Expense Reimbursements • Purchase Order Transactions • Petty Cash … · 2017. 8. 29. · According to Oracle records, 25 campuses had petty cash balances as of August 2016. These

Expense Reimbursements • Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests • Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements •

Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • Petty Cash • Expense Reimbursements • Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests • Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements •


Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • Petty Cash • Expense Reimbursements • Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests •

Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements • Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • Petty Cash • Expense Reimbursements • Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests •

Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements • Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • Petty Cash • Expense Reimbursements • Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests • Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements •



Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements • Petty Cash • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • P-Card Expenditures • Check Requests • Expense Reimbursements • Purchase Order Transactions • Petty Cash • Expense Reimbursements • Purchase Order Transactions • Petty Cash • P-Card Expenditures • Check Requests •







GARLAND INDEPENDENT SCHOOL DISTRICT Garland, Rowlett and Sachse

972.487.4651 PO Box 469026 Garland, TX 75046-9026

Phrases in (blue) are hyperlinks used by IA to review the audit and for the reader to know from where information came. This is IA Job #16-45.

Internal Audit Department

Steven Martin, CPA/CFF, CFE, CGFM, CGMA, CIGI June 26, 2017 Director of Internal Audit

Independent Auditor’s Report

Performance Audit of District‐wide Campus Transactions Involving Petty Cash, Procurement Card Expenditures, Check Requests, Expense Reimbursements and Purchase Order Transactions Processed in Oracle from February 1 through August 31, 2016

To: Board of Trustees Dr. Deborah Cron, Superintendent

Executive Summary The 2016 Risk Assessment and Audit Plan approved by the District’s Board of Trustees included a District‐wide performance audit of transactions involving petty cash, procurement card (P‐Card) expenditures, check requests, expense reimbursements, and purchase orders (PO) (2016 Risk Assessment and Audit Plan). Internal Audit (IA) identified 60 instances of non‐compliance with criteria in 43 (35 percent) of the 124 reviewed transactions. Additionally, IA counted petty cash at ten campuses. Seven of those had a combined total of $1,072 less cash than the balances in the District’s Oracle records. Campus personnel are under the authority of the Department of Curriculum, Instruction, and Assessment. Business Operations do not supervise campus personnel yet are responsible for the proper recording, receipt, and payment of transactions. A determination should be made between the two departments as to which will monitor school transactions with an enforcement policy regarding campus personnel. Principals should be held responsible for training and monitoring of school personnel. Violations of District policy including purchasing, petty cash, procurement card expenses, check requests, expense reimbursements, and purchase order transactions should result in disciplinary action, possibly including a letter to an employee’s personnel file that would affect one’s evaluation up to removal, depending on the severity of misconduct. Such disciplinary actions should be included in the CDAP. The department monitoring school transactions should prepare a Risk Assessment similar to the Purchasing Department’s Risk Assessment written by Purchasing Director Mark Booker, as seen in Appendix Four, page 71.

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Specifics of 17 findings, along with IA’s recommendations and two observations are included in the Details section of this report.

Table of Contents Page Executive Summary .............................................................................................................. 1 Table of Contents .................................................................................................................. 2 Details .................................................................................................................................... 3 Findings .................................................................................................................................. 3 Observations .......................................................................................................................... 62 Management’s Response ..................................................................................................... 63 Appendix One: 2015‐2016 Salary Schedules and Compensation Information ...... 65 Appendix Two: GISD Staffing and Scheduling Guidelines ........................................ 66 Appendix Three: Duties of the Sachse High School Student Activities Director ....... 67 Appendix Four: Purchasing Department Risk Assessment ...................................... 71 Appendix Five: Criteria Table of Contents: Applicable Portions of the following: 77 Appendix Six: Criteria: Garland ISD Board Policies (Legal) .................................... 78 Appendix Seven: Criteria: Garland ISD Board Policies (Local) .................................... 80 Appendix Eight: Criteria: GISD Campus and Department Accounting Procedures (CDAP) Manual, February 2016 revision .......................... 83 Appendix Nine: Criteria: GISD Purchasing Card Program Employee Manual (P‐Card

Manual) February 2016 revision ...................................... 106 Appendix Ten: Criteria: GISD Field Trip Manual ...................................................... 112 Appendix Eleven: Criteria: Accounting Coding “Frequent Issues” .............................. 119 Appendix Twelve: Criteria: GISD Budgeting / Coding Guide ........................................ 120 Appendix Thirteen: Criteria: Oracle iProcurement Technology PO Directions ............. 122 Appendix Fourteen: Criteria: GISD Intranet Tech Bids‐Printers ...................................... 123 Appendix Fifteen: Criteria: TEA FASRG Module Three. Purchasing Update 14 .......... 124 Appendix Sixteen: Criteria: TEA FASRG 1. Financial Accounting and Reporting Update 14 .......................................................................... 131 Appendix Seventeen: Maintenance Fee Calculation .......................................................... 134

Page 3 of 134

Details Objectives Pursuant to the Internal Audit Risk Assessment approved by the Board of Trustees on January 12, 2016, IA conducted a performance audit of District‐wide campus transactions involving petty cash, P‐Card expenditures, check requests, expense reimbursements and PO transactions in accordance with generally accepted government auditing standards.

Scope IA reviewed 124 campus transactions totaling $449,692, from the audit universe of

15,376 GISD journal debit entries of $100 or more recorded in Oracle from February 1 through August 31, 2016.

According to Oracle records, 25 campuses had petty cash balances as of August 2016. These include two of seven high schools, four of 12 middle schools, 18 of 48 elementary schools, one of two pre‐kindergarten schools, and none of two alternative schools. IA subjectively selected ten of the 25 campuses consisting of two high schools, two middle schools, five elementary schools and one pre‐kindergarten school.

(Auditor’s note: IA did not review February 1 to August 31, 2016 P‐Card transactions that were not yet recorded in Oracle. Additionally, IA did not design this audit to detect un‐deposited revenues.)

Methodology IA reviewed prior campus audits and management’s responses.

IA reviewed 124 randomly selected transactions for compliance with applicable portions of the criteria listed in this report’s Table of Contents as seen on page two. IA interviewed District Directors and personnel from the Business Operation’s Departments of Finance, Purchasing, including Textbooks and Warehouse, Oracle Technology, Payroll and Benefits, IT Operations, Assets and Budget, and Transportation; the Curriculum, Instruction and Assessment Department of Area Directors/School Operations; the Human Resources Department, including Printing Services, and the GISD Education Foundation.

IA conducted ten surprise petty cash counts and reviewed campus petty cash procedures.

(Auditor’s note: IA originally selected a representative sample of 390 transactions for review. Due to the number of violations discovered and the fact that the Superintendent mandated financial training at the District’s Administrator Conference in June 2017, the Director of IA limited this audit after the review of 124 transactions and ten petty cash counts.)

Findings IA reviewed relevant documents and conducted applicable interviews to obtain sufficient and appropriate evidence to provide a reasonable basis for findings and conclusions.

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Finding One Communication between the Departments of Curriculum, Instruction and Assessment and Business Operations is not clear regarding accountability of campus principals for campus non‐compliance with regard to financial transactions. Criteria:

The CDAP Section 1.3, Responsibility for Funds (Appendix Eight, February 2016 revision, page 84) states that the principal is responsible for “proper accounting and administration of transactions,” “expending funds in compliance with state laws and local board policies” and “adequate training and supervision of all personnel managing funds.” The secretary/accounting clerk is responsible for “processing disbursements.” The TEA FASRG, Purchasing Update 14, states, “A district needs a strong control environment in which to perform the purchasing function” and further discusses written procedures, monitoring and oversight (Appendix Fifteen, Control Environment, Sections 3.2.7., 3.3.5., 3.3.3.3., page Nos. 127‐130). The TEA FASRG, Module 4, Auditing, states: Monitoring is “a process that assesses the quality of internal control performance over time.” Ongoing activities include regular management and supervisory activities and other actions taken during the normal performance of an individual’s daily responsibilities.”

The extent to which a manager is held accountable for the effectiveness of control procedures will probably determine the extent to which the manager monitors their performance. Management of a school district should assign responsibility and delegate authority with sufficient care to ensure that:

• Persons who perform control procedures are held accountable for their performance by those who monitor their activities.

• Persons who monitor the performance of control procedures are held accountable by senior management, the board of trustees or the audit committee.

Government Auditing Standards section 3.54 states, “Ongoing monitoring procedures performed on behalf of management are built into the routine, recurring operating activities of an organization. Therefore, the management participation threat created if an auditor performs or supervises ongoing monitoring procedures is so significant that no safeguards could reduce the threat to an acceptable level.” Accordingly, IA is prohibited from monitoring District transactions.

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Condition: IA identified 60 instances of non‐compliance with the applicable portions of criteria referenced in the Table of Contents (page two), in 43 (30 percent) of the 124 reviewed transactions. Communication between the Departments of Curriculum, Instruction and Assessment and Business Operations is not clear regarding accountability of campus principals for instances of campus non‐compliance with regard to financial transactions. Reference is made to prior audits and investigations regarding school violations of the CDAP: Job ID Audit or Investigation

Job 4 Agreed‐Upon Procedures to determine if Webb Middle School was in compliance with the CDAP regarding activity fund deposits

Job 31 Performance Audit of Lakeview Centennial High School Principal’s Financial Transactions from July 1, 2013 through October 31, 2014

Job 15‐30 Report of Investigation regarding cheerleading funds

Job 15‐39 Performance Audit of the Bidding Process when Expending Bond Funds (specifically Finding Three – Services ordered from non‐contracted supplier, and Finding Four – Purchase orders not issued for services totaling $811,312)

Job 15‐50 Performance Audit of Expenditures Ending with Zeros and Vendors with High Frequency Payments (specifically Finding II – Invoice dates prior to PO issuance date)

Job 15‐52 Report of Investigation regarding an unauthorized purchase

Job 17‐11 Performance Audit of Cash Management at Lyles Middle School

Cause:

No monitoring of campus transactions by supervisors was seen. Although employees at campuses stated there was a lack of procedural training or incorrect training for employees, as noted in Findings 6) and 10) of this report, the Business Office offered training to principals, assistant principals, and secretaries/accounting clerks and provided a CDAP Manual. The Purchasing Department distributed Newsletters and provided a Purchasing Card Program Employee Manual (P‐Card Manual). The Area Directors/School Operations Department provided a Field Trip Manual. The manuals and related forms were available on the District Intranet. Currently, during the June 13 and 14, 2017 Administrator’s Conference (AdCon 2017), all administrators were required to attend financial training and all principals were required to attend budget training. Area directors will arrange training for new principals during August 2017, with a presentation from the Finance Department. CDAP training for secretaries and accounting clerks is scheduled for August 8 and 9, 2017, along with August 14 and September 11 computer lab training.

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Effect:

IA cannot determine accountability for campus principals’ “proper accounting and administration of transactions,” “expending funds in compliance with state laws and local board policies” and “adequate training and supervision of all personnel managing funds.” Does responsibility for supervising principals rest with the Department of Curriculum, Instruction, and Assessment or Business Operations?

Recommendation:

Campus personnel are under the authority of the Department of Curriculum, Instruction, and Assessment. Business Operations do not supervise campus personnel yet are responsible for the proper recording, receipt, and payment of transactions.

A determination should be made between the departments as to which will monitor school transactions with an enforcement policy regarding campus personnel. Principals should be held responsible for training and monitoring of school personnel. Violations of District policy including purchasing, petty cash, procurement card expenses, check requests, expense reimbursements, and purchase order transactions should result in disciplinary action. The department monitoring school transactions should prepare a Risk Assessment similar to the Purchasing Department Risk Assessment as seen in Appendix Four, page 71. Policies and procedures affect not only principals, assistant principals, and secretaries/accounting clerks. They are relevant, at the least, for office personnel, sponsors/teachers, librarians, and campus technology assistants/technicians.

Management should sign, and require applicable employees including assistant principals, secretaries, accounting clerks, office personnel, sponsors, teachers, librarians, and campus technology assistants or technicians to sign annual receipts stating that they are aware of District policies and procedures written in the CDAP and P‐Card manuals, similar to the Human Resource Department’s Employee Handbook Receipt. Additionally, IA recommends that supervisors sign an acknowledgement that each employee under their supervision has complied, similar with the Garland ISD Employee Handbook Supervisor’s Acknowledgment.

The same recommendation is made for the Field Trip Manual with signatures from applicable employees responsible for the management and handling of District funds.

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Management’s Response: Department: Curriculum, Instruction and Assessment Responsible Party: Jovan Wells Notes: o If there are concerns regarding principal accountability and non‐compliance

related to financial transactions, the Business Office should alert the Division of Curriculum, Instruction in a timely manner.

o As a result, Area Directors (principal supervisors) will have the opportunity to document and address the non‐compliance related financial transactions.

o Violations of policy including financial related transactions will result in disciplinary action.

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Findings two through 16 pertain to the 124 reviewed transactions and the 60 instances of non‐compliance with criteria (not including surprise Petty Cash counts).

Area Director assignments 2015‐2016 school year

Campus No. of Sampled Transactions (Petty Cash Counts NOT

Included)

Findings as Numbered in Audit Report

No. of Board Policy, CDAP, P‐

Card or FT Manual Violations

% Viola‐tions

Average % of

Violations

Area 1 Janine Fields Garland High School 8 2, 7, 11 6 75%

Austin Academy 3 7 1 33%

Bussey Middle School 3 7, 16 2 67%

Freeman Elementary 2 0%

Golden Meadows Elementary 2 10, 14 2 100%

Hillside Academy 2 0%

Kimberlin Academy 2 7 1 50%

Park Crest Elementary 0 Walnut Glen Academy 1 0%

Williams Elementary 1 0%

36%

Area 2 Wendy Eldredge South Garland High School 3 0%

O'Banion Middle School 2 7 1 50%

Sam Houston Middle School 1 0%

Caldwell Elementary 1 7 1 100%

Club Hill Elementary 1 0%

Daugherty Elementary 2 0%

Heather Glen Elementary 0

Montclair Elementary 0 Roach Elementary 2 0%

Southgate Elementary 2 6 1 50%

25%

Area 3 Gerald Hudson North Garland High School 5 6, 8 2 40%

Jackson Technology Center 2 0%

Garland AEC 0 Beaver Elementary 1 0%

Bradfield Elementary 1 0%

Bullock Elementary 1 0%

Davis Elementary 0 Ethridge Elementary 0

Watson Technology Center 1 6 2 200%

Cisneros Pre‐kindergarten 0 Parsons Pre‐Kindergarten 3 0%

34%

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Area Director assignments 2015‐2016 school year

Campus No. of Sampled Transactions (Petty Cash Counts NOT

Included)

Findings as Numbered in Audit Report

No. of Board Policy, CDAP, P‐

Card or FT Manual Violations

% Viola‐tions

Average % of

Violations

Area 4 Gayle Smith

Lakeview Centennial High School 7 7 2 29%

Classical Center at Brandenburg 3 13 1 33%

Lyles Middle School 5 9 1 20%

Carver Elementary 4 5, 10 3 75%

Couch Elementary 3 10 1 33%

Centerville Elementary 0

Handley Elementary 0

Shugart Elementary 0

Toler Elementary 0

Classical Center at Vial 0

38%

Area 5 Ron Griffen

Naaman Forest High School 4 16 1 25%

Sellers Middle School 0

Webb Middle School 0

Cooper Elementary 0

Hickman Elementary 0

Lister Elementary 3 7 1 33%

Northlake Elementary 0

Shorehaven Elementary 1 0%

Spring Creek Elementary 0

Weaver Elementary 3 7 1 33%

23%

Area 6 Angel Rivera

Rowlett High School 12 2, 6, 7, 8, 11, 14 7 58%

Coyle Middle School 2 11, 14 2 100%

Schrade Middle School 2 0%

Dorsey Elementary 3 7, 14 5 167%

Herfurth Elementary 0

Keeley Elementary 2 0%

Pearson Elementary 0

Rowlett Elementary 0

Giddens‐Steadham Elementary 1 0%

Stephens Elementary 1 16 1 100%

61%

Area 7 Linda Sires

Sachse High School 8 2, 3, 4, 10, 12, 13 13 163%

Memorial Pathway Academy 1 8 1 100%

Hudson Middle School 1 0%

Pathfinder Achievement Center 1 0%

Abbett Elementary 1 7 1 100%

Armstrong Elementary 1 0%

Back Elementary 1 0%

Liberty Grove Elementary 1 0%

Luna Elementary 0

Sewell Elementary 1 0%

40%

Totals 124 60 48%

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Finding Two POs or P‐Cards were not used for six purchases totaling $32,954 for services or tangible items. The six purchases were paid with check requests (six of 18 checks requests IA reviewed, 33 percent).

Criteria: Section 9.1 of the CDAP states, “All tangible items and services, except those excluded in Section 9.4, must be ordered using a Purchase Order (PO) or a Purchasing Card (P‐Card),” and includes an Appropriate Procurement/Payment Method Reference Guide in Section 9.7 (Appendix Eight, February 2016 revision, page Nos. 97‐102).

Condition:

Six of the 18 check requests reviewed (33 percent) were for tangible items or services as follows:

Campus Check Req. ID Supplier Description Inv. Date Amount Notes

Garland High School

58503 Artco Leaded Glass

memorial window – second payment

7/20/16 $4,950.00 The former finance director stated, “There is not an exception for a purchase of this size.” The former assistant finance director “is on maternity leave and unable to provide support on this issue.” (Nov. 9, 2016, email). The former assistant finance director approved the check request in Oracle.

Garland High School

57683 Browning Trophies and Awards

13 “staff awards” “GHS end of year” $48.50 ea.

5/27/16 $630.50 The contract wording is as follows: “Primary Order Method: Main Store; Secondary Order Method: P‐Card”

Rowlett High School

56183 Edible Ideas dba Beyond the Box

Remaining balance – Prom Catering

4/15/16 $19,334.17

Sachse High School

57604 America Team Sports

girls soccer T‐shirts and jackets

2/2/16 $4,420.00

Sachse High School

58796 America Team Sports

Softball uniforms 6/3/16 $3,334.80

Sachse High School

54086 Clay Ewell Educational Services

FFA online subscription

2/11/16 $285.00

Total $32,954.47

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Cause:

District policy was circumvented when campus employees did not enter requisitions for POs prior to ordering services or tangible items, or purchase those items with a P‐Card if applicable. Principals approved check requests instead of requiring POs or P‐Card transactions.

Effect: Bypassing these criteria excluded the Purchasing Department from these expenditures. A Purchasing Department buyer stated, “It is my understanding that there is no formal procedure in place to advise Purchasing of these payments.” These type payments “are not tied to a contract and therefore cannot be tracked against the Purchasing Department’s contract spend reports” (Apr. 26, 2016, email). The purchaser and approver are not expert in purchasing policies and laws. Consequently, they place themselves in jeopardy of violating policy and law when purchasing directly through check requests.

Recommendation:

(Auditor’s note: Prior to the date range of the transactions listed herein, IA conducted a “Performance Audit of Lakeview Centennial High School Principal’s Financial Transactions from July 1, 2013, through October 31, 2014.” The audit included “Check Requests” “Finding One” regarding 14 check requests, out of 104 reviewed, issued for tangible items. IA recommended “employee training and adherence to District purchasing policies and procedures with regard to the purchase of tangible items.” In the prior report, management did not respond to the finding.) Principals should adequately train and supervise “all personnel managing funds” in the “proper accounting and administration of transactions” to expend “funds in compliance with state laws and local board policies” with regard to purchasing tangible items. (Auditor’s Note: On September 6, 2016, the audit report draft of the Bidding Process when Expending Bond Funds from November 4, 2014, to October 31, 2015, was distributed to management and included a finding concerning 51 payments for services totaling $811,312 issued through check requests instead of POs (Finding Four, page Nos. 15‐20).

On September 13, 2016, the secretary to the finance director distributed a revision to the CDAP Manual, Section 9.4, via email to all GISD A‐Locations: The applicable portion of the email follows:

Sent: Tuesday, September 13, 2016 2:42 PM Subject: Revised CDAP Manual

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Good afternoon,

There [have] been a few changes on the CDAP manual.

Section 9: Procurement/Payment Methods

The information highlighted in yellow below previously read Asst. Director of Finance (now Chief Financial Officer) and the text in red is an added item/service a check request can be used to pay.

