other regulatory requirements as applicable, if different for the Aviation department. Management’s Response Response: The City agrees with this recommendation. City Budget and Evaluation will collaborate with the City’s Central Finance to develop and department implement procedures to document and monitor the CAP. Estimated Completion Date: Draft procedures are estimated to be in place by October 31, 2014. Responsible Party: Aviation department in conjunction with the City’s Central Finance department and City Budget and Evaluation 27 City of Charlotte, North Carolina Turn Over Review Expense Reimbursement to the City - continued Rating High Observation 11. CAP Approval Chapter 15 of the FAA Airport Compliance Manual allows the City to allocate certain indirect costs to the airport. The manual states: “In an acceptable cost allocation plan, the sponsor allocates costs in a manner consistent with Attachment A to Office of Management and Budget (OMB) Circular A-87 except substitute the phrase “airport revenue” for the phrase “grant award” wherever the latter phrase occurs in Attachment A.” The City’s CAP has not been approved by the City’s federal cognizant agency for approving indirect cost allocation plans in relation to federal grant awards. The methodologies and documentation for these cost allocations can vary from the federal guidance, but variances must be approved by the City’s federal cognizant agency, which is the federal agency responsible for reviewing, negotiating, and approving cost allocation plans or indirect cost proposals. According to the City’s Budget office, the City’s cognizant agency is the Federal Transit Administration. Recommendation Management’s Response In addition to the methodology documentation and process improvements described elsewhere, we recommend that the City obtain approval of the overall cost allocation plan. Response: City agrees with this recommendation. City Budget and Evaluation will submit proposed CAP to the Federal Transit Administration for approval. This approval should be obtained in accordance with OMB Circular A-87, evaluated by the City’s cognizant agency (Federal Transit Administration), and submitted to the FAA for informational purposes. Estimated Completion Date: City Budget and Evaluation will provide a CAP to the FTA by October 31, 2014, to seek approval for the FY2016 Budget cycle Responsible Party: Evaluation City Budget and Approval of the CAP can also serve as documentation for the allocation of direct and indirect costs to federal award programs, as allowable by those programs. 28 City of Charlotte, North Carolina Turn Over Review Expense Reimbursement to the City - continued Rating Moderate Observation 12. Basis for Cost Allocation Plan OMB Circular A-87 requires certain documentation and periodic true-up (after the fact analysis) of indirect cost allocations against actual amounts, in order to determine whether the amounts allocated were correct. Under OMB Circular A-87, estimates do not qualify as support for charges, but can be used for interim accounting purposes. If that occurs, the agency must: • Use a reasonable method for establishing the estimates; • Compare actual costs to budgeted distributions at least quarterly; and • Reflect adjustments accordingly to reflect changed circumstances. The City’s CAP is based upon amended budgeted amounts, rather than actual amounts. The CAP for FY 2013 was based upon final amended budgets for FY 2011, approved during FY 2012, and implemented in FY 2013. As such, the between budget and actual variances may not be material. Recommendation Management’s Response We recommend that actual expenditures be used as the basis for the CAP. Response: The City agrees with this recommendation. In collaboration with Aviation, Finance, and other City departments, City Budget and Evaluation will use actual expenditures as basis for CAP pursuant to OMB Circular A-87. Estimated Completion Date: TBD While the City continues to use the budgeted amounts, we recommend the quarterly comparisons are made, with adjustments as needed, in accordance with the guidance. Responsible Party: Aviation department in conjunction with the City’s Central Finance department, City Budget and Evaluation and other application City departments The City does not modify the CAP during the year, and there has not been a comparison of actual costs against the CAP since FY 2011, per discussion with the Budget office. As such, the City is not routinely performing a true-up analysis of indirect allocations. 29 City of Charlotte, North Carolina Turn Over Review Debt Management Rating High Observation Recommendation 13. Bond Funded Project Invoice Support, Coding and Tracking In order to evaluate whether the bond proceeds were properly In order to facilitate compliance with used, we selected one project and tested the supporting the bond resolution and tracking of documentation for validation that charges were coded to the the use of proceeds in accordance correct project. The project selected was “East Terminal with IRS guidelines, we recommend Expansion” #55509, which was substantially complete at the that project invoices include billing time of testing. This project was fully funded by the 2011 for one project only, include any Series B bonds. relevant purchase order and contract information, and supporting During our testing, we noted the following: documentation for amounts billed. • One invoice for $695 was for a different project, but was improperly coded to 55509. Specifically related to Direct • One vendor routinely performs project management for Payments that do not have a multiple projects at the airport. The vendor’s invoices were