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Home My WebLink AboutFCS-11-133 - Purchasing Card Program Audit & Presentation ) Jb KITCHENER Staff Report Finance and Corporate Services Department www.kitchener.ca REPORT TO: DATE OF MEETING: SUBMITTED BY: PREPARED BY: WARD(S) INVOLVED: DA TE OF REPORT: REPORT NO.: SUBJECT: I Audit Committee June 27, 2011 rCorina Tasker, Internal Auditor, x2361 I Corina Tasker, Internal Auditor, x2361 ALL June 13, 2011 FCS-11-133 PURCHASING CARD PROGRAM AUDIT RECOMMENDATION: For information only. EXECUTIVE SUMMARY: The following report provides a summary of the purchasing card audit performed by Internal Audit and the associated management response. It was not included in the regular Q2 Audit Status Report because the management response was not ready at that time. The objective of this audit is to evaluate the City of Kitchener's purchasing card program against best practice and to test a sample of purchasing card statements for compliance with policy and procedure as a further test of the adequacy of the program controls. While the City's purchasing card program does follow most of the best practices, there is room for improvement in areas of compliance and auditing. More training and better accountability are needed to bring this program up to the highest standards and reduce the risk for fraud. BACKGROUND: Purchasing cards are assigned to individual employees and each employee is responsible for their credit card, although the card balances are paid directly by accounts payable. Each card is assigned a single transaction limit, a monthly spending limit, and a merchant group number which limits which type of businesses the card may be used in. The program does not change the purchase authorization, payment, or competition requirements outlined in the City's purchasing by-law. It is the responsibility of each department to monitor and ensure compliance with procurement rules and regulations. The Purchasing Card Policies and Procedures Guide, including the Cardholder's Agreement Form, details the responsibilities and guidelines for cardholders, accounts payable, and managers. FCS-11-133 Page 1 2-1 In 2010 cards were assigned to 286 employees. Annual purchases for the fiscal year ending Oct.31 , 2010 totalled $1.7M, with an average spend per transaction of $188 and average spend per cardholder per month of $452. Purchasing cards are used to acquire a wide range of products and the use of purchasing cards is generally considered to be an efficient and cost- effective means of payment when compared to normal invoice processing or use of petty cash. REPORT: Status: Complete, Feb.8, 2011 Objective The objective of this audit is to evaluate the City of Kitchener's purchasing card program against best practice using a variety of research methods. A second objective of this audit is to test a sample of purchasing card statements for compliance to policy and procedure as a further test of the adequacy of the program controls. Methodology The following activities were undertaken as part of this audit: . Review of the City's Purchasing Card Policies and Procedures Guide . Review of the U.S. Bank National Association VISA Commercial Card Liability Waiver Insurance Certificate . Review of audit procedures . Review of current cardholder's list . External literature review on purchasing card program best practices . Audit sample of purchasing card statements . I nterviews with key staff 2-2 Summary of Findings, Recommendations and Management Response Finding Recommendation Management Response Timeline Cardholder Application Process The applicant must contact Set the applications form up on Supply Services to work with Sept. 2011 Supply Services in order to be the intranet so that applicants can IT to create online forms sent an application form online. download it themselves rather (which will allow for static than waiting for Supply Services information to not be changed) staff to send them one and will allow staff easier access Cardholders are instructed via Have the purchasing assistant set Supply Services Supervisor to June 2011 email to set up a time with the up the meeting with the buyer and revise work instruction to add buyer to receive training in new cardholders rather than this task to the workflow and order to pick up their card. making the cardholder do the review with the Purchasing scheduling Assistants Statement Audit Process Statements are approved by the Continue to employ a 100% audit See training action plan below. Dec. 2011 employee's supervisor and then of all statements and institute a 100% audit is performed by audit procedures for Operations. data entry staff to check for Operations statements could be compliance. Although this level audited either by the data entry of audit seems excessive, an clerks or by the clerk processing internal audit of 45 random the general and KU statements, statements, representing 25% depending on management of the monthly volume, revealed preference. Ideally they should that 13 statements (or 29%) be audited by the person entering contained policy deviations them into SAP, to avoid multiple which should have been caught handling of the same statement. and corrected through the audit As staff move to the KOF the process. These deviations auditing I data entry function could included things such as missing be done by the group or incorrect supervisor approval, administration function photocopied receipts, missing list of attendees at a lunch event, and purchasing goods for which we have an existing PO. Also, it was found that the Operations data entry staff did not know that they should be auditing the statements. 