9.4 Payment Methods – External Suppliers (Pg. 33)

The change to a higher level of approval for exceptions was an improvement; however, on September 15, 2016, IA asked the former finance director, “With regard to the recent changes to the CDAP Manual, can you clarify that “advance approval” by the CFO means in advance of the transaction, purchasing a product, or ordering a service? It does not mean in advance of paying the bill, does it?” On September 16, 2016, the former finance director replied, “It means in advance of paying the bill” (Sep. 15 and 16, 2016, emails). This change did not require discussion with the CFO prior to purchasing a product or ordering a service, in effect allowing employees to continue to bypass Purchasing and gain permission for a check request after the fact, with the possibility that such a purchase “may result in personal liability for the purchase or non‐reimbursement.” IA recommends that the Finance Department clarify the current CDAP statement in Section 9.4 that reads, “Exceptions to the list require advance approval of the Chief Financial Officer.” Advance approval should be written authorization by the CFO before a purchase. Written authorization by the CFO for payment for a prior purchase should be tied to employee discipline.

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Management’s Response: Department: Business Operations Responsible Party: Debbie Cabrera Notes: Two of the selections were purchased out of 800 funds. 1) GHS Artco Leaded Glass $4,950 was from 876 and 2) RHS Edible Ideas dba Beyond the Box $19,334.17 was from 865. We do not require those funds to follow District guidelines. We state the attributes of fiduciary funds in section 1 of the CDAP but we do not reiterate it throughout to prevent from purchasing there and then asking for the expenditure to be reclassed. (Auditor’s Note: We appreciate agreement that payment of four transactions in Finding Two were not in compliance with District policy. Additionally, it would be helpful if the CDAP stated that fiduciary funds are exempt from District guidelines.)

(This portion of the page was intentionally left blank)

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Finding Three Teachers did not sign four GISD Check Request envelopes and one P‐Card envelope. However, principals and the Business Office approved the payments totaling $16,718.

Criteria: Garland ISD Board Policy CAA (Local), Fiscal Management Goals and Objectives, states, “All Trustees, employees, vendors, contractors, agents, consultants, volunteers, and any other parties who are involved in the District’s financial transactions shall act with integrity and diligence in duties involving the District’s fiscal resources” (Financial Ethics). The policy continues, “Each employee who supervises or prepares District financial reports or transactions shall set an example of honest and ethical behavior and shall actively monitor his or her area of responsibility for fraud and financial impropriety” (Financial Controls and Oversight). CAA (Local) also includes, “The Superintendent or designee shall maintain a system of internal controls to deter and monitor for fraud or financial impropriety in the District” (Fraud Prevention). (Appendix Seven, page 80) The CDAP Section 1.3, RESPONSIBILITY FOR FUNDS (Appendix Eight, February 2016 revision, page 84), states that the principal is responsible for “proper accounting and administration of transactions” and “adequate training and supervision of all personnel managing funds.” The secretary/accounting clerk is responsible for “processing disbursements.” Check request and P‐Card envelopes:

Page 15 of 134

The District P‐Card Manual, February 2016 revision (Appendix Nine, page 106) states, “Issuance of a P‐Card represents trust in district personnel and empowers employees to act as responsible fiduciary agents to safeguard and protect Garland ISD. A number of unique controls have been developed for our P‐Card Program. These controls ensure that the cards will be used for only official operational purchases and within specific dollar limits. Improper use of the P‐Card may result in disciplinary action up to, and including, termination of employment.” The section on Purchasing Guidelines states, “As with the other purchasing methods, the following conditions must be met when using the P‐Card:

Each cardholder is responsible and accountable for their P‐Card.

The cardholder is responsible for verifying all purchases and transactions utilizing Oracle iExpense Module.

The person responsible for completing the expense report should view IExpense training: http://lntc02.garlandisd.net/PlayerPackage/data/toc.html.”

The section discussing P‐Card Envelopes/Administrator Approval states, “All transaction receipts must be submitted in the iExpense Receipt Envelope (Attachment 3) and forwarded to the Fund Approver (Principal/Dept. Head) for review and approval (sign‐off/signature). Approval of the contents of the envelope, as evidenced by the Administrator‐signature, shall stand as acceptance of responsibility, and acknowledgement of compliance with District policies (by the Administrator), for all P‐Card transactions submitted for reconciliation.

Page 16 of 134

Once the Fund Approver has reviewed and approved the expense report and support documentation, the envelope should then be forwarded to the Accounts Payable Department.” The completed envelope should indicate “the following:

Printed Name and Signature

Principal/Department Head Name/Signature”

The Record Keeping & Reconcilations section states, “Request for funding a card will be rejected if the school or department has not reconciled the card in accordance with district procedures.”

Additionally, under Compliance Enforcement in the February 2016 revision of the P‐Card Manual, “GISD has established a ‘3‐strikes‐you’re‐out’ methodology for non‐compliance ‐ with the guidelines and procedures of the P‐Card program. All potential violation notices shall be forwarded to the Deputy Superintendent of Business for investigation. If the supervisor was involved by failing to properly reconcile the P‐Card transaction, a strike will also be issued to the administrator.”

Condition: The former Sachse High School accounting clerk signed her name next to the printed names of the employees on four check request envelopes and one P‐Card envelope. Either the former principal or current principal approved the contents of the check request and P‐Card envelopes. The Business Department accepted the one P‐Card and four check request envelopes despite their having been signed by the accounting clerk instead of the teachers. The five purchases are detailed in the following table:

employee named as purchaser

purchase method

violation description amount date

science teacher check request 56199

accounting clerk signed envelope

software licenses

$6,500.00 04/19/16

speech debate teacher

check request 56845


golf event fundraiser

$2,200.00 05/03/16

business education coach

check request 57604


girls soccer T‐shirts and jackets

$4,420.00 05/24/16

PE coach check request 58796


Softball uniforms

$3,334.80 08/09/16

P‐Card holder: career connections teacher

P‐Card IE264168


Baked potato luncheon ‐ staff appreciation

$263.02 05/23/16

Total $16,717.82

Page 17 of 134

Cause:

As noted in Finding 2), the campus submitted three check requests for tangible items or services, bypassing the Purchasing Department against District policy. The campus accounting clerk signed her name for those three purchases totaling $9,954.80, and an additional $6,500 purchase, instead of obtaining the employees’ signatures. The former or current principal signed the envelopes and the envelopes were not rejected by the Business Department for lacking proper signatures. Additionally, the career connections teacher was not required by the former accounting clerk or principal to acknowledge the $263.02 P‐Card purchase with her signature. Instead, the former accounting clerk signed the envelope. According to the P‐Card Manual, the reconciliation envelope should have been rejected, a “Strike 1” should have been issued for the P‐Card reconciliation violation, and the request to the P‐Card administrator to fund the employee’s card should have been rejected.

Effect:

The District does not have verification from the four employees with no signatures that they actually made the purchases that were paid via check requests. By not utilizing internal controls that were in place for those expenditures, the opportunity for collusion existed. Additionally, the principals and Business Department did not require verification for the purchase from the P‐Card cardholder. Without the cardholder’s acknowledgement of the purchase, there was a possibility that the purchase was fraudulent.

Recommendation:

An employee whose printed name is on the first line of a check request or P‐Card reconciliation envelope should sign the signature line to verify responsibility for purchases. The principal’s printed name and signature should verify accuracy of names and signatures as well as administrator approval of the contents in the envelopes.

Management’s Response:

Department: Business Operations Responsible Party: Debbie Cabrera Notes: It was brought to our attention that the envelope is too wordy and confusing. In May 2017 the Business Office redesigned the envelope to make it more clear on who signs where. Although the teacher did not sign the envelopes mentioned, they were approved by the principal. Attached is the redesigned envelope. The ultimate goal

Page 18 of 134

of the Business Office is to have all attachments in Oracle and that is something we will be working on during FY18.


Page 19 of 134

Finding Four Purchase from a non‐contracted vendor Criteria:

GISD Board Policy CH (Local), Purchase Commitments, states, “All purchase commitments shall be made by the Superintendent or purchasing director in accordance with administrative procedures, including the District’s purchasing procedures.” (Appendix Seven, page 80)

The CDAP Section 1.3, Responsibility for Funds as referenced in previous findings (Appendix Eight, February 2016 revision, page 84)

Purchasing policy requires submission of a non‐catalog requisition when selecting a non‐approved supplier for purchases under $5,000 (CDAP Section 10.3.1, Appendix Eight, February 2016 revision, page 103).

Condition: A Sachse High School requisition for a non‐catalog request was not submitted to the Purchasing Department for approval. Instead, check request 54086 was entered in Oracle to issue a payment of $285 to non‐contract vendor “Clay Ewell Educational SVCS” for an Agriculture Experience Tracker (AET) subscription. On February 11, 2016, the District paid $285 to Ewell Educational Services, Inc.

A Purchasing Department buyer stated to IA, “I did not find Ewell Educational Services or Clay Ewell Educational Services approved in our system” “therefore no requisition history could be located” (June 22, 2017, email).

Cause: The principal authorized this expenditure out of compliance with District Purchasing Policy.

Effect: Bypassing this criteria excluded the Purchasing Department from this expenditure. The purchaser and approver are not expert in purchasing policies and laws. Consequently, they placed themselves in jeopardy of violating policy and law when purchasing through a non‐contracted supplier without submitting a non‐catalog requisition through the Purchasing Department.

Recommendation: (Auditor’s note: Prior to this transaction, IA conducted a Performance Audit of Lakeview Centennial High School Principal’s Financial Transactions. In “Check Requests” “Finding Two,” IA noted that seven check requests “were submitted and paid to non‐contracted suppliers without sole source provider determination from the Purchasing Department.” IA recommended “employee training and adherence to District policy and procedures with regard to procurement of goods and services from contracted and sole source suppliers.” In the prior report, management did not respond to the Finding.)

Principals should adequately train and supervise “all personnel managing funds” in the “proper accounting and administration of transactions” to expend “funds in compliance with state laws and local board policies” with regard to procuring services.

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Management’s Response: Department: Business Operations Responsible Party: Debbie Cabrera Notes: The Business Office along with the Purchasing Department will visit each principal and their staff at the start of the new school year so that they are adequately trained on all CDAP policies relating to proper purchasing procedures.


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Finding Five Unauthorized purchase

Criteria: The CDAP Section 1.3, Responsibility for Funds, as referenced in previous findings (Appendix Eight, February 2016 revision, page 84)

CDAP Section 9.1, as attached in Appendix Eight, February 2016 revision, page 97, states, “Issuance of the Purchase Order must precede the ordering of such goods and services. Ordering using any other method is considered a violation of policy and may result in personal liability for the purchase or non‐reimbursement.” CDAP Section 10.2 states, “All purchase commitments shall be made on a properly drawn and issued purchase order,” “in accordance with administrative procedures located in Section 9.4 of this manual. Personnel are not authorized to place orders verbally or utilize any other method to obligate the district.” (Appendix Eight, February 2016 revision, page 102)

Condition: The order date and invoice date preceded the issuance of a PO for fundraiser items:

Campus Vendor Name Amount Requisition PO PO Date Invoice Date Order Date

Carver Elementary

Educational Products, Inc. EPI

$2,698.60 1438714 entered 10/23/2016

5306597

10/26/2015 10/22/2015 10/7/2015

Cause: The campus did not follow District policy when the former campus secretary entered a PO requisition after an order was placed and an invoice issued.

Effect:

The District was unable to set money aside for the unauthorized purchase via a PO and encumbrance accounting.

Recommendation:

(Auditor’s note: Prior to the date range of the transactions listed here in, IA conducted a Performance Audit of Lakeview Centennial High School Principal’s Financial Transactions from July 1, 2013, through October 31, 2014. A “Purchase Orders” Finding noted that 27 invoices, out of 277 transactions reviewed, were dated prior the issuance of POs for the purchases. Management did not respond.) Principals should adequately train and supervise “all personnel managing funds” to requisition POs “in accordance with administrative procedures located in Section 9.4” of the CDAP Manual.

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Management’s Response: Department: Business Operations Responsible Party: Debbie Cabrera Notes: We will continue to train personnel to issue purchase orders prior to obligating the district. I am not sure if we can ever prevent someone from entering a requisition after‐the‐fact, but we can hold them accountable for committing the violation.


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Finding Six Four employee travel expenditures were not supported by Travel Approval Request Forms (50 percent of the eight employee travel expenditures IA reviewed).

Criteria CDAP Manual Section 1.3, Responsibility for Funds, as referenced in previous findings (Appendix Eight, page 84). The CDAP Manual Section 6.1 states, “A Travel Approval Request Form (located on the Business Office intranet) should be used to obtain the necessary advance approvals.” “Upon returning, a Travel Reimbursement Request Form should be filled out and submitted with the necessary supporting documentation and the Travel Approval Request Form as part of the iExpense reimbursement/reconciliation process” (page 91).

Condition:

Travel Approval Request Forms were not submitted for four (50 percent) of the eight employee travel expenditures IA reviewed. Additionally, the submitter and approver did not sign the Travel Reimbursement Request Form.

Campus IE/PO/Ck Request Number

Transac‐tion

Amount Date Description Travel Approval Request Form

Travel Reimbursement Request Form

Notes

Watson Technology

IE257965 expense reimb.

512.32 2/4/16

hotel ‐ TCEA conference

No Travel Reimbursement Request Form not signed/dated by submitter and approver

Campus secretary: “Last year was the first year I had ever done travel. The previous principal had always taken care of that. Therefore, I was not familiar with travel documents pertaining to teacher travel.”

Southgate Elementary

IE259616 P‐Card 296.70 2/24/16 hotel for Kindergarten conference

No Not a reimbursement

Campus secretary: First year and still in process of learning

Rowlett High School

5322356 PO 725.00 3/22/16 Avid Dallas Summer Institute


Former campus accounting clerk: Unable “to find the purchase order. That was before I arrived at this position.”

North Garland High School

56186 check request

5,075.00 4/15/16 “Avid Training Trip” registration


Total 6,609.02

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Cause CDAP Manual travel procedures were not followed. Two campus secretaries felt they were new to the travel approval process. One (now former) campus accounting clerk could not locate any paperwork associated with the PO that was issued before she was hired. The CDAP Manual, Section 1.3, states the principal is responsible for “adequate training and supervision of all personnel managing funds.” The secretary/accounting clerk is responsible for “processing disbursements.”

Effect

The campuses did not have required documented principal approval for the travel expenditures. Travel Approval Request and Travel Reimbursement Request forms are beneficial tools to document training and travel expenditures, and assist supervisors in planning employees’ time away from campuses.

Recommendation

Principals should adequately train and supervise “all personnel managing funds.” Management’s Response:

Departments: Curriculum, Instruction and Assessment and Business Operations Responsible Parties: Jovan Wells and Debbie Cabrera Notes: CIA: o The employee travel approval process will be placed in the principal handbook. o The employee travel approval process will be placed on Area Director agendas to be

discussed with each principal at the beginning of 2017‐2018. o The procedures for submitting travel approval request forms will also be sent to

principals via weekly newsletter.

Business Operations: The Business Office will visit all campuses at the start of the 17‐18 school year to ensure principals are adequately trained on adherence to the CDAP.


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Finding Seven Seventeen field trip transactions were not supported by Field Trip Request Forms or the forms were not signed by all levels of approvers (61 percent of 28 field trip transactions IA reviewed)

Criteria: Section 6 of the CDAP Manual (Appendix Eight, February 2016 revision, page 91) does not reference a GISD Field Trip Manual, although states, “Principals/department heads may institute polices that are more restrictive (not less) than those in this manual – always review location‐specific guidance prior to incurring expenses. The Business Office will consider location‐specific policies in making allowable (reimbursable) expense decisions.” “A Travel Approval Request Form (located on the Business Office intranet) should be used to obtain the necessary advance approvals.” The GISD 2015‐2016 Field Trip Manual (Appendix Ten, page 112) outlines the “Field Trip Process” including “Principal Approval” as evidenced by a Field Trip Request Form. The following statements are included in the TEA Field Trip Guidelines on page No. 25 of the District’s manual:

For audit purposes, your organization must maintain documentation of the field trip and must provide clear evidence of how the expense ties back to an instructional objective. Documentation should include the following:

Destination of each field trip

Costs associated with each field trip

Objectives to be accomplished from conducting the field trip

Teacher’s lesson plan and follow‐up activities Unallowable Costs Related to Field Trips The following costs are not allowable:

Field trips that are not properly documented (as described above) Condition:

Seventeen (61 percent) of the 28 field trip transactions reviewed, including six payments to vendors totaling $30,850, and eleven funds transfers from campuses to the Transportation Department totaling $2,200, were not supported with Field Trip Request Forms, or such forms were not signed/dated by all levels of approvers. Due to a lack of documentation, $14,115 in payments to two vendors were “unallowable costs related to field trips” according to TEA Guidelines included in the GISD Field Trip Manual. Campuses did not provide documentation for the two field trip payments and for six funds transfers, “for audit purposes,” according to the TEA Guidelines. In the other nine instances, documentation on the Field Trip Request forms was incomplete:

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Count Campus IE/PO/Ck Request

Transaction Amount Date Description Field Trip Request Form?

Condition

1 Dorsey Elementary

56148

Check request

1,290.00

2/9/16 2nd grade to Dallas Arboretum and Botanical Gardens: 114 students, 1 teacher, 14 chaperones, 10 parents

N According to the campus secretary, former principal (now retired) kept the forms

2 Dorsey Elementary

PR57717

Check request

12,825.00

5/31/16

Collin County Adventure Camp

N According to campus secretary, the former principal (now retired) kept the forms

3 Austin Academy for Excellence

IE260539 travel card 4,274.55 3/16/16 Airfare ‐World Robotics Competition, Louisville, KY for 6 students and 1 school sponsor

Y Field Trip Request form for out‐of‐state travel not completed by “Director of Program Area.” Area director did not know why document was not forwarded to program director after signing it and before associate superintendent of curriculum, instruction and assessment signed it. Area director stated her secretary no longer works with GISD, “but to the best of my knowledge this form should have had the program director’s signature” (Jan. 19, 2017, email).

4 Bussey Middle School

57339 Check request

2,787.00 5/16/16 Richland Hills, TX (Tarrant County) NRH2O Music Festival entry fees for 125 students and 11 chaperones

Y Form for out‐of‐Dallas County not submitted for signature by area director: Campus secretary provided form and stated, “I just noticed that our band director checked the in Dallas County box. I did not catch that back at the time and it got approved by our principal, but not the area director” (Feb. 17, 2017 email).

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Condition

5 Abbett Elementary

5316711

PO 3,333.92 3/16/16 Graford, TX (Palo Pinto County) Charter bus for 5th grade trip to Camp Grady Spruce for 120 students, 16 parents, 8 school sponsors

Y Out‐of‐Dallas Countyform not signed by area director: Campus secretary said, “In looking at my records, I don’t seem to have the final copy with an Area Director signature on it.” “We have proof our principal sent it in for approval, I guess there wasn’t any follow through. I’m extremely sorry about that, let me know what I need to do.” Area director’s secretary was unable to find the final copy (Feb. 17, 2017 email).

6 Kimberlin Academy

59417‐3 Check request

6,340.00 3/28/16 Austin, TX (Travis County) 4th grade trip: 84 students, 16 parents, 4 teachers

Y Form not signed and dated by sponsor; no date by principal signature

Total Paid to Vendors 30,850.47

7 Rowlett High School

Suburban trip #39841‐1

JE 100.00 8/31/16 Fort Worth, TX (Tarrant County) ROTC trip to NAS Joint Reserve Base on 8/10/16

N According to campus secretary, new group did not know requirements. Instructor email to principal, “We were unaware at the time of the requirement to obtain a field trip approval during the summer and didn’t think to ask since we weren’t taking students out of school. We now realize the district policy requires this approval from the campus administrator or higher, depending on the destination, any time students are taken off campus. Please advise on how to proceed” (April 18, 2017, email).

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Condition

8 Rowlett High School

Bus Trip #31884‐1

JE 240.00

5/3/16 Band marching contest in Mesquite to prepare for UIL 10/3/15

N Inquiry from IA, “To verify, the Mesquite Marching Festival was not an ‘academic or UIL related tournament.’” Campus secretary response: “Correct. It was an event to get ready for UIL” (May 1, 2017 email).