corresponding purchase order or initially coded to a generic “Project Management” project contract, the invoices should include cost center, and then later allocated to specific projects. For additional details either from the the project selected, 7.61% of the total costs were vendor or the Aviation department on allocated, but there is no support for how the allocation was how it was determined that the determined and calculated. The contract did not specify an invoice was for the selected project, especially in instances where the allocation, and should be based on actual time spent. • One vendor billed more than one project on the invoice and description of the work does not match the airport’s internal project Aviation used square footage for the allocation. • One invoice for $3,822.50 was properly coded, but did not description. include a stamp for approval of the payment and coding. • Multiple instances where the supporting invoice did not Further, the Aviation department reference “East Terminal Expansion”, making it unclear and/or the City’s Central Finance should consider whether the invoice was properly coded. Where a purchase department order or contract number was provided, we obtained a copy periodically sampling project invoices of the additional documentation and determined that the from the project cost reports and project was East Terminal Expansion. There were 4 verify that the amounts were coded payments, totaling $29,658.69, that were direct payments to the correct project and that documentation is and additional support (such as a PO or contract) was not supporting sufficient. available for testing. • The prime contractor on the project did not provide subcontractor invoice support in order to validate that the subcontractor properly billed for the correct project. Management’s Response Response: Invoicing: Aviation generally agrees with recommendation. In the circumstance where a contractor is involved with more than one project, Aviation will request current contractors provide Aviation with individual invoices for each discreet project. If contract terms or circumstances prevent individual invoices, Aviation will request contractor provide invoice with line-item detail for each discreet project. Aviation Finance will periodically sample project invoices and verify that amounts coded to the correct project. In November 2013 Aviation has hired a full-time project cost and grant accountant who will assist in the sampling of invoices to confirm project coding. 30 City of Charlotte, North Carolina Turn Over Review Debt Management Rating High Observation Recommendation 13. Bond Funded Project Invoice Support, Coding and Tracking - continued Management’s Response Response - continued: Direct Payments: The implementation of the Munis ERP does not allow for the use of Direct Payments to pay vendors. For nonconstruction contracts/purchase orders, Munis will require a three way match (Purchase Order or Contract /Invoice/Receiving Confirmation) to pay vendor. Current direct payments will require requisition entry and purchase order conversion. Change orders for construction contracts will require requisition and purchase order conversion, but will not require the three way match. Estimated Completion Date: Aviation will develop an invoice sampling and testing schedule by the end of June 2014. Responsible department Party: Aviation 31 City of Charlotte, North Carolina Turn Over Review Debt Management - continued Rating Moderate Observation Recommendation 14. Financial, Debt Management and Accounting Policy for the Airport Project Review and Tracking Procedures Project Review and Tracking During our discussions with management, and review of the Procedures Financial, Debt Management and Accounting Policy for the We recommend that the City’s Airport, we noted that invoices are not periodically sampled and Central Finance department tested for proper project coding for projects funded by bonds or periodically sample invoices for grants. Given the nature of the various funding sources and the projects that are funded with debt extent of projects underway at the airport, additional scrutiny proceeds or grant funds, and test whether the expenses were coded to should be paid to these expenses. the proper projects, and have Like all City departments, the Aviation department is responsible adequate support. for coding/assigning vendor invoices to the correct projects. Although invoices are selected for testing during the annual Further, we recommend the City’s external audit, the depth of the testing does not trace the Financial, Debt Management and expenses back to the specific funding source (i.e., which series of Accounting Policy be updated to bonds was used). The City and the Aviation department do include this task, including the review total expenditures by project on a monthly basis, and frequency of testing. compare the totals against the project budgets. Unused Bond Proceeds There are projects that are served by more than one vendor, and We recommend that the Aviation there are vendors that serve more than one project, increasing department and the City’s Central the risk that the vendor invoices do not contain adequate detail in Finance department prepare a summary memorandum of the bond order to allocate the costs to the correct project. proceeds that are unspent, the Unused Bond Proceeds original planned uses and the During review of the of airport special statements, we noted there allowable uses, based upon IRS are multiple series of bonds with unused proceeds yet to be rules and regulations, and the spent, including from 2004, 2007, 2010 and 2011 series bonds. options available to the Airport/City