To: Karen Collins-Fleming, Director of Environmental Management
Department
From: R. B. "Chips" Shore, Clerk of the Circuit Court,
County Comptroller and Auditor
Date: December 19, 1997
Subject: Environmental Management Department Follow-Up Audit
The Internal Audit Department has completed a follow-up
audit based on the Audit Report of the Environmental Action commission
issued on October 5, 1994. The Environmental Action commission was a local,
independent environmental agency that transitioned into the Environmental
Management Department, a county department, on October 1, 1995. At that
time, al of the programs performed under the independent agency were transferred
to the Environmental Management Department. The follow-up audit consisted
of reviewing corrective actions implemented by the Environmental Management
Department for areas where we provided constructive criticism and recommendations.
Internal Audit did not perform tests of compliance with these newly implemented
controls. We will review compliance during the next regularly scheduled
audit of the Environmental Management Department to determine whether
the controls are functioning effectively and efficiently in accordance
with managements designs and objectives.
Internal Audit found that a portion of the audit concerns
from the original audit were eliminated as a result of the Environmental
Management Department becoming a county department. In addition, the Environmental
Management Department has improved significantly by developing policies
and procedures for programs, complying with personnel issues, and updating
the Comprehensive Plan to better reflect the responsibilities of the Department.
Internal Audit noted, however, that three areas continue to require improvements
by the Environmental Management Department. These areas include the following:
Environmental Management Department does not have the ability
to determine program costs. Internal Audit believes that is essential
for the Environmental management Department to know the cost of its
programs. Accurate program costs will allow management as well as the
Board of County Commissioners to evaluate the cost of maintaining programs
with the benefits provided to the taxpayers of Manatee County. In addition,
management will be able to determine whether user fees are adequate
to cover program costs of whether the county will required to subsidize
a program.
Internal audit recommends the following improvements
to assist management in determining program costs:
Develop a time accounting system that accumulates labor hours
by programs. The Environmental Management Department has implemented
a time accounting system that consists of employees manually completing
on a weekly basis their daily work activity. The system, however,
does not accumulate hours by program; time is accumulated by departmental
divisions. In addition, a review of the reports produced indicated
problems in the accuracy and completeness of information. Although
the current system appears to be inefficient and is not providing
useful information to track program costs, adjustments could be made
to facilitate the process that would result in the production of meaningful
reports.
Charge rates for permits that cover the cost of running the
program. Rates charged for well construction permits fall short
of covering program expenses. Management is in the process of adopting
a new fee schedule that will incorporate changes to well permit fees
as well as other fees charged by the Environmental Management Department.
Environmental Management Department does not consistently monitor
compliance with contracts and standard operating procedures. Internal
Audit believes that contract compliance and adherence to standard operating
procedures are essential to ensure programs are running efficiently
and effectively. In addition, monitoring tools could be developed to
ensure report accuracy. Internal Audit identified the following compliance
concerns where monitoring improvements are recommended:
The Florida Department of Environmental Protection (FDEP) Storage
Tank System Compliance Verification Program. Compliance issues
consisted of the following:
The Environmental Management Department issues noncompliance
letters but does not always obtain the required documentation
on a timely basis.
The facility case file did not always contain a completed Underground
Storage Tank Installation and Removal form for Certified Contractors
and/or documentation of proper notification by the owner/operator
of commencement of closure activities.
A Florida Petroleum Liability Insurance Recovery Program checklist
was not completed for all regulated facilities, regardless of
insurance status.
Ordinance 96-23, The Open Burning Code. Compliance issues
consisted of the following:
Inconsistencies between the language contained in the Code versus
operating procedures regarding when to notify the local fire department.
The language in the operational procedures appears more practical
and is currently the practice of the department.
Permit fees could not always be confirmed to the permit rate
schedule due to incomplete information contained in the permit
documentation.
Justification for permit extensions is not always documented
and operating procedures do not include language for permit extensions.
Development Review Comments. Compliance issues consisted
of the following:
The Environmental Management Department still does not follow-up
on all comments generated on projects reviewed as part of the
Development Review Committee. Management has stated that staffing
constraints have made it impossible to perform site inspections
on all projects that require follow-up. As a result, project selection
for inspection is based on the Environmental Management Departments
judgement, for which risk factors are taken into consideration.
Written standardized procedures for evaluating those factors have
not been established. On projects when the Environmental Management
Department does perform inspections to follow-up on comments,
documentation of the inspections is not made.
Controls over cash receipts need strengthening. Internal Audit
believes that for any cash environment, tight controls are necessary
to ensure that cash is properly collected, recorded and deposited. Internal
Audit suggests the controls be strengthened either by implementing a
system that accounts for and reconciles all pre-numbered cash receipt
forms, centralizing the cash receipt process, or making divisions accountable
for their cash receipts. Internal Audit identified the following areas
where controls over cash receipts could be improved:
Employees of the various divisions of Environmental Management Department
are responsible for collecting the application fees, completing a
cash receipt form and submitting the documentation and the cash to
the Fiscal Section who is responsible for preparing the deposit. The
Fiscal Section does not ensure that all cash receipts are accounted
for.
Pre-numbered receipts are issued when open burn permit applications
are approved, before payment is made. The receipts are completed and
given to the permitees when they pay the permit fee. If payment is
never made, however, the receipt remains outstanding.
Internal Audit recommends that the Environmental Management
Department continue to address the areas that require improvement. By
determining program costs, monitoring compliance with contracts and standard
operating procedures, and strengthening controls over cash receipts, the
Environmental management will function more efficiently and effectively.
Another follow-up audit will be required within approximately six month.
We would like to thank the Environmental management Department staff and
management for their courteous assistance provided to our auditors.
RBS/RJO/MDB
Cc: Board of County Commissioners
Ernie L. Padgett, County Administrator
Manatee County Clerk of Circuit Court and Comptroller