9 Garland High School

Suburban trip #38295‐1

JE 400.00 4/30/16 Lubbock, TX (Lubbock County) trip to Texas Tech University on 4/12/16

N Campus secretary stated, “Going forward the person who does field trip forms will keep them with her other files for 7 years” (Apr. 18, 2017 email).

10 Garland High School

Bus Trip #39182‐2

JE 280.00 5/31/16 Flower Mound, TX (Denton County) Class of 2016 trip to Circle R Ranch on 5/23/16: 200 students, 14 parents, 1 school sponsor

Y Two forms provided: First: not marked “Out‐of‐Dallas County,” not signed/dated by sponsor, principal, area director Second: not marked “Out‐of‐Dallas County,” not signed/dated by sponsor/area director

11 O’Banion Middle School

Bus Trip #37844‐2

JE 120.00 5/31/16 Denton, TX (Denton County) 5/23/16 trip to UNT: 88 students, 11 school sponsors

Y Form not dated next to principal and area director signatures

12 Lakeview Centennial High School

Bus Trip #39245‐1

JE 120.00 5/5/2016 Band trip to Rowlett residential address for WFAA news story about reconstruction after the 12/26/15 tornado

N Campus accounting clerk wrote, “This entire paperwork process was new to us last year so our records are not that great. We have done better this year and hopefully we will be great next year.” *See additional note below:

* Campus accounting clerk continued, “Just a side note. Something that I have found is that so many people have access to enter bus trips. We have had a few that enter their trip and never fill out the required paperwork and it goes un‐noticed. I normally enter bus trips and have required the field trip paperwork this year but that has been an issue. Any advice would be appreciated” (April 21, 2017, email).

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Condition

13 Lakeview Centennial High School

Bus Trip #39245‐2

JE 120.00 5/5/2016 Band trip to residential address for news story about reconstruction after tornado

N See previous

14 Dorsey Elementary

Bus Trip #38180‐2

JE 240.00 5/10/2016 Kindergarten trip to Dallas Zoo for 104 students, 25 parents, 5 school sponsors

Y Form not signed and dated by sponsor

15 Weaver Elementary

Bus Trip #38344‐1

JE 150.00 5/11/2016 Second grade trip to Blasé Family Farms in Rockwall, TX: 74 students, 4 parents, 4 teachers

Y Form not signed and dated by area director for Out‐of‐Dallas County trip

16 Caldwell Elementary

Bus Trip #37523‐2

JE 210.00 4/27/2016 Frisco, TX (Denton County) fifth grade trip to Frisco Roughriders Dr. Pepper Ball Park for 86 students and 9 teachers

Y Form not signed and dated by sponsor; Form incorrectly marked as “In Dallas County,” and not signed and dated by area director for “Out‐of‐Dallas County”

17 Lister Elementary

Bus Trip #38560‐2

JE 220.00 5/4/2016 Tyler, TX (Smith County) Fifth grade trip to Pine Cove – The Timbers

N form was not completed

Total funds transfers 2,200.00

(Auditor’s note regarding additional required Field Trip documentation: The Hillside Academy campus secretary provided a completed Field Trip Request Form for an out‐of‐Dallas County Camp Grady Spruce student trip that occurred during the 2016‐2017 school year. The form was signed by the sponsor, principal and area director. Additional required forms per the GISD Field Trip Manual (Appendix Ten, page 112) were not located: “*Completed requests include: Field Trip Checklist, Field Trip Request Form, Activity Fund Fundraising Application and Financial Recap, transportation documents, and one copy each (in English and Spanish) of the Itinerary, the Parent/Guardian Approval and Release Form.” IA did not request the additional required forms from other campuses.)

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Cause:

Campus personnel did not complete or did not maintain eight Field Trip Request forms.

Nine Field Trip Request forms were not signed/dated by all levels of approvers.

According to the Lakeview accounting clerk, “so many people have access to enter bus trips.” Lack of required Field Trip paperwork goes un‐noticed (April 21, 2017 email).

Effect:

Due to lack of proper documentation, two vendors were paid in violation of TEA Guidelines.

In eight instances, Field Trip documentation per the GISD Field Trip Manual and TEA Field Trip Guidelines contained therein was not available for audit purposes.

There is no proof of required field trip approval in the nine instances of incorrectly completed or incomplete Field Trip Request forms.

Recommendation:

IA recommends continued training of all employees responsible for entering, approving, processing transactions, including all employees with access to enter Suburban/Bus Trips in the Compass Field Trip Software Program.

The Finance Department and Curriculum, Instruction and Assessment Department should coordinate policies and reference those policies in their respective manuals.

(Auditor’s Note: With regard to documentation not maintained on campus, refer to Finding 14), page 49.) Management’s Response: Departments: Curriculum, Instruction and Assessment and Business Operations Responsible Parties: Jovan Wells and Debbie Cabrera Notes: CIA: o All level approvers will receive Field Trip Request form training during a Curriculum,

Instruction and Assessment meeting. o Campus principals will also receive information related to Field Trip Request form

requirements in the principal handbook. o The Field Trip Request Form approval process will also be placed on Area Director

agendas to be discussed with each principal at the beginning of 2017‐2018. o The procedures for submitting Field Trip Request forms will also be sent to principals via

weekly newsletter.

Business Operations: Reference to the Field Trip Manual has been added to the CDAP.

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Finding Eight Three printers were not shipped to the Marvin D Roden Technology Center and not included in GISD technology inventory – total value of $7,542 (43 percent of seven technology transactions IA reviewed)

Criteria: The GISD Oracle iProcurement Technology Purchase Order Directions PO Check List states, “Change the Delivery information in the Deliver To Location box to read Technology Center except for Data Drops. This is for configuration and installation purposes.” (Appendix Thirteen, page 122) “Special Notes” included in GISD Intranet Tech Bids – Printers states, “All printer/scanner products ordered must be shipped to the District’s Technology Department for configuration prior to delivery and installation to your department/school” and, “Shipping Instructions: Change the Deliver‐To Instructions on ALL Technology equipment to read Dr. Marvin D Roden Technology Center. This is for configuration and installation purposes.” (Appendix Fourteen, page 123)

Condition: Three out of seven technology transactions (43percent) IA reviewed were for printers that were not shipped to the Marvin D Roden Technology Center as required per GISD Oracle and GISD Intranet instructions. As of December 12, 2016, the GISD technology inventory did not include the printers purchased in April and June 2016 for a total of $7,542:

Campus Item Description PO Invoice Ship To

Address on Invoice

Invoice Date

Amount Printer Tagged?

Included in Technology Inventory?

North Garland High School

HP designjet T520 Eprinter

5330337 CSG4678 2109 W Buckingham Rd, North Garland HS

14‐Apr‐16 2,445.10 Yes No

Rowlett High School

HP LASERJET PRO M402DN PRINTER including three year warranty

5331932 CVZ3803 4700 Kirby Rd, Rowlett HS

27‐Apr‐16 247.16 No No

Memorial Pathway Academy

HP DJ T930 36IN Postscript Printer

5338773 DNP9046 2825 S 1st St, Memorial Pathway Academy

30‐Jun‐16 4,850.00 No – CTS stated she was tagging the printer

No

Total 7,542.26

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Cause: The former Rowlett High School accounting clerk said she thought the technology coordinator for the campus reviews the POs and would have caught the shipping address. The Memorial Pathway Academy campus secretary said that upon her receipt of printer delivery notification from CDW Government, the technology coordinator requested direct delivery to the campus. An IT specialist set up the printer at the campus (Dec. 14, 2016 interviews). The assistant director of IT Operations, Assets and Budget stated, “Ordering instructions are listed on the GISD Intranet which includes that all printers are to ship to Technology for inventory tagging and configuration / installation” (Dec. 16, 2016 email). The assistant director of IT Operations, Assets and Budget said technology coordinators review POs to try to “catch” orders that are not changed to ship to Technology; however, they do not always catch those orders. At that point, the tagging process falls to the campus technology assistant/specialist (CTA/CTS). Technology usually receives a request, after equipment delivery, to install and configure devices (Dec. 13, 2016, interview). Additionally, IA observed that the CDAP Manual, Section 9.2: Purchase Orders, offered no instruction regarding the “Ship To” site for technology purchases (i.e., cameras, tablets, data drop, computers, printers).

Effect:

Unaccounted inventory could be missing. The director of IT Operations, Assets and Budgets stated, “Tasks still actively being worked as we speak include: ‐ Oracle Purchasing to TipWeb‐IT integration ‐ currently being tested with our vendor; ‐ IT Asset Management (ITAM) Policy Manual ‐ currently drafted but still needs revision and additional content before publishing. All that said, I expect to be wrapping up on these activities in the 1st quarter of the 2017 calendar year” (Dec. 13, 2016, email). (Auditor’s note: TIPWeb‐IT School Asset Management Software is used by the District to track inventory.)

Recommendations: IA recommends internal control teamwork as follows: Campuses comply with Oracle and Intranet instructions for technology

purchases Technology coordinators conduct quality review of PO shipping addresses Tag IT equipment and enter into inventory upon receipt Update the CDAP Manual to include specific ordering and shipping

instructions for technology purchases

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Management’s Response: Department: Technology Responsible Party: Donna Eurek Notes: We agree with the findings and recommendations. Please note that tasks previously noted to be in progress a) Oracle Purchasing to TipWeb‐IT integration and b) IT Asset Management (ITAM) Policy Manual have since been completed. The ITAM Policy is being incorporated as a separate section of the CDAP Manual.


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Finding Nine

No tracking mechanism for transport of a Chromebook

Criteria: The District has millions of dollars of inventory in computers and similar equipment. Due to the cumulative value and high propensity toward theft or loss of technology equipment, the District needs to track transport of the equipment. The TEA FASRG, Financial Accounting and Reporting Update 14, Sections 1.2.4.2. Basis of Capital Assets, states, “a school district may wish to maintain accountability for certain capital assets even if they do not meet the school district’s capitalization policy. For example, certain audiovisual or computer equipment may not be capitalized (i.e. not recorded as capital asset); however a listing of such assets and their location may be maintained for control and accountability purposes. This is common for items with a higher risk of theft (easily transportable or marketable or diverted to personal use)” (Appendix Sixteen, page 131). The District purchased TIPWeb‐IT School Asset Management Software to track such assets.

Condition: On February 2, 2017, IA met with the CTA at Lyles Middle School to confirm the school’s possession of a Chromebook laptop computer listed on an invoice in IA’s sample selection. The Chromebook was not located and the CTA said the Chromebook might be at the Technology Center. On February 3, at approximately 9:14 a.m., IA received an email from the CTA stating that the field service technician confirmed the Chromebook was at the Technology Center for repair (Feb. 3, 2017, email). On that same date, at approximately 10:00 a.m., IA visually confirmed that the Chromebook was at the Technology Center. On February 7, IA interviewed the technology coordinator, field service lead, and field service technician (Feb. 3, 2017, interview). IA received three Chromebook records from TIPWeb: 1) GISD Ticket #141516, 2) Technology Transfer Ticket – Transfer Number 8077, and 3) IT‐A08992 LifecycleReport:

1) Monday, January 30, 2017, 1:58 p.m., Lyles CTA submitted Ticket #141516

2) Tuesday, January 31, 3:00 p.m., field service technician updated the GISD Ticket #141516 status from “Assigned Not Updated” to “On Hold”

The field service lead said TIPWeb is the mechanism to show where the Chromebook is located. When he receives service call sheets from campuses, the field service technician’s response takes a half‐day to a full day.

The field service technician said he picked up the Chromebook and brought it back to Technology late in the workday on the same date. Because it was late, he did not

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scan the Chromebook into TIPWeb. He attended training the next two days and scanned the Chromebook in TIPWeb on returning from training.

However, it was not until Friday, February 3, the “Technology Transfer Ticket” with “Transfer Number 8077” was created by the field service lead to transfer the Chromebook from Lyles Middle School to the Technology Center. The technology coordinator said transfer tickets are not printed for signatures because the document is in TIPWeb (February 8, 2017, email).

Following IA’s visit to the Technology Center on Friday, February 3, the field service lead had updated the Lifecycle Report showing the Chromebook was removed as a component and in transit from Lyles MS on February 3 at 10:22 a.m., then received at the Dr. Marvin D Roden Technology Center at 10:25 a.m. on that same date:

Event Date

Event Name Tag Status Tag Site Update Tag Location Update

Event Details

01/06/2017 11:53 AM

Added as Component

Available 051-Lyles Middle School

Room: RM05114-E2

2/3/2017 10:22 AM

Removed as Component

Parent Tag: IT-B10863

2/3/2017 10:22 AM

Added to Transfer

In Transit Transfer: 8077

Destination Site: 926-Dr. Marvin D Roden Technology Center

2/3/2017 10:25 AM

Received on Transfer

In Repair 926-Dr. Marvin D Roden Technology Center

Room: 19947

Cause: The Chromebook was not scanned into TIPWeb until February 3, following IA’s visit to the Technology Center. The field service lead said there are no written procedures for field services. Effect: The Chromebook was unaccounted between 3:00 p.m., January 31, and the morning of February 3. Unaccountability of equipment could lead to equipment being replaced, lost or stolen. Recommendation: The IT Department should track the transport of technology assets “for control and accountability purposes” and finish the Procedures Manual. Feb. 3, 2017, interview:

The technology coordinator said that implementation of a new service ticket process was scheduled to begin the week of February 13, 2017.

The technology coordinator said that the director of IT Operations, Assets and Budgets is working on a procedures manual.

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Management’s Response: Department: Technology Responsible Party: Donna Eurek Notes: We agree with the findings and recommendations. The ITAM Policy Manual has been completed and addresses this finding under the section regarding Managing Asset Movement.


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Finding Ten Systemic issue – Principals’ approvals and reviews of fundraisers were undocumented

Criteria: Fundraising guidelines and procedures in the Fundraising Section of the CDAP focus on the campus principals’ responsibility to document their approval of fundraising activities in advance and review the financial recap of fundraisers. Responsibilities of the sponsors and secretaries/accounting clerks are also addressed. Required forms are the Activity Fund Fundraising Application and Financial Recap Form (CAP‐122), and the “Log of CAP‐122 Forms issued” (CAP‐123). (Appendix Eight, Section 3, page Nos. 85‐87)

Condition:

All five fundraiser transactions reviewed in IA’s sample (100 percent) were not supported by an Activity Fund Fundraising Application and Financial Recap Form (CAP‐122) and/or a Log of CAP‐122 Forms issued (CAP‐123):

Campus Invoice Inv. Date

Vendor Amount CAP‐122 CAP‐123

Sachse High School

CK Req. 56845

9/30/15 American Golf Corporation

$2,200.00 No No

Couch Elementary IE263356 4/28/16 Scholastic Book Fair

$4,555.94 Yes No

Golden Meadows Elementary

IE264102 3/30/16 Educational Products, Inc.

$2,407.49 No No

Carver Elementary

IE262291 4/19/16 Scholastic Book Fair

$4,292.72 No No

Carver Elementary

PO 5306597

10/22/15 Educational Products, Inc.

$2,698.60 Incomplete: former secretary signed as “sponsor” with 1) no principal approval 2) no expected net income 3) no end date 4) no financial recap

No

total $16,154.75

Cause: Sachse High School

The teacher/sponsor described the golf tournament fundraiser to IA, but did not comply with the CDAP requirement for a CAP‐122 form (Nov. 9, 2016, email).

The student activities director stated that she did not receive a CAP‐122 form for the event (Jan. 19, 2017, email). Additionally, the student activities director stated in an email to IA, “They are supposed to start with me. I verify that I have the fundraiser scheduled on my calendar and that it is an approved fundraiser. I initial and it goes to our principal to sign. Once he signs it goes back to the sponsor to fill out the bottom section once the fundraiser is over. They fill out the bottom and turn back in once it is over. We have so many ongoing fundraisers and this CAP 122 form is a form they struggle with on starting and turning in. They schedule through me and

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get it approved but the form doesn’t always make it to the very end” (Jan. 23, 2017, email).

IA did not receive documentation to show that a CAP‐123 log was maintained by the former accounting clerk to track the number of fundraisers held by each student group.

Couch Elementary:

The former campus secretary confirmed that she did not complete the “Log of CAP‐122 Forms issued” (CAP‐123). On January 10, 2017, the former campus secretary wrote, “In years past, when discussing fundraisers, it was mentioned that it is usually secondary [campuses] that keeps a log, as elementary [campuses] didn’t do that many fundraisers but if we did many then we should. Couch [Elementary] didn’t do but 1‐2 a year max. I even asked several other elementary secretaries at the time and they didn’t do the log either due to that reason.”

In a follow‐up email, the former secretary wrote, “If memory serves, it was usually presented as, this is mostly used at the secondary level due to all the student groups and departments that do fundraisers. Elementary campuses don’t have but 1‐2 a year and it is easy to keep track of the forms. I think that is where confusion lies.”

On January 10, 2017, the Finance Department campus accounting liaison responded, “I do not recall that ever being said nor do I recall it being asked. The purpose of the CAP 123 is to assist the principal in tracking the fundraisers happening on their campus. Secondary campuses have a much higher volume of fundraisers and this form was designed with them in mind” (Jan. 10, 2017, emails from the former secretary and the campus accounting liaison).

Golden Meadows Elementary:

IA received the following response from the current campus secretary, “The Secretary and Principal have both since left. I have gone through the box of copies etc. from last year and was not able to locate it” (Jan. 6, 2017 email).

Carver Elementary:

IA received a response from the current campus secretary stating she was new along with a new campus librarian. The campus secretary stated that she provided the items she had (Feb. 15, 2017 email).

Effect: IA was unable to determine that expenditures, and profits or losses, for the fundraisers were approved or reviewed by the Principal. By not completing the CAP‐122, there was no indication of principal approval, fundraiser purpose, or taxable status for the fundraiser, and by not completing the CAP‐123, there was no record of the number of fundraisers by student group.

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Recommendation: Administrative control over fundraising activities should be documented by completion of forms CAP 122 and 123 for all campus fundraising activities. The principal, sponsor and secretary/accounting clerk should comply with policies and procedures as instructed in the CDAP manual. Fundraisers should be monitored on each campus for compliance with the CDAP. To facilitate these recommendations, the principal should enforce campus awareness of District policy regarding fundraisers, and the Finance Department should consider offering required online training for fundraisers, to include training for principals and sponsors to access Oracle activity fund reports for their campuses.

Management’s Response: Department: Curriculum, Instruction and Assessment Responsible Party: Jovan Wells Notes: o The required process and forms for Principals’ approvals and reviews of fundraiser

will be placed in the principal handbook. o The Principals’ approvals and reviews of fundraiser process will be placed on Area

Director agendas to be discussed with each principal at the beginning of 2017‐2018. o The procedures for submitting Principals’ approvals and reviews of fundraiser will

also be sent to principals via weekly newsletter.


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Finding Eleven Systemic issue: Evidence of Student Group approval for the four Student Activity Fund 865 expenditures totaling $21,969 IA reviewed (100 percent) was not available. CDAP Manual requirements were unclear regarding documentation.

Criteria: Board policy CFD (Local) seen in Appendix Seven, page 81, states, “Funds collected by student groups shall be used only for purposes authorized by the organization or upon approval of the sponsor. The principal or designee shall approve all disbursements” (emphasis added). However, CDAP, Section 1.2, seen in Appendix Eight, February 2016 revision, page 83, describes Student Activity Fund 865 as Agency Funds generated and controlled by student groups (governed by an elected body) and states, “Expenditures must be approved by group, sponsor, and principal and be for the benefit of the students” (emphasis added).

Condition: A requirement is included in the CDAP Manual for student group, sponsor, and principal approval for Fund 865 expenditures. This statement does not explain documentation for such approval. However, Board Policy CFD (Local) requires that funds collected by student groups be used only for purposes authorized by the organization or approved by the sponsor. Based on the CDAP Manual requirement for student group approval for expenditures, IA asked campuses for documentation of student group approval for the four Student Activity Fund 865 transactions IA reviewed (100 percent). Evidence of student group approval was not available:

Campus Vendor Payment ID Date Amount Fund Description Notes

Coyle MS

FCA Camps Check Request 54111

4/14/16 $2,090.00 865 2016 FCA Weekend of Champions Registration

No documentation of student group approval – sponsor no longer employed at Coyle MS

Rowlett HS

Edible Ideas Inc dba Beyond the Box

Check Request 56183

4/15/16 $19,334.17 865 Rowlett Class of 2016 – balance on prom package

According to campus accounting clerk: per the sponsor, there are no written minutes for the approval.