The City’s Financial, Debt Management and Accounting Policy for for the future use of those funds. the Airport requires bond funds to be spent within 3 years, or a written memorandum of explanation to the City’s Finance Director We further recommend that, based must be prepared by the Aviation department, and Bond Counsel upon the summary, management confer with Bond Counsel and would be consulted as appropriate. develop an action for the appropriate A memorandum of understanding has not been prepared for any future use of those funds. of the unspent bond proceeds that are not currently attached to committed projects. Management’s Response Response: Project Review and Tracking Procedures: Aviation Finance will periodically sample project invoices and verify correct project funding source. In November 2013 Aviation has hired a full-time project cost and grant accountant who will assist with the sampling of invoices. Furthermore, implementation of Munis ERP will provide a project cost and grant module that will provide for more accurate management and accounting of project funding sources, including those funded with general airport revenue bonds. Unused Proceeds: Aviation agrees with recommendation. In collaboration with City Finance – Treasury, Aviation will prepare a summary of the bond proceeds that are unspent and develop a plan for use of unused bond proceeds. Said plan will be prepared in accordance with the City’s Financial Debt Management and Accounting Policy. City Finance – Treasury will consult with Bond Counsel on Aviation’s proposed plan for unused bond proceeds 32 City of Charlotte, North Carolina Turn Over Review Debt Management - continued Rating Moderate Observation Recommendation 14. Financial, Debt Management and Accounting Policy for the Airport - continued Management’s Response Estimated Completion Date: Aviation will develop an invoice sampling and testing schedule by the end of calendar year 2014. Aviation will meet with the City’s Central Finance – Treasury by the end of calendar year 2014 to define scope of unused bond expenditure plan. Aviation will complete plan for use of bond funds for Bond Counsel review by end of calendar year 2014. Responsible Party: Aviation department in conjunction with the City’s Central Finance - Treasury 33 Process Maps City of Charlotte, North Carolina Process Map Billing and Revenues to include Rental Agreements and Contract Management Revenue and Billing Page 1 of 1 START Prepares billing advice Generate invoice in PROPworks® based on billing advice On periodic basis, compare the active contracts to invoicing parameters to determine accuracy and completeness of invoices and follow-up on identified issues Review nonrecurring invoices to applicable supporting documentation Review monthly/ annual/periodic required reporting Send invoices (electronically via e-mail or mailing hardcopies) Aviation Finance Department Aviation A/R Accountant Contract Administrator City of Charlotte, North Carolina: Charlotte Douglas International Airport Approve credit memo in END PROPworks® Resolve invoice disputes Yes Issue credit memo in PROPworks® Send credit memo to customer Receives payments and reconciles information to PROPworks® Yes Customer No Submit applicable documentation for billing advice preparation – nonrecurring invoices Receives invoice Note: The Aviation Department has documented process maps/workflows of the following areas: phase, invoice dispute, and new customer, contract or agreement. Dispute invoice? Credit memo needed? Submit monthly/ annual/periodic required reporting No PROPworks® overview, invoice payment by Process Step Legend: Automated Control Key Control 34 City of Charlotte, North Carolina Process Map Billing and Revenues to include Rental Agreements and Contract Management - continued Contract Administration Page 1 of 1 Aviation Finance Department City of Charlotte, North Carolina: Charlotte Douglas International Airport Enter contract information into PROPworks® PROPworks® for changes or amendments (Note 1) Aviation Director Process invoices from billing advices Update Approve contract amendment Approve contract END PROPworks® System Aviation Revenue Contracts Administrator Aviation Department START Contract amended Contract executed File hardcopy of contract and attach electronic copy in PROPworks® Electronic copy of contract is uploaded to PROPworks® Monitor compliance with contract requirements (Note 4) Review reports received from lessees for reasonableness Resolve reporting and other contract requirement issues Review and act on reminders from Monitor changes in circumstances affecting contract (Note 2) PROPworks® system (Note 3) PROPworks® is utilized PROPworks® system for tracking contract requirements and other tickler items (Note 1) sends prompts based on information entered Note 1: Contract information includes all contract terms and information requiring future update or monitoring. For example, expiration dates, square footage reviews, index-based rate updates, should be entered into PROPworks® to enable system monitoring and automated reminder functionality. Note 2: Changes in circumstances affecting the contract include early termination, square footage changes, etc. Note 3: The Contract Administrator should involve other finance or business office employees as needed to ensure updates are made in accordance with the contract terms. For example, if a reminder is received that a contract is set to expire, the Contract Administrator will ensure that appropriate parties are involved with drafting and executing a renewal or new contract. Note 4: The Contract Administrator should ensure that required reports are received