2-3 There was no consistency in terms of what each data entry staff looked for when auditing statements. Training should be provided to all staff who are auditing to ensure that they are all checking for the same things. Specific training will be developed and delivered by Accounting and Supply Services staff regarding the Purchasing Card Program targeted for cardholders, signing authority and audit staff. Training will include documentation, initial and refresher training which will be delivered as staff are added to the program and on an annual basis. Dec. 2011 Best Practice Assessment Best Practice: Ensure strong commitment and leadership by senior management to ensuring a climate and culture of internal controls and intolerance for unethical behaviour. Senior management as a whole N/A supports a culture of internal controls and intolerance for unethical behaviour. This is evidenced in the People Plan under the "Culture of Community Stewardship" wherein the corporation has committed to being a good corporate citizen through fair and ethical behaviour. The audit sample found no evidence of unethical behaviour. N/A 2-4 Best Practice: Allocate sufficient resources to effectively manage and perform overs~qht of the program. Resources include the N/A cardholder supervisors, 6 data entry clerks, one buyer and one purchasing assistant. (Note, that purchasing cards are not the only duty assigned to these resources). The program appears to be running effectively with this level of resources. However, when Operations moves to a 100% audit of statements, as recommended above, this may put a strain on data entry resources so this should be monitored closely. N/A Best Practice: Be selective in issuing cards and ensure there is an effective approval process in place for issuing new cards in order to limit the exposure of the company. In 2010 286 employees had Directors should periodically Annually, the Program Oct. 2011 purchasing cards or roughly review the business need for all Coordinator will coordinate a 14 % of staff. This indicates that cardholders to assess whether review with each Division to card issuance is selective and is cards are still required. ensure that appropriate staff not given to the employee are in the Purchasing Card population at large. Program. A review of the activity by cardholder for the period May 2010 to October 2010 shows there are 29 cardholders who had no activity during the period. This does not necessarily indicate that the cards are not needed however does indicate that further review is justified. 2-5 It was suggested by staff that Given that the primary and Limiting the program does not Dec. 2011 we should move to having more secondary controls are not take into account the cost to staff hold purchasing cards in effective at this time, it is not process low dollar value order to get away from using recommended to increase the purchase orders or controls petty cash for small dollar number of cardholders in order to related to petty cash. purchases wherever possible capitalize on the card rebates and Supply Services will undertake and in order to capitalize on improve controls over small dollar a further review to investigate card rebates. There is limited purchases. Limiting the number of cost vs. risk related to the risk in terms of fraud as all cards will limit the corporation's expansion of the purchasing fraudulent purchases made on exposure to undetected fraud. If card program. cards, either by employees or if future audits show a lower the card is stolen, will be waived deviation rate then the feasibility by US Bank with zero of increasing the number of deductible based on our cardholders could be examined. insurance policy with them. However, this assumes that the controls we have in place are sufficient to identify the fraudulent purchases in the first place. As was seen in the audit sample 29% of the statements had minor violations which were not caught by either the supervisor or the data entry clerks. This is cause for concern and indicates that the control points are not effective. Best Practice: Establish spending limits commensurate with needs and limit total financial exposure. Monthly dollar value transaction A lower monthly card limit of Having one amount for all Dec. 2011 limits can be no greater than $5000 could be set for the cardholders allows for $10,000. The cardholder list majority of cards in order to limit consistency and less program shows that 87 cardholders the corporation's exposure to maintenance. To reduce (30%) have lower monthly undetected fraud. In addition, multiple program changes in transaction limits, set usually lower limits will mean that one year, we would suggest between $1,000 and $5,000, employees can purchase less and that we leave the monthly limit but sometimes as low as $500. may not be tempted to take the as is until the cost I risk review Only 3 cardholders have higher risk of fraud for such low amounts. and Purchasing Bylaw review monthly limits set between It is recognized that in some on transaction limits are $20,000 and $50,000. instances a higher card limit complete. should be maintained in case of Despite these limits the average emergencies. However, this will monthly spend is only $452. not be the case for all cardholders. Directors should assess this on a case by case basis. 