Garland HS

Garland High School Culinary Arts Catering

JE for Invoice OP‐122

5/16/16 $265.00 865 Catering for Leadership Banquet

Garland HS

Garland ISD Transportation

JE for Bus Trip #39182‐2

5/31/16 $280.00 865 Class of 2016 Bus trip to Circle R Ranch

According to campus accounting clerk, no one can find an approval form for the field trip

Total $21,969.17

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Cause:

The CDAP manual does not offer instruction for documentation of student group approval for expenditures. Additionally, Board policy CFD (Local) states, “Funds collected by student groups shall be used only for purposes authorized by the organization or upon approval of the sponsor. The principal or designee shall approve all disbursements” (emphasis added).

Effect:

In the event of an inquiry from a student or parent regarding expenditures of funds raised by the student group, there is no record to verify student group approval.

Recommendation:

The CDAP Manual should match District Board Policy CFD (Local) which states, “Funds collected by student groups shall be used only for purposes authorized by the organization or upon approval of the sponsor. The principal or designee shall approve all disbursements” (emphasis added). However, if the student group approval is still required, the CDAP Manual should be updated to clarify documentation of approval for Student Activity Fund 865 expenditures.

Management’s Response: Department: Curriculum, Instruction and Assessment Responsible Party: Jovan Wells Notes: o The Student Group approval for Student Activity Fund’s process will be placed on

Area Director agendas to be discussed with each principal at the beginning of 2017‐2018.

o The procedures for Student Group approval for Student Activity Fund’s process will also be sent to principals via weekly newsletter.

o I concur with the audit recommendation: “The CDAP Manual should match District Board Policy CFD (Local)”


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Finding Twelve GISD Board of Trustees approved an annual stipend of $938 which was not paid to a student activities director for the 2015‐2016 school year, and as of March 31, 2017, was not paid for the 2016‐2017 school year. There is no District‐wide description of student activities director duties.

Criteria: As attached in Appendix Seven, GISD Board Policy DEA (Local) states, “The Superintendent shall recommend an annual compensation plan for all District employees. The compensation plan may include wage and salary structures, stipends, benefits, and incentives. The recommended plan shall support District goals for hiring and retaining highly qualified employees. The Board shall review and approve the compensation plan to be used by the District” (page 82). Board Policy DEAA (Local) states, “The Superintendent shall recommend a stipend pay schedule as part of the annual compensation plan of the District” (page 82).

The Board of Trustees approved the 2015‐2016 budget during the August 25, 2015 Board of Trustees Regular Board Meeting (Item 12, pdf page No. 6), which included 2015‐2016 salary schedules and compensation. According to the GISD 2015‐2016 Salary Schedules and Compensation Information, page No. 20, High School activities directors were to receive an annual stipend of $938 during the 2015‐2016 school year (Appendix One, page 65). The only District‐wide criterion for this additional responsibility was the number of classes, activity periods and conferences assigned for the “Assignment of Sponsors of Co‐Curricular Activities” (Appendix Two, page 66) (GISD Staffing and Scheduling Guidelines, page No. 7).

Condition:

The Sachse High School (SHS) student activities director was not paid the established $938 stipend as outlined in the GISD 2015‐2016 Salary Schedule, and as of March 31, 2017, was not receiving payment of the stipend. During a January 24, 2017 interview, the SHS student activities director verified that 2014‐2015 was the last school year she received a stipend for the position of Student Activities Director (Interview with student activities director). However, teachers assigned the position of GISD High School student activities director at the following high schools were paid an annual stipend of $938 for the 2015‐2016 school year and were scheduled for payment of $938 for the 2016‐2017 school year, as of January 24, 2017. (Oracle document of all payments scheduled for position of Activities Director as of Jan. 24, 2017):

Garland HS Lakeview Centennial HS Naaman Forest HS

North Garland HS Rowlett HS South Garland HS

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Also, there was no District‐wide description of the position of student activities director. Additionally, High School student activities directors’ fundraising responsibilities were not addressed in the CDAP manual. IA requested a written description for student activities directors from the following departments. Responses:

Human Resources: “All stipends are outlined in the GISD Salary Schedule. Each principal selects the Activities Director for their campus” (Jan. 24, 2017 email from executive director of human resources). (Auditor’s note: The referenced document lists stipend amounts; There is not a definition of student activities director responsibilities. See Appendix One, page 65) “The stipend is $938 with 5 additional contract days. I do not see any description of what the responsibilities are or requirements for receiving this” (Mar. 29, 2017 email from the human resources specialist to the Sachse High School principal’s secretary).

Area Directors/School Operations: Referred IA to Payroll (Jan. 23, 2017 email from area director’s secretary)

Payroll: “Payroll does not have descriptions of responsibilities” (Jan. 23, 2017 email from payroll and benefits office manager).

Sachse High School: Assistant principal:

“We use the GISD Salary Schedules and Compensation Information manual. On page 19 the stipend amount is listed for Activities Director” (Jan. 24, 2017 email). (Auditor’s note: As stated above, this document does not contain a definition of student activities director responsibilities.)

Student activities director: No answer regarding written procedures; however, she provided a description of her duties with regard to fundraisers (Jan. 23, 2017 email).

Principal’s secretary: Provided “campus based” “Duties of Sachse High School Student activities director” (Appendix Three, page Nos. 67), and stated the document was authored in 2015 by the former principal (Jan. 23, 2017 email).

Cause:

The stipend elimination was an administrative decision, usurping the Board of Trustees’ authority. An April 27, 2015 memo was distributed to High School Principals as follows:

“In our meeting on April 24, 2015 we discussed the following items and the changes that must to [sic] be made at your campuses beginning with the 2015‐2016 school year and beyond: 1) Activities Coordinators: Activities coordinators will teach a total of 4 sections

and receive an extra conference period for activity coordinator duties. If the

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activity coordinator chooses to receive a $750.00 stipend, the coordinators must teach a total of 6 sections and will not receive an extra conference for activity coordinator duties. Do NOT double dip stipend and conference periods. They may receive one or the other only.” (portion of memo referencing “Activities Coordinators”)

On September 15, 2015, a PAR was generated in the Human Resources Department and the Payroll Department was instructed to “Delete Activities Director $750 stipend” for the SHS student activities director.

On March 29, 2017, the SHS principal’s secretary contacted the Human Resources Specialist asking, “Does the student activities director get a stipend and if so what are the stipulations?” In a follow‐up email the SHS principal’s secretary stated, “Ours is not receiving a stipend because she has Student Activity periods. It was taken from her a couple years ago, 2015 I believe. So, she should be receiving it even with the student activities periods correct?” The former secretary to the director of secondary human resources answered, “I believe at the time of this change, they were to get the stipend or an extra period.” The SHS principal’s secretary replied, “Yes, I believe that is correct. Did that change? If so, can I submit a PAR to re‐instate that? Will it be retro‐active?” The former secretary to the director of secondary human resources answered, “No, they either get the extra period or they get the stipend. They can’t get both” (March 29, 2017 emails). In an email to the SHS principal’s secretary dated March 31, 2017, the director of position administration budget stated, “For some reason her [SHS student activities director] stipend was removed, so I am trying to see if I can add it back.” On that same date, the SHS principal’s secretary replied, “We were told if she had a student activity period she couldn’t have her stipend.” On April 4, 2017, the director of position administration budget replied, “I entered the par today to add the stipend back in. I asked for a retro to August of 2015 when it was taken away” (March 31 through April 4, 2017 emails). Additionally, GISD did not have a District‐wide definition of responsibilities for the position.

Effect:

The District was in violation of the 2015‐2016 and 2016‐2017 Salary Schedules and Compensation Information approved by the Board of Trustees.

Recommendation:

The District should pay stipends to employees as approved by the Board of Trustees.

The District should define responsibilities for the paid position of student activities director.

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(Auditor’s note: June 7, 2017, IA was told that following the March 29, 2017 campus inquiry to the Human Resources Department, as described in the “Condition” portion of this finding, the Sachse High School student activities director began receiving the 2016‐2017 school year stipend and was retroactively paid the 2015‐2016 stipend (June 7, 2017, interviews with former Sachse High School principal and Sachse High School principal’s secretary).) Management’s Response:

Department: Chief Officer Responsible Party: Linda Chance Notes: The omitted stipend was paid in April of 2017. District‐wide description and scheduling expectations are in place for the student activities directors for the 2017‐2018 school year.


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Finding Thirteen Incorrect coding of the three athletic transactions reviewed by IA (100 percent)

Criteria: The following documents were available in the Business Department Procedures section of the GISD Intranet:

Account Coding “Frequent Issues” (Appendix Eleven, page 119): Function 36 – Athletics/Extracurricular activities

GISD Budgeting/Coding Guide (Appendix Twelve, page 120):

Function 36 – Extracurricular Activities: Expenses related to school‐sponsored activities outside of the school day. Program Intent Code (PIC) – is used to account for the cost of instruction and other services that are directed toward a particular need of a specific set of students: PIC 91 – Athletics

Applicable portions of the TEA FASRG Financial Accounting and Reporting Update 14 (Appendix Sixteen, page 131), explain [emphasis added in bold]:

1.4.3 Function Codes: A function represents a general operational area in a school district and groups together related activities. The R by a function indicates that the

function is required for reporting purposes (PEIMS and/or Annual Financial and Compliance Report) if such funds are applicable to the school district. (Auditor’s note: PEIMS is the acronym for Public Education Information Management System.)

R 36 Extracurricular Activities: Extracurricular activities include athletics.

Certain expenditures must be accounted for by organization code and program intent code.

Program Intent Code (PIC):

R 91 Athletics and Related Activities: The costs incurred to provide for

participation in competitive athletic activities

R 99 Undistributed: This code may be used for costs not clearly attributable to a

specific program intent.

Condition: The three athletics transactions reviewed by IA, totaling $5,836.01, were incorrectly coded by function and/or program intent code (PIC), for PEIMS and/or Annual Financial and Compliance Reporting (100 percent of the transactions reviewed):

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Campus Check Req/PO

Vendor Name

Amount Description Fund Function Campus Account Pic Activity

Sachse HS Ck req. 57604

America Team Sports

$4,420.00 T‐shirts and jackets for girls soccer

461 36 010 63999 99 ‐should be 91

92170

Sachse HS Ck req. 58796

America Team Sports

$420.51 Softball uniforms

461 36 010 63999 99 ‐should be 91

92180

Classical Center at Brandenburg

PO 5303273

America Team Sports

$995.50 Shorts, tees, polos for boys athletics

461 11 –should be 36

047 63999 99 ‐should be 91

92010

Total $5,836.01

Cause: Account codes may have automatically populated during Oracle entry of POs or check requests. Users did not correct the incorrect coding during Oracle input. IA verified the incorrect coding through a Finance Department accounting liaison who stated, “Yes, these should have been coded to PIC 91.” “Most of the items paid for at a campus level are generally paid using a PIC 99, so that may be where the confusion happened” and, the function for the transaction coded to Function 11 “should have been function 36” (Jan. 12, 2017 email, cc’d to District campus budget analyst).

Effect:

TEA required codes were incorrect for reporting purposes. Recommendation:

The Finance Department should continue ongoing training of District personnel and monitor coding to identify and request corrections of coding errors for accurate PEIMS reporting (e.g. run a weekly or monthly Discoverer report of all expenditures coded to Athletic activities and verify the fund and PIC codes).

(Auditor’s note: Following IA’s coding questions addressed to the Finance Department, attendees at the February 24, 2017, Monthly Business Meeting were informed that a Chart of Accounts was posted on the GISD Intranet Business Department website and a demonstration was presented for accessing the document.)

Management’s Response: Department: Chief Officer Responsible Party: Linda Chance Notes: The athletic department reviewed and confirmed the audit information indicating wrong budget codes were used for P.O.’s and check requests at Sachse High School and the Classical Center at Brandenburg. The campus accounting clerks while purchasing athletic apparel from campus activity funds made the incorrect budget codes in error. We will

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work with GISD Business Department to ensure additional budget code training Is provided for Sachse High School, the Classical Center at Brandenburg and for all first year campus accounting clerks hired on the secondary campuses. From the information that we received the Sachse High School accounting clerk has only served in this position for the 2016‐2017 school year.


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Finding Fourteen Management allowed employees at four campuses to leave their positions without documents clearly filed and maintained. Criteria:

The TEA FASRG: Module 3. Purchasing Update 14 states, “Precise and systematic record‐keeping and records management withstands the constant scrutiny of various interest groups including vendors, the general public, and outside agencies as well as internal groups which are the users or customers of the purchasing system” (3.1.1. Purchasing Policy, Appendix Fifteen, page 124). Section 1.7 of the CDAP states, “All financial‐related records should be kept current and in good order for a period of seven years at which time they should be destroyed” (Record Retention, Appendix Eight, page 84). The TEA Field Trip Guidelines within the GISD Field Trip Manual state, “For audit purposes, your organization must maintain documentation of the field trip” (Appendix Ten, page 114).

Condition:

Documentation unavailable Rowlett High School:

IA requested a Travel Approval Request form for a conference registration and received the following response from the now former campus accounting clerk, “I wasn’t able to find the purchase order. That was before I arrived at this position. Is there anything else I can do?” (Mar. 6, 2017, email).

Coyle Middle School:

In response to IA’s request for a Travel Approval Request form and documentation of Student Group approval for an expenditure, IA received the following memo (Feb. 20, 2017, memo):

“It has come to our attention that we are no longer in possession of the FCA Sponsor’s paperwork for the 2015‐2016 school year. The responsibility shifted with ______________’s retirement in June 2016. Coyle staff are instructed to keep their documentation for three years in case of audit. What is our recourse at this time?” signed by the current FCA sponsor, principal’s secretary, and the principal

Golden Meadows Elementary:

IA requested CAP‐122 and CAP‐123 for a fundraiser and received the following response from the current campus secretary, “The Secretary and Principal have both since left. I have gone through the box of copies etc. from last year and was not able to locate it” (Jan. 6, 2017 email).

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Dorsey Elementary:

IA requested two Field Trip Request Forms. According to the campus secretary, the former principal, who is now retired, kept the forms (Feb. 21, 2017, conversation).

Cause:

Management allowed employees to leave their positions without documents clearly filed and maintained on four campuses.

Effect:

Documentation either did not exist or was unavailable for audit. Recommendation:

IA recommends inclusion of a chapter in the CDAP Manual outlining requirements for implementation of a standardized filing system at each campus, either hard copy or electronic.


Department: Curriculum, Instruction and Assessment Responsible Party: Jovan Wells Notes: o I concur with the audit recommendation: “Include a chapter in the CDAP Manual

outlining requirements for implementation of a standardized filing system at each campus, either hard copy of electronic”

o Once this system has been established, Area Directors will monitor the requirements on an ongoing basis. As positions are vacated, the AD may also work with the principal and/or campus personnel to verify compliance prior to the employee separating from the district.


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Finding Fifteen Lack of coordination between the CDAP, Section 6, Travel Expenditures, and the Field Trip Manual

Criteria

CDAP, Section 6, Travel Expenditures, as attached in Appendix Eight, February 2016 revision, Section 6.1, page 91 includes, “All information provided below is applicable for supervisor‐approved travel only. Principals/department heads may institute policies that are more restrictive (not less) than those in this manual – always review location‐specific guidance prior to incurring expenses. The Business Office will consider location‐specific policies in making allowable (reimbursable) expense decisions.

A Travel Approval Request Form (located on the Business Office intranet) should be used to obtain the necessary advance approvals (as described in this section). Upon returning, a Travel Reimbursement Request form should be filled out and submitted with the necessary supporting documentation (receipts, etc.) and the Travel Approval Request Form as part of the iExpense reimbursement / reconciliation process.”

Section 6.2, Allowable Payment Methods includes under Description of Expenditure “Employees meals – traveling with students” and “Student Meals.” Section 6.3, Allowable Expenditure Guidelines include:

1) Out‐of state travel 2) Airfare 3) Hotel 4) Vehicle rental 5) Automobile (mileage) 6) Meals – employees 7) Meals – non‐employees – in lieu of per diem, actual costs of meals for

students or chaperones will be allowed. 8) Meals – business meetings 9) Supplies/Materials 10) Other business‐related expenses 11) Chaperone/sponsor costs (student travel) (emphasis added) – hotel cost

limits above do not apply to student travel, including costs for chaperones or sponsors of such trips. For these trips, the actual cost of meals will be reimbursed.

12) Personal Costs 13) Sales Tax

Section 6.4, State/Federal Grant Funds Guidelines, states, “Individuals expending grant funds should contact the applicable program manager for specific guidelines/restrictions.” Examples of more restrictive state/federal policies are then provided.

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The Field Trip Manual (Appendix Ten, page 112) states on page one, “The purpose of this Field Trip Manual is to provide information to principals and staff in planning and preparing for field trips of all types, regardless of the form of transportation.”

On page five, the following table is included:

Field Trip Location: Completed Request Submission Deadline: Within Garland ISD or Dallas County At least 21 days prior to the trip

Outside of Garland ISD but within Texas At least 21 days prior to the trip Outside of Texas, but within the continental United States At least 30 days prior to the trip

Outside of the continental United States At least 90 days prior to the trip

TEA Field Trip Guidelines pages 29 states, “Costs for the field trip must be reasonable. Any entrance fees and transportation costs must be reasonable in comparison to the intended objectives of the trip. For audit purposes, your organization must maintain documentation of the field trip and must provide clear evidence of how the expense ties back to an instructional objective.”

The Field Trip Checklist includes: o Overnight Field Trips o Trips Outside the United States o Title 1 Lesson Plan o Title 1 Field Trip Evaluation Form o Chaperones o Activity Fund Fundraising Application and Financial Recap

The Field Trip Approval Process includes: o Approved trip in Dallas County o Approved trip overnight/outside Dallas County o Approved trip outside Texas o Approved trip outside U.S.

The Field Trip Approval Signatures sheet includes: o Title I Funded Trips o Overnight or Outside Dallas County o Outside of Texas but Within the United States

The Field Trip Request Form includes: o # of parent chaperones o Cost of Trip and Source of Funding: 461, 199, Title 1, Account Code o How are meals to be provided and where?

Condition

Section 6: Travel Expenditures, of the CDAP includes expenditures common to field trips including “Employee meals – traveling with students,” “Student Meals,” and “Chaperone/sponsor costs (student travel).” Yet nowhere in the Field Trip Manual or its forms is mention made of CDAP Section 6: Travel Expenditures.

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Additionally, CDAP Section 6 states, “All information provided is applicable for supervisor‐approved travel only” and then includes a requirement for a Travel Approval Request Form. However, as seen above, travel for employees outside of Dallas County, throughout Texas, the United States, or internationally, is also permitted with a Field Trip Request Form.

The CDAP and Field Trip manuals both include sections regarding travel, but neither reference the other in this category.

Cause

The CDAP does not reference the Field Trip Manual and the Field Trip Manual does not reference the CDAP.

Effect

It is acknowledged that the majority of field trips are local for which no travel‐related expenditures such as for hotels, airlines, and meals are required. However, the Field Trip Manual also provides for overnight stays throughout Texas, the United States, and internationally. However, for such overnight travel, the Field Trip Manual does not include or reference CDAP Sections 6.2 and 6.3 regarding Allowable Payment Methods and Allowable Expenditure Guidelines nor provide similar guidelines. Additionally, no provision is made in the CDAP authorizing travel related expenditures to be approved via the field trip process. The CDAP states hotel, airfare, and other travel‐related costs may only be approved via a Travel Approval Request as described in the CDAP. A field trip may violate District procedures as described in the CDAP. Should an accident occur, such violations could be problematic for the District.

Recommendations

The Field Trip Manual should be revised to state that travel related costs may be authorized via the field trip approval process, and that in so doing the Travel Approval Request as described in the CDAP is not required for field trips. Additionally, the Field Trip Manual should reference CDAP Sections 6.2 and 6.3 regarding Allowable Payment Methods and Allowable Expenditure Guidelines or provide alternative guidelines.

The CDAP should reference the Field Trip Manual and state that travel related expenditures may be authorized under field trip authorization as well as the Travel Approval Request.