and that the reports meet the information requirements stated in the contract. Process Step Legend: Automated Control Key Control 35 City of Charlotte, North Carolina Process Map Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting Pay Application Processing, Review and Approval – Internal Project Manager Page 1 of 1 START Generates Pay Application pencil copy Receives pencil copy of invoice City Finance Department Aviation Finance Department Assistant Contracts Director for Coordinator for Development Development Project Manager Inspectors Contractor City of Charlotte, North Carolina: Charlotte Douglas International Airport Concurs on percentage of completion to be paid Reviews invoice for percent completion. Invoice Finalized Inspectors approve invoice, documented by sign-off* Compares the finalized invoice to pencil copy and verify the amounts match to the PM Receives copy of invoice Receives invoice Attends weekly construction meetings Project manager approves invoice, documented by signoff Reviews invoice for proper signatures, certifications, correct funding, reporting requirements met Receives invoice Receives approved invoice Reviews retainage, amount due, funds availability Submits original invoice with support to Aviation Finance Department and files copy of invoice Reviews and approves invoice Inputs invoice information into CIP Database Sends hard copy of invoice to City Finance via interoffice mail Final invoice review and approval Scans invoice into ImageNow system Pays invoice Process Step Legend: Automated Control END Key Control 36 City of Charlotte, North Carolina Process Map Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting - continued Pay Application Processing, Review and Approval – External Project Manager Page 1 of 1 START Generates Pay Application pencil copy Receives invoice Concurs on percentage of completion to be paid Reviews invoice for percent completion. Invoice Finalized Project manager approves invoice, documented by sign-off (Note 1) Receives invoice Attends weekly construction meetings City Finance Department Aviation Finance Department Assistant Contracts Director for Coordinator for Development Development Project Manager, Architect Contractor City of Charlotte, North Carolina: Charlotte Douglas International Airport Note 1: Architect does not sign off to note approval or certification for payment. Reviews invoice for proper signatures, certifications, correct funding, reporting requirements met Receives invoice Receives approved invoice Submits original invoice with support to Aviation Finance Department and files copy of invoice Reviews and approves invoice Reviews retainage, amount due, funds availability Inputs invoice information into CIP Database Sends hard copy of invoice to City Finance via interoffice mail Scans invoice into ImageNow system Process Step Final invoice review and approval END Pays invoice Legend: Automated Control Key Control 37 City of Charlotte, North Carolina Process Map Project Accounting and Capital Asset Accounting, to include Grant Budgeting & Accounting continued Change Order Processing, Review and Approval Page 1 of 1 City of Charlotte, North Carolina: Charlotte Douglas International Airport Signs off on the change order Submits change order request Receives proposal and payment request Initiates change order form and consults with Architect and/or Engineer, as applicable Reviews change order proposal Verbally approves change order Logs change order, verify funding, complete encumbrance forms Logs in final change order Receives final change order for filing Reviews request for encumbrances, proper approvals END Change order >=$100,000? City Council Fully executes No City Manager Reviews change order and supporting documentation (Note 1) Aviation Director Contracts City Finance Coordinator for Department Development Aviation Finance Department Assistant and Deputy Directors for Development Project Manager Contractor START Change order >$50,000? Yes Reviews change order and supporting documentation with internal staff Approves change order Reviews change order and supporting documentation and approve change order Yes Reviews change order and supporting documentation and approve change order Note 1: Change order supporting documentation may include: entitlement determination, cost support, and architect/engineer review and input. No Process Step Legend: Automated Control Key Control 38 City of Charlotte, North Carolina Process Map Contract Facility Charge Contract Facility Charge Page 1 of 1 City Finance Department Aviation Rental Car Finance Concessionaires Department Rental Car Customer City of Charlotte, North Carolina: Charlotte Douglas International Airport Start Executed agreement that includes CFC remittance procedures required reporting Customer executes rental car agreement and drives car off of lot Customer returns rental car System calculates applicable CFC based on pickup and drop off parameters Submit monthly activity reports to Aviation Finance Department Remit preceding month’s CFC revenue to the Trustee by 10th of succeeding month Review monthly activity reports for reasonableness Follow-up with concessionaire as deemed necessary Compare concessionaire monthly reporting to Trustee statement and general ledger Reconcile Trustee bank statement to the general ledger and posts accordingly Submit reconciliation to Aviation Finance Department End Remaining CFC utilized for approved expenditures Process Step Legend: Automated Control Key Control 39 Our Promise to YOU At McGladrey, it’s all about understanding our clients Your business, Your aspirations, Your challenges. 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