2-6 Individual dollar value Similar to the monthly card limits, The transaction limit has been Dec. 2011 transaction limits can be no a lower transaction limit of $1000 set to follow the Purchasing greater than $2,500 (which is could be set for most cardholders Bylaw which allows for line with the Field Orders). in order to limit fraud exposure purchases under $2500 to be The cardholder list shows that and decrease the incentive for purchased directly by staff. 112 cardholders (39%) have fraud. Directors should assess this Having one amount for all lower transactional limits, set on a case by case basis. cardholders allows for usually between $1000 and consistency and less program $2000, but sometimes as low as maintenance. $200. Only 7 cardholders have This transaction limit will be higher transactional limits set at reviewed as part of the $3,000, $7,000 and $40,000. Purchasing Bylaw review planned for 2011. Despite these limits, the average transactional spend is only $188. Best Practice: Identify appropriate approving officials. They should be sufficiently independent and of sufficient rank to question cardholders about specific transactions. They should each be accountable for a limited number of cardholders to ensure reviews are adequate and timely. The general rule of thumb is approximately 5-7 cardholders each. Approving officials are most The 20 supervisors should The 20 supervisors had Sept. often the cardholder's determine whether they have shared responsibility for the 2011 immediate supervisor but can enough time to lli!!Y..review all of review and sign off related to occasionally be other the statements they are cardholders within their management staff within the responsible for. If not, then it is division. To correct this, each work group, which is consistent recommended that they delegate cardholder will be assigned with best practice. Of the 80 the responsibility for some of the one supervisor which will have authorized approvers, 20 are statements to another supervisor authority to sign and review responsible for greater than 7 in order to ensure there is and one secondary approver cardholders. adequate oversight at this level. which will be the supervisor's supervisor. Training for supervisors will set expectations of what is involved with an appropriate approval. 2-7 Anecdotal evidence suggests Supply Services should Specific training will be Dec. 2011 that some of the authorized periodically remind I train developed and delivered by approvers only verify the validity approvers of their responsibilities Accounting and Supply of a sample of statements while when approving statements. Services staff regarding the approving all of them due to the Purchasing Card Program amount of statements they need targeted for cardholders, to approve. This is a cause for signing authority and audit concern given that this is the staff. Training will include primary control point for documentation, initial and ensuring that purchases are refresher training which will be valid. delivered as staff are added to the program and on an annual basis. It was found that the authorized HR (PeopleSoft) should send Scheduled updates will be March signature list is out of date, Supply Services updates sent every six months by the 2011 explaining the apparent wrong whenever reporting relationships Peoplesoft administrator to the signatures in the audit sample. change so that they can Supply Services Division so proactively update the authorized that the signing authority sheet approver list and send it to the can be reviewed and updated data entry clerks. Currently they as required. are relying on the supervisors to advise them which is clearly not working. Best Practice: Ensure separation of duties. A single individual should not be able to buy, receive, and certify funds for purchases. Cardholders should not be approving their supervisor's claims or be the alternate approver in their supervisor's absence. It was found that a separation of The Fleet administrative Accounting will data enter and Sept 2011 duties conflict exists in the Fleet assistant's statement should be audit the Fleet Administrative area. The Fleet administrative audited by accounts payable staff. Assistant statement. There assistant is responsible for data (Note that this is not because the may be opportunity for the entering and auditing all of the auditor feels the current OperationslUtilitieslFM and statements. However, she also administrative assistant is likely to Fleet statements to be data enters and audits her own commit fraud, but simply to managed in a centralized statement. Although the audit eliminate the separation of duties fashion since they are all now sample did indicate her conflict in the position, regardless located at the KOF. This supervisor did approve the of the incumbent) opportunity will also be statement, there is the potential explored. for the employee to make fraudulent purchases and simply enter them into SAP, without the supervisor ever seeing the statement. 