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Management’s Response: Department: Business Operations Responsible Party: Debbie Cabrera Notes:

(Auditor’s Note: As noted in Management’s response to Finding Seven and as can be seen above, the CDAP Manual has been updated to reference the Field Trip Manual. It is unknown at this point if the Field Trip Manual will follow any CDAP travel guidelines.)


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Finding Sixteen

Three Incomplete GISD Warehouse Pick Slips totaling $4,663 (20 pick slips reviewed by IA were complete)

Criteria Section 8.1 of the CDAP Manual as attached in Appendix Eight, page 97, addresses procedures for end users to reference when placing warehouse orders. Otherwise, there are no documented warehouse procedures (Nov. 7, 2016, interview of warehouse services coordinator).

Condition

IA reviewed 23 Internal requisition GISD Warehouse Pick Slips for orders delivered to campuses from the Warehouse. There were no issues with 20 Warehouse Pick Slips, two were missing dates under the “Received By” signature, and “No one there” was written on the “Received By” line of one Warehouse Pick Slip:

Campus Order Number

Requested Date

Description Amount Condition

Naaman Forest HS

157423 8/8/16 120 cases Paper Xerographic

$2,940 No date following signature

Stephens Elementary

154880 4/24/16 20 cases Paper Xerographic

$490 No date following signature

Bussey Middle School

157704 8/20/16 9 Table Folding Leg (30x72)

$1,233 No signature

Total 4,663

Cause

Warehouse drivers requested that recipients of deliveries on campuses sign and date Warehouse Pick Slips acknowledging receipt of deliveries. The drivers filed the signed Pick Slips on their return to the Warehouse. The recipients at Naaman Forest HS and Stephens Elementary did not date their signatures. The driver did not obtain a signature at Bussey Middle School. On March 29, 2017, IA went to the campus to look at the tables requested on August 20, 2016. The campus secretary said she did not know if they received the tables or where they were located.

Effect

There was no verification that Bussey Middle School received the tables.

Recommendation Warehouse drivers should obtain dated signatures from campus personnel for all deliveries, as there is no internal mechanism in Oracle for recipients to verify receipt of items ordered.

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Management’s Response: Department: Purchasing Responsible Party: Mark Booker Notes: Concur with finding, effective January 1, 2017, the warehouse personnel were directed to ensure all delivery tickets are signed and dated.


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Finding Seventeen Surprise petty cash counts at ten campuses revealed that seven campuses had a total of $1,072 less cash than District Oracle records totaling $4,300, one campus had the correct amount, and two campuses had turned in their petty cash funds. Criteria

The GAO’s Standards for Internal Control in the Federal Government: Internal Control Standards: Physical Control over Vulnerable Assets, page No. 47, states, “Management establishes physical control to secure and safeguard vulnerable assets. Examples include security for and limited access to assets such as cash, securities, inventories, and equipment that might be vulnerable to risk of loss or unauthorized use. Management periodically counts and compares such assets to control records.” The TEA FASRG, Module 3 states, “A petty cash fund is used to reimburse employees for small expenditures for district supplies or services and to make small district purchases. Such a fund can save time, paperwork, and associated administrative costs. Authorization to purchase from this source should be clearly defined in district or campus procedures and the dollar amount for each purchase should be limited (usually between $50‐$100). Purchases made with petty cash may occur at both the campus and departmental level. It is important that petty cash purchases be kept at a minimum and that accurate accounting records be maintained for all purchases by employees who have been assigned as custodians of the petty cash funds. (Purchasing Update 14: 3.2.3.8. Petty Cash Purchases, Appendix Fifteen, page 124)

The CDAP Manual Section 9.1 (Appendix Eight, February 2016 revision, page 97) defines the use of petty cash:

Petty Cash •Used for making change or immediate payments under $100 •Should be reconciled timely through Oracle •Should not be used in the place of iExpense (travel reimbursements)

According to GISD Petty Cash Procedures, when a Petty Cash Form is turned in to the Business Office, supporting documentation includes a Petty Cash Voucher with related receipts and a Food Purchase Form, if applicable. The voucher includes the name of the person being reimbursed, the description of items being reimbursed, the signature of the person receiving cash and the administrator approval signature.

Condition

February 1, 2016, through August 31, 2016, an Oracle petty cash report showed no petty cash at 46 campuses, and petty cash balances for 25 campuses (Oracle GL petty cash account report). IA subjectively selected the following ten out of those 25 campuses with balances, for petty cash counts. At the time of the petty cash counts, two of the campuses no longer had petty cash per Oracle:

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Campus Date of Petty Cash

(P/C) Count

Amount from District Record in

Oracle at time of P/C Count

Cash on Hand /

Vouchers at time of P/C

Count

Missing at time of

P/C Count

Notes

Note actions by the Finance Department during this audit with regard to contact from some campus personnel following cash counts at their campuses (see the “Recommendations” section of this Finding)

South Garland HS

4/4/2017 $1,500.00 $1,000.16 $499.84 Accounting clerk stated SGHS campus petty cash is $1,000 and the Finance Department does not want campuses to have petty cash; she feels petty cash is necessary for small reimbursements instead of completing an iExpense reimbursement report for very small reimbursement amounts (Apr. 4, 2017, interview)

Hudson MS 4/6/2017 $0.00 0.00 0.00

Nita Pearson Elementary

4/7/2017 $300.00 267.46 32.54 Campus secretary did not know why $32.54 was unaccounted. She stated the school starts and ends each school year with $300 and the balance is $300 unless there are outstanding vouchers (April 7, 2017, interview).

Hickman Elementary

4/12/2017 300.00 224.23 75.77 Campus secretary did not know why $75.77 was unaccounted. Following the p/c count, the Assistant Principal and campus secretary located an additional $31.96, bringing the missing amount to $43.81 (April 12, 2017, email) (April 12, 2017 Petty Cash Form).

Herfurth Elementary

4/17/2017 300.00 300.00 0.00

Cisneros Pre‐K 4/18/2017 300.00 298.05 1.95 Four receipts comprised $117.05 paid from petty cash. Receipts for cash expenditures were available. However, the identity of employees who received cash for shopping were not recorded, nor was administrator approval for expenditures recorded prior to purchases. According to the campus secretary, petty cash is distributed to employees prior to purchases, not upon the secretary receiving signed GISD Petty Cash Vouchers approved by an administrator following purchases (April 18, 2017, interview).

Classical Center at Brandenburg

4/18/2017 0.00 0.00 0.00

Southgate Elementary

4/20/2017 300.00 0.00 300.00 Campus secretary stated she has never had petty cash (April 20, 2017, interview).

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Campus Date of Petty Cash

(P/C) Count

Amount from District Record in

Oracle at time of P/C Count

Cash on Hand /

Vouchers at time of P/C

Count

Missing at time of

P/C Count

Notes

Northlake Elementary

4/21/2017 300.00 148.53 151.47 Campus principal said when the former campus secretary left, no one came to verify the petty cash. The current campus secretary said she did not verify the amount of petty cash when she began her position two years ago. She said she uses the petty cash for people who lose money in the Dr. Pepper machine, then recovers the cash from the vendor when he comes to the campus (April 21, 2017, interview). On April 24, 2017, the principal supplied IA with an email chain and deposit ticket from February 26, 2015, with instructions from the former GISD project accountant to the former campus secretary to “1. Deposit the $300 into the bank, but do not record it in Oracle. 2. Scan and email me a copy of the deposit ticket. 3. I’ll do the rest for you ” (email and deposit ticket). On April 25, 2017, the principal supplied the email from the former secretary to the former project accountant with the scanned deposit slip attached (February 26, 2015, email and deposit ticket). Concerning the cash on hand, the principal wrote, “The origin of that money goes back before my time at Northlake. We have added to it through the years with lost & found money” (email from principal).

Sachse HS 4/21/2017 1,000.30 990.00 10.30 Accounting clerk said she has $1,015 in petty cash and does not know why Oracle shows $1,000.30. She said fundraiser “starter” cash of $25 was out at the time of IA’s visit, and was to be turned in before the close of the school day. However, there was no signed and dated form to verify who on campus had the “starter” cash (April 21, 2017 interview).

Totals 4,300.30 3228.43 1071.87

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Cause Prior to the date range of the transactions listed herein, IA conducted a “Performance Audit of Lakeview Centennial High School Principal’s Financial Transactions from July 1, 2013, through October 31, 2014.” The audit included “Finding – Petty Cash – Cash on Hand Differs from District Records.” IA recommended, the “Finance Department routinely reconcile this account to actual cash on hand.” In the prior report, former management responded, “Finance Department staff do not have time to ensure that every campus is counted at least once a year, without adding additional staff … The use of petty cash could be eliminated through the use of P‐Cards and expense reimbursements. There are 60 campuses that have petty cash. The remaining 11 have turned in their petty cash.”(Sep. 29, 2015 email with response). Per management’s prior response, the District petty cash account may not have been reconciled to cash on hand at the campuses. However, only 25 campuses still had petty cash as of August 31, 2016. Additionally, please refer to the Notes column in the preceding table.

Effect Cash on hand was missing from the amounts recorded in the District’s Oracle records. Missing petty cash, although immaterial in amount, is material to the public trust.

Recommendation

During this audit, in the May 17, 2017, Business Office Monthly Meeting for Campus/Department Secretaries and Accounting Clerks, the Finance Director stated that fewer campuses have petty cash and encouraged campuses to turn in their petty cash. The Finance Director said that a form would be available to request a limited time change fund, as needed. Beginning with the 2017‐2018 school year, campuses with petty cash will receive an email showing the Oracle balance and asking that the campus cash be reconciled to the Oracle report. IA concurs with these actions.

Other management actions taken during the audit include:

The Finance Department corrected the $32.54 shortage at Nita Pearson Elementary. The campus secretary planned to deposit the remaining petty cash at the recommendation of the Finance Department. Most campuses have turned in their Petty Cash, so if you would like to turn in your Petty Cash please let me know and I will send you the directions on how to do that” (May 4, 2017, email).

The remaining petty cash of $256.19 at Hickman Elementary was turned in and the missing balance written off (May 2, 2017, email).

The Finance Department emailed the Northlake Elementary principal:

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When we researched the information you gave us regarding the return of the Petty Cash, we found that it was received by the bank (BOA, which is no longer the bank we use), but it wasn't entered in Oracle when [the former campus secretary] sent it to [the former project accountant. The former project accountant] left the district soon after that deposit was made, so it got lost in the transition of replacing her position. I have submitted a Journal Entry for the returned Petty Cash. Once the JE is approved, your campus will be cleared of having any Petty Cash on campus (May 2, 2017, email).


Department: Curriculum, Instruction and Assessment Responsible Party: Jovan Wells Notes: o The procedures for adhering to the CDAP Manual’s definition and use of petty cash

will be reinforced by principal supervisors during one‐on‐one meetings at the beginning of 2017‐2018.

If petty cash discrepancies occur at a campus, the principal supervisor should be notified and violations will result in disciplinary action.


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Observations

1) As of December 9, 2016, GISD procurement instructions identified different vendors for Printers:

GISD Oracle iProcurement Technology Purchase Order Directions identified Staples as the contracted vendor (Appendix Thirteen, page 122)

The GISD Intranet Tech Bids – Printers webpage identified CDW Government as the contracted vendor (Appendix Fourteen, page 123)


Department: Technology Responsible Party: Donna Eurek Notes: We agree with the observation. Vendor name has been corrected and updated on the Technology Bids intranet web page.

2) Following an inquiry by IA, Technology tagged and is tracking Air Eco pad systems

(clickers used in classrooms) in TipWEB IT School Asset Management Software used by the District to track inventory:

On June 12, 2016, GISD was invoiced $8,300 for the purchase of two Air Eco systems with 26 and 34 pads respectively, including training and licenses for Steadham Elementary. Air Eco systems were not available for ordering through the Tech Bids page in Oracle, so they were not shipped to the Technology Department for IT tagging.

On January 25, 2017, IA asked the assistant director of IT Operations, Assets, and Budget if Air Eco systems were tracked in TipWEB.

On January 27, IA received the following reply, “Yes. After further research we plan to track the Air Eco system in TipWeb as a bundle with one IT tag placed on each IR Receiver.” The elementary technology coordinator was asked to “please contact the CTA at Steadham Elementary and make sure the 8 ‐ AIR ECO IR on line 3, 4 of P.O. # 5335031 below are tagged and tracked in TipWeb” (Jan. 27 email).

On January 30, the elementary technology coordinator stated, “I’ve contacted the CTA and she has placed an IT tag on each of the 8 IR Receivers for the bundles on the P.O. She has also placed them in TipWeb IT for inventory purposes” (Jan. 30 email).


Department: Technology Responsible Party: Donna Eurek Notes: We agree with the observation. Current policy of Coordinators reviewing all technology related requisitions will be re‐enforced to ensure all “controlled” IT assets are centrally received and tagged.

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Audit Conducted Pursuant to GAGAS IA conducted this performance audit in accordance with Generally Accepted Government Auditing Standards (GAGAS). Those standards require that IA plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. IA believes that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Management’s Response Applicable portions of Management’s Response are included under each finding. Management asked that we include the following announcement for upcoming training from Business Operations:

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Appendix One

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Appendix Two Garland Independent School District Staffing and Scheduling Guidelines

VI. Assignment of Sponsors of Co‐Curricular Activities, page No. 7

Block Classes Activity Period(s) Conference(s)

Student activities director 4 2 2

Student Council Sponsor 4 2 2

Cheerleader Sponsor 4 2 2

Varsity Drill Team Sponsor 4 2 2

Jr. Varsity Drill Team Sponsor 4 Fall; 6 Spring 2/1 2/1

Trimester Classes Activity Period(s) Conference(s)

Student activities director 3 1 1

Student Council Sponsor 3 1 1

Cheerleader Sponsor 3 1 1

Varsity Drill Team Sponsor 3 1 1

Jr. Varsity Drill Team Sponsor 3 1 1

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Appendix Three Duties of the Sachse High School Student Activities Director

According to the principal’s secretary, the former principal authored this document in 2015. Responsibilities regarding fundraisers are highlighted (Jan. 23, 2017 email).

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Appendix Four

Purchasing Department

Garland ISD Procurement Risk Assessment June 21, 2016 - Steve Martin received Garland ISD Procurement Risk Assessment from Purchasing Director Mark

Booker -DLP

1. Identifying the need and planning the purchase

2. Specification Development

3. Selecting the purchasing method

4. Purchasing documentation

5. Bid/RFP Process

6. Evaluating offers

7. Negotiations

8. Contract management

1. Identifying the need and planning the purchase

Risk Likely consequences Action

1.1 User needs not properly identified

Unacceptable purchase or less than suitable product or service

Time lost

Improve communication and training with end users to develop clear statement of work and definition of need

1.2 Insufficient funding Delay in making the purchase

Verify funding source and availability of funds

1.3 Impractical timeframe Inadequate responses from suppliers

Increased procurement cost

Develop procurement schedule which allow suppliers and end users sufficient time through the process

2. Specification Development


2.1 Restrictive specifications(e.g. use of brand name)

Fewer alternatives

Most suitable product or service may not be obtained

Increased costs

Define the specification in terms of required outputs

Use performance, design, technical, and combinations of specifications

Buyers provide a template too provide guidance

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2.2 Biased specification Inadequate number of responses from suppliers

Vendor Protest

Avoid overly restrictive specifications

Prohibit use of supplier provided specifications

Implement a control mechanism to review specification before release

2.3 Vague or insufficient specifications

Variety of offers

Insufficient responses

Products offered not meeting needs

Difficult to evaluate due to wide price ranges and various product quality levels

Be familiar with requirements and develop specifications which provide sufficient information for suppliers to respond.

Use functional and performance specifications

Incorporate needs analysis provided by the end user

3. Selecting the purchasing method


3.1 Failure to identify potential sources

Lack of offers from capable suppliers

Improve procurement planning processes

Identify sources outside current database for specialty purchases

3.2 Selecting inappropriate method

May result in rejection of all bids

Vendors may protest

May violate procurement law

Develop a form to assist buyers in selecting appropriate method

Provide staff with appropriate training

4. Purchasing documentation


4.1 Terms and conditions unacceptable to suppliers

Reduced number of supplier responses

Increase number of deviations

Use standard documentation prepared by Purchasing Department

Select appropriate documentation for purchase type (i.e. goods, services, goods and

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Risk Likely consequences Action services, or information technology related)

4.2 Providing inadequate information

Variations in offers

Having to provide clarifying information, causing delays in bid/RFP closing

Additional costs

Ensure staff have appropriate training

Improve planning and preparation

Develop and use standard forms

4.3 Inadequate file management

Missing forms could result in increased risk to district

Suppliers not held to standards in the contract document

Create checklist for completion

Develop standard filing practices

5. Bid/RFP Phase


5.1 Failure to adequately address questions from suppliers

Claims of unfair practices

Offers with qualifications by suppliers

Withdrawal of offers

Implement procedures for responding to questions

Provide staff with appropriate training regarding bid/RFP management training and experience

Respond in a timely manner to enquiries

Allow adequate time for suppliers to respond

5.2 Actual or perceived favouritism

Complaints from suppliers

Withdrawal of offers

Potential litigation

Provide training to end users regarding contact with suppliers and biased actions

Answer questions in writing and provide copies to all potential suppliers by issuing addenda

5.3 Actual or perceived breach of confidentiality


Mistrust by suppliers

Establish formal security procedures

Train staff in their obligations

5.4 Insufficient number of responses

Need to undertake process again

Increased costs

Use appropriate notification process to increase competition

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Allow sufficient time for suppliers to respond

6. Evaluating offers


6.1 Failure to follow effective evaluation procedures

Inconsistent evaluations

Possible complaints from suppliers

Subjective not objective evaluation of offers

Provide staff with appropriate assessment and evaluation training

Improve Bid/RFP assessment and evaluation processes

Maintain, audit and review evaluation procedures

Ensure that Evaluation Committee members declare any conflicts of interest

6.2 Breaches of security Claims of unethical or unfair practices

Provide staff with appropriate training and monitor performance

Ensure that Evaluation Committee members understand and sign Confidentiality Agreements

6.3 Offers fail to meet needs Need to rebid

Additional costs

Delay in delivery

Develop clear concise scope of work and specifications

Develop functional and performance specifications

6.4 Decision made on subjective grounds

Claims of unethical and unfair behaviour


Reduced response for future bids/RFP’s

Ensure evaluation criteria contains the critical factors

Ensure evaluation criteria are appropriate and measurable when possible

Ensure that Evaluation Committee members sign Declaration of Conflict and Confidentiality Agreements

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7. Negotiations


7.1 Lengthy negotiation process

Delivery delays, deadlines not met

Inefficient use of resources

Improve communication, including ensuring that Terms and Conditions are part of the Request for RFP or Bid

Provide staff with training in contract planning and management

Define terms carefully

Clarify all uncertainties in the evaluation process

8. Contract management


8.1 Use of unapproved suppliers

Supplier protest

Receive inferior product or service

Increased cost

Litigation

Ensure end users are aware of approved suppliers and local policy

Monitor decentralized purchasing methods, P-Card and check request for compliance with policy

8.2 Failure of either party to fulfil the conditions of the contract

Contract disputes

Failure to satisfy needs

Delays in delivery

Downtime

Legal action

Ensure good contract administration and performance management

Ensure all staff know responsibilities and conditions

Ensure good record keeping and documentation

8.3 Inadequately administering the contract

Cost increases

Failure of contract

Full benefits not achieved

Delivery of unsatisfactory product

Contract/supply disputes

Ensure all staff are suitably trained and experienced in contract planning and management

8.4 Commencement of work by the supplier before contract is executed or purchase order issued

Potential liability to pay for unauthorised work

Possibility of legal action for perceived breach of contract

Ensure approvals are received before allowing work to start

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Risk Likely consequences Action Confirm contract execution prior to commencement of work

Enforce local policy regarding unauthorized purchases

8.5 Unauthorized increase in scope of work

Unanticipated cost increases

Contract disputes

Ensure all contract amendments are issued in writing

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Appendix Five

Criteria Table of Contents

Applicable portions of the following criteria are included page

Appendix Six: Garland ISD Board Policies (Legal) .................................................. 78 Appendix Seven: Garland ISD Board Policies (Local) .................................................. 80 Appendix Eight: GISD CDAP Manual, February 2016 revision .................................. 83 Appendix Nine: GISD P‐Card Manual, February 2016 revision ................................ 106 Appendix Ten: GISD Field Trip Manual .................................................................... 112 Appendix Eleven: Accounting Coding “Frequent Issues” ............................................ 119 Appendix Twelve: Criteria: GISD Budgeting / Coding Guide ........................................ 120 Appendix Thirteen: Criteria: Oracle iProcurement Technology PO Directions ............. 122 Appendix Fourteen: Criteria: GISD Intranet Tech Bids‐Printers ...................................... 123 Appendix Fifteen: Criteria: TEA FASRG Module Three. Purchasing Update 14 .......... 124 Appendix Sixteen: Criteria: TEA FASRG 1. Financial Accounting and Reporting Update 14 .......................................................................... 131

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Appendix Six Applicable Portions of GISD Board Policies (Legal)

Garland ISD Board Policy CFD (Legal): Accounting: Activity Funds Management DATE ISSUED: 10/15/2009 1 of 1 UPDATE 86 CFD(LEGAL)‐P

DISCRETIONARY FUNDS The District shall adopt a policy governing the expenditure of local

funds from vending machines, rentals, gate receipts, or other local sources of revenue over which the District has direct control. A policy under this section must: 1. Require discretionary expenditures of local funds to be related to the District’s educational purpose and provide a commensurate benefit to the District or its students; and 2. Meet the standards of Section 52, Article III, Texas Constitution, regarding expenditure of public funds. Education Code 44.908

Garland ISD Board Policy CH (Legal) Purchasing and Acquisition, page Nos. 1 and 5 DATE ISSUED: 10/7/2015 UPDATE 103 CH(LEGAL)‐P

BOARD AUTHORITY A board may adopt rules and procedures for the acquisition of goods

and services. Education Code 44.031(d) DELEGATION OF AUTHORITY

A board may delegate its authority regarding an action authorized or required to be taken by a district by Education Code Chapter 44, Subchapter B, to a designated person, representative, or committee.

A board may not delegate the authority to act regarding an action authorized or required to be taken by the board by Education Code Chapter 44, Subchapter B. Education Code 44.0312

SOLE SOURCE Compliance with Education Code 44.031 is not required for purchases

that are available from only one source, including:

An item for which competition is precluded because of a patent, copyright, secret process, or monopoly.

A film, manuscript, or book. Garland ISD Board Policy CHF (Legal) Purchasing and Acquisition Payment Procedures, page Nos. 1-3 DATE ISSUED: 6/7/2006 UPDATE 78 CHF(LEGAL)-P

PAYMENT DUE A payment owed by the District based on a contract executed on or

after September 1, 1987, is overdue on the 31st day after the date on which the District received the goods under the contract or the date on which the performance of services under the contract was completed, or the date on which the District received the invoice for the goods or services, whichever is later. However, if the Board meets only once a month, the payment is not overdue until the 45th day after the date of receipt of goods, performance of services, or receipt of invoice, whichever is later. The renewal, amendment, or extension

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of a contract executed on or before September 1, 1993, is considered to be the execution of a new contract. Gov’t Code 2251.021

INTEREST A payment begins to accrue interest on the date the payment

becomes overdue. The rate of interest that accrues on an overdue payment is the rate in effect on September 1 of the fiscal year in which the payment becomes overdue. The rate in effect on September 1 is equal to the sum of one percent and the prime rate as published in the Wall Street Journal on the first day of July of the preceding fiscal year that does not fall on a Saturday or Sunday.

Interest on an overdue payment stops accruing on the date the District or vendor mails or electronically transmits the payment.

The unpaid balance of a partial payment made within the prescribed period accrues interest, unless the balance is in dispute. Gov’t Code 2251.025, 2251.029

The District shall compute and pay interest at the time the payment is made on the principal. Interest payments shall accompany payment of the net amount due for the goods or service. The District may not require a vendor to petition, invoice, bill, or wait additional days to receive the interest due. The District may not require a vendor or subcontractor to agree to waive the vendor’s or subcontractor’s right to interest as a condition of the contract. Gov’t Code 2251.027

EXCEPTIONS These provisions do not apply to payments made by the District or a

vendor if:

1. There is a bona fide dispute between the District and a vendor, contractor, subcontractor, or supplier concerning the goods delivered or the service performed that causes the payment to be late;

2. There is a bona fide dispute between a vendor and a subcontractor or between a subcontractor and its supplier about the goods delivered or the services performed that causes the payment to be late;

3. The terms of a federal contract, grant, regulation, or statute prevent the District from making a timely payment with federal funds; or

4. The invoice is not mailed to the person to whom it is addressed in strict accordance with any instructions on the purchase order relating to the payment. Gov’t Code 2251.002

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Appendix Seven Applicable Portions of Garland ISD Board Policy (Local)

Garland ISD Board Policy CAA (Local) Fiscal Management Goals and Objectives: Financial Ethics, page Nos. 1‐2 DATE ISSUED: 10/7/2015 2 of 3 UPDATE 103 CAA (LOCAL)‐A

All Trustees, employees, vendors, contractors, agents, consultants,

volunteers, and any other parties who are involved in the District’s financial transactions shall act with integrity and diligence in duties involving the District’s fiscal resources.

FRAUD AND FINANCIAL IMPROPRIETY

The District prohibits fraud and financial impropriety, as defined below, in the actions of its Trustees, employees, vendors, contractors, agents, consultants, volunteers, and others seeking or maintaining a business relationship with the District.

DEFINITION Fraud and financial impropriety shall include but not be limited to: 1. Forgery or unauthorized alteration of any document or account

belonging to the District. 2. Forgery or unauthorized alteration of a check, bank draft, or any

other financial document. 3. Misappropriation of funds, securities, supplies, or other District

assets, including employee time. 4. Impropriety in the handling of money or reporting of District

financial transactions. 5. Inappropriately destroying, removing, or using records, furniture,

fixtures, or equipment. 6. Failure to provide financial records required by federal, state, or

local entities. 7. Any other dishonest act regarding the finances of the District. 8. Failure to comply with requirements imposed by law, the

awarding agency, or a pass‐through entity for state and federal awards.

FINANCIAL CONTROLS AND OVERSIGHT

Each employee who supervises or prepares District financial reports or transactions shall set an example of honest and ethical behavior and shall actively monitor his or her area of responsibility for fraud and financial impropriety.

FRAUD PREVENTION The Superintendent or designee shall maintain a system of internal

controls to deter and monitor for fraud or financial impropriety in the District.

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Garland ISD Board Policy CFB (Local) Accounting Inventories DATE ISSUED: 8/7/2015 LDU 2015.02 CFB(LOCAL)‐X CAPITALIZATION THRESHOLD

The capitalization threshold for purposes of classifying capital assets and infrastructure assets shall be $5,000.

CAPITAL ASSETS Property shall be classified as a capital asset if it: 2) Has an initial cost exceeding $5,000 per item; 3) Is not consumed as a result of use; 4) Has a useful life of at least one year; and 5) Is controllable, can be identified by a permanent or assigned

number, and can be accounted for through a physical inventory system.

Garland ISD Board Policy CFD (Local) Accounting Activity Funds Management DATE ISSUED: 10/15/2009 UPDATE 86 CFD(LOCAL)-A FIDUCIARY RESPONSIBILITY

The Superintendent, principal, and sponsor, as applicable, shall be responsible for the proper administration of District and campus activity funds and student activity funds in accordance with state law and local policy, District‐approved accounting practices and procedures, and the TEA Financial Accountability System Re‐source Guide.

STUDENT ACTIVITY FUNDS

The Superintendent or designee shall ensure that student activity accounts are maintained to manage all class funds, organization funds, and any other funds collected from students for a school related purpose. The principal or designee shall issue receipts for all funds prior to their deposit into the appropriate District account at the District depository. Student activity funds shall be included in the annual audit of the District’s fiscal accounts. [See CFC]

Garland ISD Board Policy CH (Local) Purchasing and Acquisition, page Nos. 1-2 DATE ISSUED: 1/6/2015 UPDATE 101 CH(LOCAL)‐X

PURCHASING AUTHORITY

The Board delegates to the Superintendent or purchasing director the authority to make budgeted purchases for goods or services. However, any single, budgeted purchase of goods or services that costs, in the aggregate, $75,000 or more, regardless of whether the goods or services are competitively purchased, shall require Board approval before a transaction may take place.

EXCEPTIONS A purchase utilizing an interlocal contract, or a cooperative or state

purchasing program approved by the Board, shall be approved by the Superintendent or purchasing director.

RESPONSIBILITY FOR DEBTS

The Board shall assume responsibility for debts incurred in the name of the District so long as those debts are for purchases made in

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accordance with the adopted budget, state law, Board policy, and the District’s purchasing procedures. [See CE] The Board shall not be responsible for debts incurred by persons or organizations not directly under Board control. Persons making unauthorized purchases shall assume full responsibility for all such debts.

PURCHASE COMMITMENTS

All purchase commitments shall be made by the Superintendent or purchasing director in accordance with administrative procedures, including the District’s purchasing procedures.

Garland ISD Board Policy DEA (Local) Compensation and Benefits Compensation Plan DATE ISSUED: 5/26/2015 UPDATE 102 DEA(LOCAL)‐A

The Superintendent shall recommend an annual compensation plan for

all District employees. The compensation plan may include wage and salary structures, stipends, benefits, and incentives. [See also DEAA] The recommended plan shall support District goals for hiring and retaining highly qualified employees. The Board shall review and approve the compensation plan to be used by the District.

Garland ISD Board Policy DEAA (Local) Compensation and Benefits Incentives and Stipends DATE ISSUED: 5/26/2015 UPDATE 102 DEAA(LOCAL)‐A

STIPEND The Superintendent shall recommend a stipend pay schedule as part of the annual compensation plan of the District. [See DEA]

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Appendix Eight Applicable Portions of the Garland ISD Campus and Department Accounting Procedures

(CDAP) Manual February 2016 Revision Section 1: General Information, page Nos. 1, 2, and 4 (pdf page Nos. 5, 6, and 8) revised 6/30/15 1.1 PURPOSE The Campus Department Accounting Procedures (CDAP) Manual is designed to be the single source of guidelines which, when followed, assists in complying with the TEA’s Financial Accountability System Resource Guide (FASRG), general Federal/State Program requirements, Generally Accepted Accounting Principles (GAAP) and District policies and procedures. This manual provides general guidance – specific questions regarding the use or intent of these procedures should be sent to the Assistant Director of Finance or your Campus/Department Liaison.

1.2 Government Accounting Overview Governmental accounting systems are organized and operated using funds segregated for the purpose of carrying on specific activities or attaining certain objectives. These funds are broken down into the following three types:

Governmental Funds

•Must be included in District Budget •Must comply with State purchasing guidelines

Proprietary Funds

•Record private‐business‐like activities (i.e. Print Shop, CCC, etc.) •Services are usually funded by user charges

Agency Funds

•Involve a fiduciary (trustee) responsibility •Held by the District for use by another entity

While a large number of funds are used within the District’s system, the following four are the most common:

199 ‐ General Funds

• Governmental Funds• Generated from State, Local, and Federal Sources • Allocated through budget process • Must comply with State purchasing guidelines

461 ‐ Campus Activity Funds

• Governmental Funds• Generated from student fees, vending, and fundraising • Must comply with State purchasing guidelines • Administered by principals to promote the general welfare of campus and educational development and morale of students and staff.

865 ‐ Student Activity Funds

• Agency Funds• Generated and controlled by student groups (governed by an elected body) • Expenditures must be approved by group, sponsor, and principal and be for the benefit of the students

876 ‐ Other Activity Funds

• Agency Funds• Collected at campuses and sent to admin offices ‐ OR ‐ • Controlled by the employees

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1.3 RESPONSIBILITY FOR FUNDS The responsibilities noted below do not pertain to funds collected, disbursed, and/or controlled by parents, patrons, or alumni organizations. Such funds should not be accounted for in GISD Funds. See Section 1.5 for guidance on booster clubs and parent organizations.

Principal / Department Head

• Proper collection, disbursement, and control of all funds• Safekeeping of funds • Proper accounting and administration of transactions • Expending funds in compliance with state laws and local board policies • Adequate training and supervision of all personnel managing funds

Secretary / Accounting Clerk

• Depositing receipts• Safekeeping of funds • Processing disbursements • Providing fund reports as requested

Activity Fund Sponsors

• Managing respective activity funds• Safekeeping of funds • Developing fundraising plans • Monitoring financial position of activity fund • Reviewing activity fund financial statements

NOTE: Activity Fund reports should be reviewed at least monthly to determine that all transactions have been properly recorded. 1.7 RECORD RETENTION All financial‐related records should be kept current and in good order for a period of seven years at which time they should be destroyed. Under no circumstances should such records be placed in any trash receptacle. All records slated for destruction must be disposed of according to District guidelines.

1.8 FINANCIAL ETHICS The District and its entire staff are obligated to ensure all activities involving District resources are performed with integrity and diligence. Certain GISD Board Policies have been created to improve internal controls:

• CAA (Local) – expresses the expectation for integrity and diligence in managing the District’s financial resources; describes the responsibility of reporting knowledge of fraud; and references other policies affecting financial management.

Section 2: Cash Receipts & Deposits, page No. 4 (pdf page No. 12) revised 2/8/16 2.8 DEPOSIT ADJUSTMENTS

As part of the bank reconciliation process, the Business Office receives information from the bank regarding deposit corrections/adjustments. These adjustments are processed according to the nature of the reconciling item, as follows: 1. Deposits in Bank, not in Oracle – these are adjustments for deposits sent to the bank but

never recorded in Oracle. In the month discovered, the Business Office will record these deposits to the “Deposit Adjustments” Activity (90050) within the appropriate campus/department activity fund (461/865/876). Campuses/departments will be notified of these items and asked to submit transfer requests to move the adjustments into the appropriate Activity accounts.

2. Bank account used different from Oracle bank account – these are adjustments for deposits sent to one Bank account (Campus/Student/Other) but recorded into a different bank account in Oracle. The Business Office will process these adjustments.

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3. Amount deposited corrected by Bank – these adjustments occur when the amount actually received by the Bank differs from that shown on the campus/department deposit slip. In the month discovered, the Business Office will add these corrections to the appropriate Oracle Batch and into the “Deposit Adjustments” Activity (90050). Campuses/departments will be notified of these items and asked to submit transfer requests to move the adjustments into the appropriate Activity accounts.

4. Deposit slip and Oracle amounts differ – these are “informal”, usually minor, variances resulting from keying errors, etc. In the month discovered, the Business Office will add these corrections to the appropriate Oracle Batch into the “Deposit Adjustments” Activity (90050). Campuses/departments will be notified of these items and asked to submit transfer requests to move the variances into the appropriate Activity accounts.

Section 3: Fundraising, page No. 1 (pdf page No. 14) revised 6/30/15 3.1 GENERAL FUNDRAISING GUIDELINES A fundraising activity may be defined as any activity involving participation of a student body or school‐recognized student group undertaken for the purpose of deriving funds for a school or school‐sponsored group. Such activities are not confined to regular school hours but are considered an extension of the school program.

The following guidelines should be considered prior to engaging in any fundraising activities:

All fundraising activities must be approved in advance by the sponsor (if applicable) and the principal/department head. This includes approval over in‐school advertisement of such activities.

• District funds (including those obtained through fundraisers) cannot be used to purchase incentives (tvs, bicycles, headphones, etc.) to be given to students, employees, or others.

3.2 FUNDRAISING PROCEDURES 1. Prior to beginning any fundraiser (including one held off‐campus), the Activity sponsor must complete the upper portion of the Activity Fund Fundraising Application and Financial Recap Form (CAP‐122), sign it, and forward the entire three‐part form to the principal, keeping a photocopy for their own record. (Refer to Section 4: Sales Tax for guidance on determining the activity’s sales tax status.)

2. The principal will approve or disapprove the Fundraising Application. a. If disapproved, principal shall write “DISAPPROVED” on the form along with an explanation and return the white copy to the sponsor. The canary and pink copies will be maintained by the secretary/accounting clerk.

b. If approved, principal signs the form and returns the white and canary copies to the sponsor. The pink copy will be used by the secretary/accounting clerk to track open fundraisers.

3. Upon completion of the activity, the sponsor shall complete the bottom portion (Financial Recap) of the form (both white and canary copies) with agreement from the secretary/accounting clerk (indicated by their signature on the form).

4. The principal should review and initial the completed form.

5. The secretary/accounting clerk will retain the canary copy of the complete form and attach it to the pink copy, closing out the fundraiser. The sponsor will retain the white copy.

6. The secretary/accounting clerk will maintain the “Log of CAP‐122 Forms issued” (CAP‐123) to track the number of fundraisers held by each student group.

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Section 4: Sales Tax, page No. 1 (pdf page No. 16) revised 6/30/15 4.1 PURCHASES – TAXABLE STATUS School districts are exempt from the payment of sales tax on purchases made for use in the normal course of operations. The following guidelines should be followed when considering the taxable status of various purchases (all forms mentioned can be found on the Business Office intranet site):

• The exemption should be claimed at the time of purchase – a properly issued District purchase order is sufficient proof of the District’s exempt status. If a purchase order is not used, the vendor must be provided with a “Texas Sales and Use Tax Exemption Certification” form. o Employees will not be reimbursed for sales tax on purchases made on behalf of and for the exclusive use of the District.

• The exemption does not apply to items purchased for resale. o The vendor must be provided with a “Texas Sales and Use Resale Certificate” o When the items are resold the appropriate sales tax must be collected (see below)

• The exemption may not be used by employees for personal purchases nor by parents, patrons, alumni organizations, booster clubs, parent organizations, etc.

• Texas law does not require sellers to accept a District purchase order or Exemption Certification form and, accordingly, may collect sales tax. In those instances, explanations should be submitted to the Business Office along with other relevant documentation.

Section 5: Staff/Student Expenditures, page Nos. 1‐3 (pdf page Nos. 19‐21) revised 6/30/15

5.1 GENERAL INFORMATION Principals and department heads are responsible for expending funds in harmony with the basic purpose of each fund. The ultimate consideration in determining the appropriateness of an expenditure is the impact (improvement) it will have on student welfare and academic performance. Activity funds shall be expended to benefit current students associated with the group that accumulated those funds.

The goal of using Activity funds is to promote the general welfare of the campus/department including the education, development and morale of all the students and staff. Article III, Section 51 of the Texas Constitution prohibits gifts of public funds, except those specifically allowed in the law. Attendance awards and personal gifts to employees risk conflict with this statute. GISD feels such expenditures, de minimis in amount and infrequent in occurrence, meet the goal of promoting general student/staff welfare. The following guidelines have been developed to allow principals/department heads to reach this goal.

5.2 GIFTS OF PUBLIC FUNDS GUIDELINES

NOTE: The list that follows is not exhaustive to the situations that may occur at a campus or department. For questions not addressed in the examples below, contact the appropriate Business Office Campus/Department Liaison or the Asst. Director of Finance.

1. Gifts to employees – payments and gifts to employees are never permitted from General Funds (199). Campus Activity Funds (461) may only be used to purchase a retirement gift, not to exceed $50.00. Gifts to employees (flowers, meals, etc.) for hospitality, condolences, etc. are allowed out of Other Activity Funds (876) only, upon the decision of the committee managing these funds. Cash, gift cards, etc. are NOT PERMITTED from any fund.

2. Staff incentives – the purchase of school-related awards (i.e. Teacher of the Month) is allowed from Campus Activity Funds (461) in an amount not to exceed $100.00 annually. Appropriate awards include: a framed certificate/plaque, designated parking, reimbursement of school supplies, etc. Performance awards are not allowed – a gift based on job performance could be considered additional compensation. Payments to employees for Extra Duty are permitted from General Funds (199) and are processed through payroll only.

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3. Instructional supplies and staff shirts – the purchase of instructional supplies (including portfolios and textbooks) and staff shirts (once annually) for staff is allowed from General Funds (199) and/or Campus Activity Funds (461).

4. Staff meals/refreshments – At the discretion of the principal/department head, refreshments or food for faculty/staff development or business meetings may be purchased from General Funds (199) or Campus Activity Funds (461). Campus Activity Funds (461) may also be used to assist with expenditures for school-wide staff parties at a max of $20.00/employee annually. Because they do not have 461 funds, departments only may use 199 to pay for staff parties (same $20/employee limits). NOTE: With all expenditures, tips should never exceed 20percent and alcoholic beverages can never be purchased.