2-8 A separation of duties conflict was identified regarding administrative assistants purchasing items such as conference registrations, hotel reservations, etc for their supervisor on their own card and then the supervisor approving the statement. Although conference expenses would need supervisor approval via the conference form, business travel or other expenses would not, thereby avoiding the scrutiny of the 2nd level supervisor. Administrative assistants (or other staff) who purchase goods or services for their supervisor should use their supervisor's purchasing card where ever possible. If it is not possible to use the supervisor's card then the staff using their own cards should get 2nd level approval of their statement from their supervisor's supervisor. Unfortunately there is limited ability to audit whether this is happening. Therefore this must be set into policy and trusted to employees to carry out. It is against program policy to Sept. 2011 utilize another person's card to make a purchase. Each procurement card has a unique number and is issued in the name of the City and the employee who has been authorized to use the card. Cards are not transferable among employees. If a staff member needs to purchase goods or services for their supervisor (who is the signing authority on their statement), then a secondary approval (from their supervisor's supervisor) will be required on the applicable statement Alternatively, the Supervisor may become a cardholder and process their requirements with their own purchasing card. The program coordinator will review Divisions which only have cards issued to the administrative staff to proactively prevent supervisor's from signing off on purchases made for them. Best Practice: Make training mandatory including educating cardholders on applicable procurement policies, monthly reconciliations and submission requirements and educating approvers on appropriate review of cardholder purchases and reconciliations. Before new cardholders may receive their cards they must attend a 5 minute mandatory training from purchasing staff on the use and restrictions of the card. It includes signing a cardholder agreement form which outlines their responsibilities. There is no follow up training provided and approvers do not receive any training. Supply Services should create and deliver mandatory refresher training for cardholders and approvers on an annual basis. This could be done together as one session or via other means such as email. Specific training will be developed and delivered by Accounting and Supply Services staff regarding the Purchasing Card Program targeted for cardholders, signing authority and audit staff. Training will include documentation, initial and refresher training which will be delivered as staff are added to the program and on an annual basis. Dec.2011 2-9 Best Practice: Use preventative controls such as card limits, pre-emptive blocking from certain vendor cate_qories, and data mininq usinq prowams to identify common theft and fraud patterns. Card limits are in place. All In order to simplify the MCC cardholders were originally set process, block only the high risk up in 1 of 4 groups which had vendor category. This would specific merchant category need to be coupled with the codes (MCC) set up in order to approver training mentioned restrict purchases from certain above to ensure supervisors and types of vendors. However, data entry clerks are trained on legitimate business reasons what they are looking for in terms gave rise to the need to add of inappropriate purchases. back certain MCC's to individual card accesses thereby creating new groups. The total number of groups now equals around 60 which is difficult to administer. The Program Coordinator will schedule and organize an update to the system to update the blocking on each cardholder to reflect only the high risk category being blocked and to ensure consistency across all cardholders. Sept.2011 The City currently does not own any data mining software to analyze purchase history. It is, however, the supervisor's responsibility to review and ensure that all purchases are legitimate. The buyer in Supply Services also reviews the monthly summary report to look for unusual purchases. Best Practice: Establish a multi-faceted approach to monitoring and overs~qht in case the primary approval at the supervisor level fails to detect errors. If the supervisors should fail to adequately oversee the process, two backup procedures are in place. First, staff responsible for inputting the statements into SAP perform a 100% audit, ensuring that all receipts are attached, purchasing rules have been followed, and the appropriate supervisor has signed off. The exception to this is the statements being input for Operations. Their data entry clerk only checks for receipts and signatures and does not verify if purchases are compliant with policy. Second, a buyer in purchasing Given the cost of such software and the City's relatively low purchase history it is not recommended to pursue such software at this time T rain all data entry clerks on what is expected in terms of auditing. No action required N/A Specific training will be Dec.2011 developed and delivered by Accounting and Supply Services staff regarding the Purchasing Card Program targeted for cardholders, signing authority and audit staff. Training will include documentation, initial and refresher training which will be delivered as staff are added to the program and on an annual basis. 