5. Staff membership fees – General Funds (199) may be used to pay for membership dues in a professional organization. Campus Activity Funds (461) may be used only for one membership for each campus principal and assistant principal. Student Activity Funds (865) should not be used to pay for a staff’s membership dues. Memberships in civic organizations may not be purchased with District funds.

6. Professional conference expenses – in accordance with District travel guidance (See Section 6), General Funds (199) and Campus Activity Funds (461) may be used for professional conference expenses and staff development. Student Activity Funds (865) cannot be used to pay such staff expenses unless the staff is supervising students while traveling.

7. Door prizes – door prizes are not permitted from General Funds (199) or Campus Activity Funds (461) but may be purchased with Student or Other Activity Funds (865/876). Additionally, door prizes donated by private business or individuals may be accepted and utilized according to the wishes of the donor.

8. Student incentives – attendance and incentive awards for students (i.e. perfect attendance pizza party; college entrance exam reimbursements) are allowed from General Funds (199) and Campus Activity Funds (461).

9. Scholarships – it is recommended that all scholarships be administered through the Best Foundation. Scholarships are not allowed from General Funds (199) or Campus Activity Funds (461) but may be provided from Student or Other Activity Funds (865/876). If a Student Activity (865) wishes to provide a scholarship, the officers and sponsors of the organization must submit a signed request to the principal.

Funds raised for scholarships should be placed in a specifically designated account according to the group raising such funds (865 – Student Activity; 876 – Employee/Community). Specific wishes of the donor are to be followed. A scholarship committee should be assembled to evaluate applicants and recommend recipients. This committee may including individuals both internal and external to the District.

NOTE: The Business Office recommends that campuses/departments verify recipients’ collegiate enrollment prior to issuance of any scholarship payments.

10. Fundraisers for/Donations to outside organizations – the District encourages staff involvement in worthwhile community organizations. However, no General Fund (199) or Campus Activity Funds (461) should be donated/contributed to such organizations. Student or Other Activity Funds (865/876) should be used to account

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for any fundraisers for outside organizations. Such fundraisers should never require staff/students to contribute nor should they place individuals under duress.

11. Flowers/Receptions for students or parent volunteers – such purchases may be made from Campus Activity Funds (461) or Student Activity Funds (865). Examples include sending flowers to hospitalized students or showing appreciation of campus volunteers.

5.3 APPROPRIATE EXPENDITURES REFERENCE GUIDE To provide a practical reference for assisting principals/department heads in making decisions regarding appropriate expenditures, the following contains guidance on the most commonly questioned expenditures.

Description of Expenditure

General Funds (199)

Campus Activity Funds

(461)

Student Activity Funds (865)

Other Activity Funds

(876)

Gifts to employees (excluding retirement gifts) NO NO NO1 YES

Retirement gifts ($50 limit) NO YES NO1 YES (no limit)

Retirement receptions, wedding showers, etc. NO NO NO1 YES

Cash, gift cards/certificates, etc. NO NO NO NO

Staff incentives (school‐related; $100 limit) NO YES NO YES (no limit)

Performance awards NO NO NO NO

Extra duty pay (paid through Payroll only) YES NO NO NO

Instructional supplies (including textbooks) YES YES NO1 NO

Staff shirts/spirit items (1x annually) YES YES NO YES (no limit)

Food staff development/business meetings YES YES NO YES (no limit)

Food for all‐staff campus activities2 YES YES NO YES (no limit)

Parties for all staff ($20/employee annually)3 NO4 YES NO YES (no limit)

Tips exceeding 20percent NO NO NO1 YES (no limit)

Meals for no special event NO NO NO1 YES (no limit)

Alcoholic beverages NO NO NO NO

Membership in professional organizations YES YES (1 per

administrator) NO NO

Membership in civic organizations NO NO NO NO

District‐related travel (approved) – no students YES YES NO NO

District‐related travel (approved) ‐ students YES YES YES NO

Door prizes NO NO YES YES

Student incentives YES YES NO1 NO

Scholarships NO NO YES YES

Donations to outside organizations NO NO YES YES

Flowers/Receptions for students or parent volunteers NO YES YES NO

Flowers for staff NO NO NO YES 1With student members and sponsor approval, these funds may be used to make purchases that fall within these categories.

2Examples include: Beginning/Ending of year; testing; teacher conferences 3Examples include: Thanksgiving; Christmas/Winter Break. The $20 max/employee should be calculated including tip (which must be less than 20percent).

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4Due to the absence of a 461 account, Departments only may use 199 to fund these activities

Section 6: Travel Expenditures, page Nos. 1-3 (pdf page Nos. 22-24) revised 2/18/16 6.1 GENERAL INFORMATION All information provided below is applicable for supervisor‐approved travel only. Principals/department heads may institute policies that are more restrictive (not less) than those in this manual – always review location‐specific guidance prior to incurring expenses. The Business Office will consider location‐specific policies in making allowable (reimbursable) expense decisions. A Travel Approval Request Form (located on the Business Office intranet) should be used to obtain the necessary advance approvals (as described in this Section). Upon returning, a Travel Reimbursement Request Form should be filled out and submitted with the necessary supporting documentation (receipts, etc.) and the Travel Approval Request Form as part of the iExpense reimbursement/reconciliation process.

6.2 ALLOWABLE PAYMENT METHODS Not all District‐approved payment methods can be used for travel expenses. The following chart provides guidance on which methods can/cannot be used and when:

Description of Expenditure District P‐Card

District Travel Card

Personal Credit Card1

Travel Advance

Transportation (Airfare, car rental, etc.) NO YES YES NO

Hotel NO YES YES NO

Conference/training registration YES YES YES NO

Employee meals – not traveling with students NO NO YES YES2

Employees meals – traveling with students YES YES YES YES2

Student meals YES YES YES YES2

Gasoline – mileage being reimbursed NO NO NO NO

Gasoline – District or rental vehicle YES YES YES NO

Expenses for person(s) other than self YES YES NO NO 1 Reimbursement requests must be submitted through Oracle iExpense.

2 Advances are requested via the Travel Advance form and will be issued for per diem amounts. Only employees at the following pay grades are eligible to receive advances:

• Professional: 7-12 (Teachers to Assistant Principals) • Professional Support: 6s-12s • Professional/Technical: ALL • Paraprofessional: ALL • Auxiliary: ALL

NOTE: Advances requested for student meals totaling more than 20 per travel event do not require Sponsors to collect/remit change or itemized receipts, unless requested to by a specific Department.

6.3 ALLOWABLE EXPENDITURE GUIDELINES

Online reservations/bookings must be made through the service‐providers’ official (direct) website only. Use of online travel websites (Kayak, Orbitz, Hotwire, Expedia, etc.) or

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purchasing travel packages (through airlines, hotels, etc.) is not allowed and resulting expenditures may not be reimbursed.

NOTE: The list that follows is not exhaustive to the situations that may occur at a campus or department. For questions not addressed in the examples below, contact the appropriate Business Office Campus/Department Liaison or the Asst. Director of Finance.

1. Out‐of‐state travel – requires advance written approval from the appropriate Deputy Superintendent. All allowable cost rates (hotel, meals, etc.) will be based on General Services Administration Per Diem rates (www.gsa.gov) – the District does not, however, reimburse per diem for incidentals.

2. Airfare – only standard (coach/economy) fare is allowed. Additional fees charged for “preferred” seating or “priority” boarding are not allowed. Early check‐in fees will be reimbursed up to $10 each way only. All receipts and ticket stubs should be provided with the iExpense report. Baggage fees for more than one checked bag or for over size/weight bags will only be reimbursed if checking District supplies/equipment. The District does not cover trip insurance.

3. Hotel – per person costs in excess of $120/night (excluding city hotel occupancy taxes) will not be allowed for travel within the State of Texas. Any exceptions from this policy require advance approval from the appropriate Deputy Superintendent. All itemized receipts for lodging must be provided with the iExpense report.

The District is exempt from Texas state hotel occupancy taxes – a State Hotel Occupancy Tax Exemption Form should be provided when checking in. The District is not exempt from paying city hotel occupancy taxes – they should be reported as part of lodging costs.

4. Vehicle rental – GPS rental will not be reimbursed. Enterprise Rent‐a‐Car is the District’s car rental service provider and should be used unless they do not have an office at the location to which travel occurs. Reservations can be made at 1‐888‐291‐0359 or by using the following link:

http://www.enterprise.com/car_rental/deeplinkmap.do?bid=002&cust=TXS0579

The Direct Bill account number for the District is TXS0579. All rates include unlimited mileage except those for Premium, Luxury, 15‐Passenger, Cargo, and Pick‐up Trucks. Those rates include 200 miles/day, 1,200/week and 3,000/month. Rates also include Loss Damage Waiver and Supplemental Liability Protection. NOTE: Rental of 9‐15 passenger vans is prohibited. Itemized receipts must be provided with the check request.

5. Automobile (mileage) – mileage will be paid at the Texas Comptroller rate. Effective 1/1/16, the mileage rate is $0.54/mile. The total amount of mileage should not exceed the cost of coach airfare. Employees with an in‐District travel allowance may not be reimbursed for travel within the following counties: Dallas, Rockwall, Collin, Hunt, Kaufman, Ellis, Denton, Tarrant, and Johnson.

To be eligible for reimbursement, mileage should be documented through a print out from an electronic mapping source or beginning/ending odometer readings (submitted with the iExpense report).

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6. Meals – employees – if no overnight stay is required, meals will only be reimbursed for travel outside the following counties: Dallas, Rockwall, Collin, Hunt, Kaufman, Ellis, Denton, Tarrant, and Johnson. If overnight stay is required, the daily maximum in‐state reimbursements are: Breakfast ($7), Lunch ($11), and Dinner ($23). On travel days, meals will be prorated when travel extends outside of normal business hours. Employees attending vendor or conference‐provided meals while traveling are prohibited from requesting per diem amounts for that meal.

7. Meals – non‐employees – in lieu of per diem, actual costs of meals for students or chaperones will be allowed. Breakfast, lunch, and dinner should be reported separately through iExpense – itemized receipts must be attached to the report. The number of persons eating, individual names (if less than 10), and the group should also be included. Groups of 10+ must use a Sales Tax Exemption Certificate. Tips in excess of 20percent are not allowed.

8. Meals – business meetings – in lieu of per diem, actual costs of meals for business meetings occurring while traveling will be allowed. Breakfast, lunch, and dinner should be reported separately through iExpense – itemized receipts and a Food Purchase Purpose Statement must be attached to the report. The number of persons eating, individual names (if less than 10 people), and the name of the group should also be included. Groups of 10 or more should use a Sales Tax Exemption Certificate. Tips in excess of 20percent are not allowed.

9. Supplies/Materials – such purchases made while traveling should be made from approved vendors only. Itemized receipts must be attached to the iExpense report. Those items purchased while inside the District should be purchased using a Purchase Order or P‐Card.

10. Other business‐related expenses – usual charges for business‐related taxis, buses, tips (less than 20percent), parking, telephone calls, internet connections, etc. incurred while traveling will be reimbursed. All expenses in excess of $20.00 must be supported with a receipt.

11. Chaperone/sponsor costs (student travel) – hotel cost limits above do not apply to student travel, including costs for chaperones or sponsors of such trips. For these trips, the actual cost of meals will be reimbursed.

12. Personal Costs – employees will be expected to pay for all personal costs (travel costs for spouse, movies, personal phone calls, laundry, alcohol, bottled water, candy, etc.)

13. Sales Tax – should not be paid on any District‐funded purchases (199 or 461) or on purchases made with a P‐Card.

6.4 STATE/FEDERAL GRANT FUNDS GUIDELINES Individuals expending grant funds should contact the applicable program manager for specific guidelines/restrictions. NOTE: grant fund expenditures must adhere to the more restrictive of either state/federal or local policies. The following are examples of more‐restrictive state/federal policies regarding travel expenses: o In State Hotel ‐ Hotel reimbursement cannot exceed the GSA published rate as listed in

the Federal Per Diem Rate Map on the Texas State Comptroller’s Website (http://www.gsa.gov/portal/content/104877) OR $120/night, whichever is LESS. If the area is not listed on the GSA website, the maximum allowed is $85/night.

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o Out of State Hotel ‐ Hotel reimbursement cannot exceed the GSA published rate as listed in the Federal Per Diem Rate Map on the Texas State Comptroller’s Website (http://www.gsa.gov/portal/content/104877). If the area is not listed on the GSA website, the maximum allowed is $89/night.

o In State Meals ‐ The daily maximum in‐state reimbursements is $46: Breakfast ($8), Lunch ($12), and Dinner ($26).

o Out of State Meals ‐ The meal reimbursement rate is the based on the GSA published rate as listed in the Federal Per Diem Rate Map on the Texas State Comptroller’s Website (http://www.gsa.gov/portal/content/104877) unless the area is not listed on the GSA website. In that case, the reimbursement is up to $46/day: Breakfast ($8), Lunch ($12), and Dinner ($26). The Incidental Rate on the GSA page will not be reimbursed.

o Itemized receipts are required.

o Tips, gratuities, and incidentals will not be reimbursed.

o Travel must be directly related to the grant award.

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Travel Approval Request 1

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Travel Reimbursement Request 1

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Section 7: Fixed Assets, page No. 1 (pdf page No. 25) revised 6/30/15

7.1 DEFINITION Fixed assets are purchased or donated items that have a unit value of at least $5,000 (including delivery and installation costs) and have a useful life of at least one year. These items and the inventory monitoring of them, is the responsibility of the Business Office Project Accountant.

7.2 PURCHASES OF FIXED ASSETS Campus personnel should contact the Project Accountant prior to purchasing fixed assets from Activity funds.

Section 8: Warehouse Procedures & Disposal of Non‐Fixed Assets, page Nos. 1‐2 (pdf page Nos. 27‐28) revised 6/30/15

8.1 GENERAL WAREHOUSE INFORMATION Internal requisitions, items stocked in the warehouse, are requested in the Oracle system through iProcurement using a “shopping cart” method. These requisitions will follow the appropriate campus or departmental approval hierarchy and will, after final approval, generate an internal Sales Order that will be picked by warehouse personnel and delivered on the next scheduled delivery day. 8.1.1 Deliveries

Internal Sales Orders are printed at 8:00 AM each work day for delivery the following morning. Internal requisitions that have not been approved by 8:00 AM on the day before delivery will be processed for delivery during the next regularly scheduled day.

8.1.2 Backorders Items not available at time of order will be automatically placed on backorder and delivered on the next scheduled deliver day after receipt of goods.

Section 9: Procurement/Payment Methods, page Nos. 1‐7 (pdf page Nos. 27‐ 36) revised 6/30/15

9.1 GENERAL INFORMATION Below is a brief summary of all District procurement methods:

Purchase Orders (POs)

•Are created through Oracle iProcurement Module •Shall have a minimum value of $1001 •May be changed (by request) within seven calendar days of issuance2 •Are valid 60 days from issuance (finally closed 90 days after issuance)3

Purchasing Cards (P‐Cards)

•Can be requested from the Purchasing Department •Require use of approved/contracted suppliers (similar to POs)4

•Must be reconciled through Oracle iExpense Module •Have spending limits (transaction/daily/total balance)

Petty Cash •Used for making change or immediate payments under $100 •Should be reconciled timely through Oracle5 •Should not be used in the place of iExpense (travel reimbursements)

1 Controlled Assets (sound systems and other audio equipment; cameras; tvs, video players/recorders; computers – desktop and laptop; data projectors; smartphones, tablets, and other hand‐held devices) must always be purchased using a PO, regardless of cost.

2 Requests should be submitted through iProcurement. See Section 9.2 for more details.

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3 Includes requisitions automatically approved through punch‐outs, templates, and/or the Main Store. See Section 9.2 for more details.

4 Written requests to use non‐contracted suppliers must be submitted to the Purchasing Department A‐location email account at least three days prior to the planned date of purchase. See P‐Card Manual for detailed instructions.

5 Instructions on Petty Cash reconciliation can be found on the Business Office intranet site.

All tangible items and services, except those excluded in Section 9.4, must be ordered using a Purchase Order (PO) or a Purchasing Card (P‐Card). Issuance of the Purchase Order must precede the ordering of such goods and services. Ordering using any other method is considered a violation of policy and may result in personal liability for the purchase or non‐reimbursement. Per footnote 5 above: Petty Cash Procedures 1. Complete a Petty Cash Form (available on the Business Office/Forms intranet page

(http://home/pages/Business‐Forms)) a. This form is used to request specific denominations/coin b. “Save As” this form and rename it to match the Oracle Batch Name used above c. The “Difference” will auto calculate based on the amount of the petty cash request and the denominations/coin selected and should always end up at zero.

2. Submit the following items to the Business Office (Box 132) for validation and payment: a. Petty Cash Cover Sheet (found on Business Office/Forms intranet page) b. Oracle Invoice Register Report c. Petty Cash Voucher and related receipts d. Food Purchase Form (if applicable) e. Petty Cash Form (completed above)

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9.2 PURCHASE ORDERS The diagram below illustrates the Purchase Order process:

The PO process begins when a requisition is submitted through Oracle iProcurement. The following information should be noted while submitting a requisition:

• Provide a detailed description of product/service (even when a quote is present)

• $0.00 lines should not be entered when using Federal or Project funds. These items should be added to the description of a value line using “to include at no additional cost”.

• The “Note to Buyer” section should be used to provide contract information and any special instructions/notes

• Similar items with different prices must have different descriptions to prevent Oracle from combining like-items.

• Internal Requisitions require the “shopping cart method and will generate an Internal Sales Order. See Section 9.3 for more information.

• Changes (after submission) can be requested according to the following guidelines: 1. Quantity changes for tangible items must be made within seven days of issuance 2. Price changes for tangible items may be requested until the PO is closed 3. Any changes for services may be requested until the PO is closed but must be approved

prior to delivery of service.

As information is entered, the system automatically creates an encumbrance which reduces the available budget in the account codes being used. This encumbrance remains until a matching invoice is input or the purchase order is finally closed.

Requisitions approvals are determined by the HR hierarchy and the nature of items being ordered. Once approved at the initial campus/department level, requisitions are automatically routed to the next level. The Purchasing Department has final approval of all requisitions and will notify the submitter if one is not approved.

Once a requisition has been finally approved, a purchase order number is assigned and the purchase order is sent directly to the supplier. Items/services ordered should be delivered to the site indicated on the purchase order. If a site does not receive the order within a reasonable time, the vendor should be contacted regarding the status of the purchase order and shipment.

Within 24 hours of receiving items/services ordered, the requisition submitter must use Oracle to mark the order as “received”. To avoid problems and/or financial penalties, the following should be verified during the receiving process:

• Site – ensure all packages are addressed to the site which ordered them • Number of Packages – ensure number of packages received agrees to packing slip • Contents – match items received against those orders and check for any damages

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Only the items (and quantities) actually received should be indicated as such in Oracle. If the order has issues (overages, damage, wrong products, etc.), contact the supplier to coordinate return.

Contact the Purchasing Department with any vendor shipment/return issues.

Once a purchase order has been received on in Oracle and an invoice is received, the Business Office matches the charges to the items received. At this point, the PO is closed, the original encumbrance is released and an actual reduction in budgeted funds is created. If there are no issues on the invoice (or once they are resolved), the supplier is paid according to the payment terms of that supplier. Suppliers cannot be paid until the order has been received in Oracle. Penalties assessed due to delayed Oracle receiving will be charged to the account code using in making the purchase. NOTE: The Business Office may require completion of an Invoice Discrepancy

Explanation Form to reconcile differences between invoices, receipts, and purchase orders.

Purchase orders for which either the items/services ordered and/or the related-invoice are not received will be finally closed after 90 days of issuance. POs for construction, furniture, live specimens, musical instruments, student agenda books, and certain services may be kept open longer by request through the “Note to Buyer” field. Requests for purchases that can be broken into smaller units over an extended period of time will be rejected in favor of issuing multiple POs.

If a PO does not automatically close after 90 days – or – the remaining encumbrance is too large to wait, follow the instructions below to request a purchase order be manually finally closed:

1. Complete a “Request to Final Close Purchase Order(s)” form 2. Email completed form to Business Office Accounts Payable (AP) Manager for approval 3. Upon AP Manager approval, form will be forwarded to the Purchasing Department to process the

manual close

ALL QUESTIONS OR ISSUES RELATED TO REQUISITIONS OR PURCHASE ORDERS SHOULD BE DIRECTED TO THE PURCHASING DEPARTMENT.