2 - 10 reviews the monthly summary report to look for split purchases or purchases which should have been made on existing purchase orders. Best Practice: Clearly outline consequences of inappropriate behaviour prior to issuing purchasing cards and make any actual improper uses and consequences known to show that everyone will be held accountable for their actions. As per the Purchasing Card Policies and Procedures Guide, "IMPROPER USE OF THE CITY PURCHASING CARD MAY RESULT IN DISCIPLINARY ACTION UP TO AND INCLUDING DISMISSAL." However, discipline for non-compliance is very limited and equates to a slap on the hand. Cardholders are informed of their mistakes but nothing is done to follow up or ensure they do not happen again. More accountability is warranted. Accounts Payable should develop a process to track deviations by employee so that repeat offenders can be identified and their supervisor notified. This process should be implemented with all data entry clerks. Accounting management should work with supervisors to progressively discipline repeat offenders as appropriate. Accounting will develop a process to track deviations (limited to approvals, proper receipts and back up etc.) and share this process during the training sessions with the other areas responsible for entry and audit of credit card purchases (Operations, Utilities, FM and Fleet). These findings will be shared with Supply Services so that offenders can be dealt with appropriately by Supply Services. Sept. 2011 Best Practice: Keep controls reasonable and balance the value-add of strict controls with the risk of loss to the corporation. The 100% audit of all statements seems excessive given that the average purchase amount is only $188, the various spending limits set on the cards are low, and supervisors must sign off on all purchases. Furthermore, both the AlP staff and the purchasing staff are looking for split transactions which is a duplication of effort. However, the extra effort of auditing a statement while simultaneously data entering it into SAP is minimal. Also, the amount of deviations found during this audit indicates that the auditing process is not completely Maintain current controls and increase the amount of training for cardholders, supervisors and data entry clerks. If a reduction in workload is required in the future the adequacy of controls can be reassessed and the percentage of statements audited could be re- examined. Specific training will be developed and delivered by Accounting and Supply Services staff regarding the Purchasing Card Program targeted for cardholders, signing authority and audit staff. Training will include documentation, initial and refresher training which will be delivered as staff are added to the program and on an annual basis. Dec.2011 2 - 11 effective. The root cause appears to be lack of training for all involved. Other FindinQs The current contract with US Supply Services should meet with The Program Coordinator will Sept. 2011 Bank provides an approximately the US Bank representative to schedule and organize a 1.8% rebate on the amount discuss this proposition. review of the current payables spent each month. US Bank and opportunities to potentially has offered to analyze the City's expand the program with US overall payables to investigate Bank. the feasibility of allowing other large dollar purchases such as construction contracts to be paid via purchasing card. The potential impact of the rebate on multi-million dollar projects cannot be ignored as it could be used to fund other projects. It was found that the Chandler Chandler Operations data entry Accounting will establish a Dec. 2011 Operations group does not clerks should start to check that mandatory reconciliation ensure that all statements have all statements have been process and provide training to been submitted within the submitted by simply checking Operations, Utilities, Fleet and month. This has the potential to them against the summary file FM so that these areas are distort the financial statements prepared by Accounting. able to reconcile to the as charges will not be monthly credit card statements transferred to the correct cost for their area. centre in the correct period if the statements are delinquent. ALIGNMENT WITH CITY OF KITCHENER STRATEGIC PLAN: Work falls within the Efficient and Effective Government plan foundation area of the Strategic Plan. The goal of Internal Audit work is to protect the City's interests and assets through - ensuring compliance with policy, procedures and legislation - ensuring adequate controls are in place to protect our assets - ensuring our operations are as efficient and effective as possible This helps support the financial goal of long term financial stability and fiscal accountability to our taxpayers. The work also supports the public sector leadership goal of positioning the municipality as a leader in public sector policy, processes, and systems. 2 - 12 ) Jb KITCHENER Staff Report Finance and Corporate Services Department www.kitchener.ca FINANCIAL IMPLICATIONS: NIA COMMUNITY ENGAGEMENT: N/A ACKNOWLEDGED BY: Dan Chapman, DCAO, Finance and Corporate Services FCS-11-133 Page 13 2 - 13 , -c s..... I · co -- C") o-g C") ~ ~ 0)<( ~ I 0 ~ N ~ C I E C/) ... -- I'- en () co N co U- s..... ()) ..c 0) t c () 0 ::J 0 s..... s..... ...., a. ::JQ.. 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