9.3 PROCUREMENT – INTERNAL

Warehouse Items (internal requisitions)

•Requested using "shopping cart" method in Oracle iProcurement •Follow same requisition approvals as external purchase order process •Generate Internal Sales Order processed by warehouse personnel

GISD Print Shop Orders

•In-District department providing customized printing services •Orders submitted through "Printing Quotation" form (GP-150) •Charges for orders processed by Business Office through monthly expense transfer

When ordering Print Shop items, the following should be considered: • Completed Printing Quotation forms should be returned to the Print Shop along with samples of

the document requested (if applicable) • Printing Services will produce a draft of the request and return it to the originator for approval • If no corrections needed – sign and return the approval form • If corrections needed – return the draft with corrections made in red ink. Corrections will be made

and a second draft will be prepared and returned for approval. • Production will only begin once approval has been received by Printing Services

9.4 PAYMENT METHODS – EXTERNAL SUPPLIERS

As part of the purchase order process described above, District vendors/suppliers are automatically paid when invoices are entered and matched to the receipt of items/services. This following briefly describes payment methods that are necessary when a purchase order is not used:

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Check Requests •Requested through Oracle Check Request module •Should not be used for orders made on a Purchase Order or P-Card •Supporting documentation must be sent to Business Office •Requires approval from supervisor and Asst. Director of Finance

Expense Reimbursements

•Requested through Oracle iExpense module •Requires submission of itemized receipts •Must be reconciled through Oracle iExpense Module •Should not be used in place of a Purchase Order

Check Requests may be used to pay for the items/services listed below. Exceptions to this list require advance approval of the Asst. Director of Finance.

• Field-trip payments • Scholarships • On-site instructional programs1 • Certifications/licenses • Competition judges • Postage • Accompanists • Courier services • Refunds to parents/students • Building permits • Donations • Physical exam/drug-testing fees • Game officials (non-GISD employees) • Attorney fees • Facility deposits2 • Tuition reimbursements • Hotel deposits2 • Insurance deductibles • Conference registrations • Notary applications/renewals • Memberships2 • Interpreters

1 On-site instructional programs include: magicians; puppeteers; jugglers; speakers/presenters 2 These items/services should be procured using a PO or P-Card when accepted by the vendor

9.6 PAYMENT METHODS – INTERNAL (TRANSFERS)

Sometimes, one campus/department/activity owes another campus/department/activity for services provided or items purchased. In these situations, a Transfer Request form should be filled out and submitted (with supporting documentation) to the appropriate Business Office Campus/Department Liaison for processing.

Transfer Request forms should be submitted: • To Correct an error in account coding • To Cost Share the purchase of an item/service with another campus/department/activity • To Bill a campus/department/activity for services/items provided • To Adjust a negative Activity balance

Transfer Request forms should not be submitted: • Until an expense is actually incurred (recorded in the account from which it will be moved) • To adjust budget amounts

9.7 APPROPRIATE PROCUREMENT/PAYMENT METHOD REFERENCE GUIDE

To provide a practical reference for assisting principals/department heads in making decisions regarding appropriate procurement/payment methods, the following contains guidance on the most commonly questioned expenditures.

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Section 10: Purchasing Policies/Procedures, page Nos. 1‐ (pdf page Nos. 37‐ ) revised 6/30/15

10.2 AUTHORITY TO OBLIGATE THE DISTRICT All purchase commitments shall be made on a properly drawn and issued purchase order, procurement card, properly signed contract, or a check request in accordance with administrative procedures located in Section 9.4 of this manual. Personnel are not authorized to place orders verbally or utilize any other method to obligate the district.

10.3 SELECTING SUPPLIERS Not every supplier in the Oracle database is an approved supplier. An approved or contracted supplier is defined as a company which has been awarded a contract in compliance with the law. Approximately 350 contracts and 1,500 suppliers have been approved through the use of competitive solicitations in accordance with local, state, and federal statutes; local board policy; and

Description of Expenditure Purchase

Order

(PO)

P-Card Petty

Cash

Check

Request

Exp.

Reimb

.

Most tangible items & services > $100 YES YES NO N N

Most tangible items & services < $100 N YES NO YES N

Immediate payments < $100 N YES YES N N

Controlled Assets (any value) YES NO NO N N

Book Clubs (Troll, Scholastic, etc.) YES YES NO N N

Field-trip payments (admission, dining, etc.) YES YES NO YES YES (meals)

On-site performers (magicians/jugglers, etc.) YES YES NO YES N

On-site speakers/presenters YES YES NO YES N

Competition judges YES YES NO YES N

Accompanists/Mariachi instructors YES YES NO YES N

Refunds (parents/students) N NO NO YES N

Donations N NO NO YES N

Game officials (non-GISD employee) N NO NO YES N

Facility deposits YES YES NO YES N

Hotel deposits YES YES NO YES N

Conference registrations YES YES NO YES YE

Memberships/Dues YES YES NO YES YE

Scholarships N NO NO YES N

Certifications/licenses YES YES NO YES YE

Postage YES YES YES YES N

Courier services YES YES NO YES N

Building permits YES YES NO YES N

Physical exam/drug-testing fees YES YES NO YES N

Attorney fees YES YES NO YES N

Tuition reimbursements N NO NO YES N

Insurance deductibles YES YES NO YES N

Notary applications/renewals YES YES NO YES N

Interpreters YES YES NO YES N

Catering services YES YES NO N N

Fundraiser payments (book fairs, etc.) YES YES NO N N

Contract labor/consultant fees YES YES NO N N

Periodicals/subscriptions YES YES NO N N

Lease/Rental payments YES YES NO N N

Musical productions YES YES NO N N

Prom/Homecoming YES YES NO N N

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best business practices. Most goods and services required by the district can be obtained through one of the approved suppliers. The two-step process listed below will assist you in determining which suppliers may be used: 1. Search items in Oracle iProcurement using the search feature (refer to the Oracle iProcurement

Training Material). Items purchased through the iProcurement Store do not require approval by the Purchasing Department and purchase orders will be immediately faxed to the supplier.

2. If goods and services are not found in Oracle iProcurement, run the GISD Approved Supplier Report to view an extensive list of approved suppliers and contracts. The report may be accessed through iProcurement or GISD Employee Self Service by selecting the “Report” Tab. Instructions for running the report are available at: http://home/pages/Purchasing-Documents_and_Links Specific ordering instructions are provided for each supplier. If directed to use a non-catalog request, the requisition must be entered into Oracle and routed to the buyer for approval. As a minimum, the following should be included for a non-catalog request: • Provide a detailed description of the product and service, including: make/model #; ISBN #; item

#; color; size; etc. (if applicable) • Provide contract information in the Note to Buyer section as instructed in the ordering instructions

provided. Additionally, include any special instructions/notations needed (i.e., “This is special pricing not available for these items as loaded in the Main Store”), when applicable.

• Include the quantity of items desired in the quantity field and the price in the price field

• Select the appropriate purchasing category code EXAMPLE: Note to Buyer Description Qty UOM Price Total

Amount

CPA #5143727

“Gone with the Wind” by Margaret Mitchell, ISBN 0‐446‐36538‐6

30 Each $7.99 $239.70

Shipping & Handling 1 Each $4.50 $ 4.50 Category Code: Instructional Material. Books, Library NOTE: Purchasing Department reserves the right to approve or reject/return requisition(s) based on information provided. Each year, the district will add additional contracts to the iProcurement Module to reduce the need to search for contracts in two places. Goods and services must be purchased using the contractors approved by the Board of Trustees. Requisitions submitted using approved/contracted suppliers will be approved within 24 hours if submitted using the correct category code and contract number (both items are available on the district intranet). Each employee should ensure that one of the 1,200 approved/contracted suppliers cannot provide a product or service which meets the intended purpose before submitting a requisition to use a nonapproved/contracted supplier. It is important to differentiate between meeting an educational purpose and a user preference. Most employees have a preference to use a certain product or service which may not be available from a contracted supplier, but a similar product or service (which can meet the intended purpose) is available from an approved/contracted supplier. The approved contractor should be used. Building principals and department administrators should ensure their employees are aware of the difference between purpose and preference.

10.3.1 SELECTING NON-APPROVED SUPPLIER FOR PURCHASES UNDER $5,000 EXCEPTIONS: Purchases for travel expenses, offsite dining, student/staff offsite instructional programs, professional memberships, registrations, and purchases made with fund 865 or 876 are exceptions to the requirement(s) stated for non-contracted purchases, and should be treated/processed in the same manner as any non-contracted purchase(s) under $5,000, negating the requirement to search for approved suppliers.

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After searching at least two approved suppliers without finding the appropriate item or service, submit a non-catalog request in lieu of a telephone call or e-mail requesting approval. A properly submitted non-catalog request will provide the required information needed by the purchasing department to make a decision. The requisition will be routed to the appropriate buyer, and will require additional time based on the value of the purchase and other expenditures made in the same commodity category for the year. Approval or rejection will occur within three business days from receipt of the requisition. Note to Buyer Description Qty UOM Price Total

Amount

Item not available through contracted supplier.

Easel Double Adjustable Dry Erase Panels, 4’x6’, Item #

5 Each $13.49 $67.45

Checked with: Staples and School Specialty

1234567‐890

10.3.2 SELECTING NON-APPROVED FOR PURCHASES OVER $4,999

Complete the Spot Purchase Request Form available at http://home.garlandisd.net/pages/Business-Forms for purchases exceeding $4,999. Purchases of this value may require four to six months to complete if competitive bidding is required (refer to Section 10.5). Contact the Purchasing Department as soon as the need for the good and or service is identified. Prior planning is paramount!

10.9 SOLE SOURCE The Purchasing Department is responsible for determining if a supplier qualifies as a sole source provider. A letter from the supplier in itself is insufficient. The Purchasing Department must be reasonably assured that competition is precluded because the supplier is the exclusive supplier or provider of the item(s) or service(s) and that it holds the patent or copyright, or that the product(s) or service(s) is/are the result of a secret process or monopoly. Submit a completed Sole Source Determination Form to the Purchasing Department if you believe a good or service qualifies as a sole source. Submission of the form provides the necessary information to make a determination and should not be construed as an approved purchase.

10.10 REQUESTING A NEW SUPPLIER By using the internet procurement web requisition for a “Non-Catalog” request, users may request a new supplier be added to procure non-contracted goods and services. The “New Supplier” contact information (phone number, fax number, contact name, company name) should be included on the requisition. The requisition will flow through the appropriate campus or department approval process and reach the auto create requisitions process. The buyer responsible for the commodity associated on the requisition will evaluate the requested item or service and attempt to source it to an already identified approved supplier. If the buyer determines there is no suitable supplier currently available, then they may use the “New Supplier” contact information to contact the requested source to complete the supplier setup at http://www.garlandisd.net/departments/purchasing/howto.asp. No purchases may be made in the GO system until a valid supplier has been completely setup.

10.11 SAM’S CLUB ORDERS

Campuses/departments wishing to shop at Sam’s more frequently than once a week or to purchase perishables may purchase a GISD campus/department membership on a cash-and-carry basis. Membership is restricted to GISD employees and all purchases should be District-related. District PCards may be used for these purchases.

10.12 RECEIVING Items ordered with a Purchase Order will be delivered to the site from the Supplier. It is imperative to mark items as received in Oracle within 24 hours of physical receipt. Suppliers cannot be paid until the receiving activity has taken place. The district is required by law to pay bills in a timely manner or

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incur financial penalties for the delay. Penalties incurred will be charged to the budget code provided on the purchase order.

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Appendix Nine Applicable Portions of the GISD Purchasing Card Program Employee Manual

February 2016 revision

PURPOSE Page No. 4

This Procurement Card (P-Card) program is designed to delegate the authority and capability to efficiently purchase items directly from the supplier in compliance with all procurement laws and local policies. Use of the card will result in the following benefits:

Reduce/eliminate travel advances Significantly reduce the number of purchase orders issued Streamline invoice payments Reduce the numbers of voucher/payment (Check Request) Eliminate blanket PO’s. Reduce cash expenditures

Issuance of a P-Card represents trust in district personnel and empowers employees to act as responsible fiduciary agents to safeguard and protect Garland ISD. A number of unique controls have been developed for our P-Card Program. These controls ensure that the cards will be used for only official operational purchases and within specific dollar limits. This Cardholder manual has been developed to assist you in better understanding the program by answering some typical questions you may have and by providing step-by-step instructions on the use of the P-Card. Please take the time to read and understand the process before you begin using your P-Card. Improper use of the P-Card may result in disciplinary action up to, and including, termination of employment. GUIDELINES FOR P‐CARD USAGE, beginning on page No. 4 Purchasing Guidelines Cardholders may make purchases for district items only. The P‐Card is a supplement to Purchase Orders (PO’s),Check Request, Petty Cash and Reimbursements. As with the other purchasing methods, the following conditions must be met when using the P‐Card:

Bank of America P‐Cards will be issued in the cardholder’s name with the Garland ISD emblem and the wording “Official Use Only” clearly shown on the card. This card is for business purposes only and may not be used for personal purchases.

Each cardholder is responsible and accountable for their P‐Card. DO NOT SHARE YOUR CARD WITH ANYONE!

The cardholder is responsible for verifying all purchases and transactions utilizing Oracle iExpense Module. This verification must occur weekly and all receipts forwarded to Accounts Payable within three weeks from the Oracle transaction date.

The person responsible for completing the expense report should view IExpense training at http://lntc02.garlandisd.net/PlayerPackage/data/toc.html.

Requesting a Procurement Card, page No. 6 A building principal, director, or member of the Superintendent’s Management Team may request cards for district employees. Individuals must be active, permanent employees to qualify for a card. Prior to issuance of the P‐Card(s), individuals must complete the following process:

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Supervisor must submit a completed and signed P‐Card Request Form (Attachment 2)

Complete Cardholder On‐line Training Session and Assessment *

Read the Procurement Card Manual

Read and sign the Purchasing Card User Agreement Form (Attachment 1) *Cardholders utilizing the GISD Management Profile are not required to complete the training or assessment due to the nature and use of the card. Note: The travel card may be used for certain travel expenses of District students and employees. A property card holder may act as the Travel Coordinator, if desired. Upon receipt of your application form, the Program Administrator will approve or reject the application. Rejected applications will be returned to the submitter with the appropriate reason code identified. The bank will send the P‐Card(s) to the Program Administrator. This process normally takes two to three weeks. The cards will be activated and issued to the designated cardholders after they have completed training.

P‐Card Envelopes/Administrator Approval, page Nos. 49‐50

All P‐Card transactions must have accompanying receipts in order to be considered for review and subsequent approval. All transaction receipts must be submitted in the iExpense Receipt Envelope (Attachment 3) and forwarded to the Fund Approver (Principal/Dept. Head) for review and approval (sign‐off/signature). Approval of the contents of the envelope, as evidenced by the Administrator‐signature, shall stand as acceptance of responsibility, and acknowledgement of compliance with District policies (by the Administrator), for all P‐Card transactions submitted for reconciliation. Once the Fund Approver has reviewed and approved the expense report and support documentation, the envelope should then be forwarded to the Accounts Payable Department. Complete the envelope by indicating the following:

Printed Name and Signature

School/Department Name/Location Number

Expense Report Date/Number

Principal/Department Head Name/Signature

Check appropriate statement/box indicated on form

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ATTACHMENT 3, page No. 62

Record Keeping & Reconcilations, page Nos. 49‐50 Request for funding a card will be rejected if the school or department has not reconciled the card in accordance with district procedures.

Audit, page No. 52

All Procurement Card Statements and receipts will be audited to ensure that purchases are in compliance with District procedures and policies. Failure to follow the proper procedures could result in revocation of the Procurement Card or other appropriate disciplinary actions. Use of the Procurement Card is always subject to review by your Administrator, Program Administrator, and Internal Auditor. It is critical that you maintain good records. The primary purpose of an audit is to ensure the proper expenditure of funds under this program. A secondary purpose is to track data on how, where, and for what cards are used. As a result of the audit, the Procurement Card program may be modified so the program is more beneficial.

Compliance Enforcement, page Nos. 55‐56 GISD has established a 3‐strikes‐you’re‐out methodology for non‐compliance ‐ with the guidelines and procedures of the P‐Card program. All potential violation notices shall be forwarded to the Deputy Superintendent of Business for investigation. If sufficient evidence suggest a violation has occurred, the immediate supervisor of

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the cardholder will be notified. Upon determination that an offense has taken place, a strike is issued and the immediate supervisor notified. If the supervisor was involved by failing to properly reconcile the P‐Card transaction, a strike will also be issued to the administrator. STRIKE 1: E‐mail Notification to Cardholder, immediate Supervisor.

1. 1st missing receipt

2. 1st violation of policy

3. 1st delay in allocating and/or approving P‐Card transactions

4. 1st submittal of P‐Card envelopes including statements and receipts more than 3 days late without prior approval from the Accounts Payable Department.

STRIKE 2: Written email communication to Cardholder, immediate Supervisor and Director. o 2nd missing receipt o 2nd violation of policy o 2nd delay in allocating and/or approving P‐Card transactions o 2nd submittal of P‐Card envelopes including statements and receipts

more than 3 days late without prior approval from the Accounts Payable Department.

o 1st split transaction STRIKE 3: Direct verbal and written email communication to Cardhholder, immediate Supervisor and

Director and Director’s Supervisor. Cancellation of the P‐Card and /or Further Employee Reprimand. More serious offenses may result in further disciplinary action for the employee up to and including termination.

If there is a continuing pattern of non‐compliance or a serious violation in the use of the P‐Card, the card may be permanently cancelled.

3rd missing receipt

3rd violation of policy

3rd delay in allocating and/or approving P-Card transactions

3rd submittal of P-Card envelopes including statements and receipts more than 3 days late without prior approval from the Accounts Payable Department.

2nd split transaction

1st Personal use of the P-Card

Supervisor/Administrator Approval Responsibility, page No. 56

Three violations for approval of unauthorized purchases may result in loss of all P-Cards for the school/department, job reassignment, demotion, termination, and/or criminal prosecution dependent on the nature of the offenses.

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Appendix Ten Applicable Portions of the GISD 2015-2016 Field Trip Manual

The purpose of this Field Trip Manual is to provide information to principals and staff in planning and preparing for field trips of all types, regardless of the form of transportation. (page No. 1) The Field Trip Process: General Information, page Nos. 5 ‐ 7 I. Pre‐Trip Planning

A. The Field Trip Request The district has provided a Field Trip Checklist (see Forms section) to guide sponsors through the field trip process. The campus sponsor will complete and retain each required document as part of a field trip packet which will be used for future planning and possible documentation in the event of any issues that may occur during the trip. The process begins with a Field Trip Request Form and required accompanying documents being submitted to the campus principal within the following district timeframes:

Field Trip Location: Completed Request Submission Deadline:

Within Garland ISD or Dallas County At least 21 days prior to the trip

Outside of Garland ISD but within Texas At least 21 days prior to the trip

Outside of Texas, but within the continental United States

At least 30 days prior to the trip

Outside the continental United States At least 45 days prior to the trip *Completed requests include: Field Trip Checklist, Field Trip Request Form, Activity Fund Fundraising Application and Financial Recap, transportation documents, and one copy each (in English and Spanish) of the Itinerary, the Parent/Guardian Approval and Release Form, and the Release of Liability for Student Participation in Trip with a Destination Outside of the United States, if applicable. In addition, any trips that utilize Title I funds must also submit a TEA Justification Form and Title I Lesson Plan Form.

B. Principal Approval

Once the completed field trip request is received, principals will follow these district guidelines for approval of school‐sponsored field trips:

Any overnight trips or trips outside of Dallas County will require additional approval by the area director.

If outside of Texas, additional approval is required from the appropriate director of the program area (Athletics, Fine Arts, Career and Technical Education, Special Education or area director) and the associate superintendent of Curriculum, Instruction, and Assessment.

Trips outside of the United States require additional approval of the superintendent.

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C. District Approval

If the field trip requires additional approval at the district level (as indicated above), the principal will forward the Field Trip Request Form and accompanying documents to the appropriate staff member to begin the district level approval process. This may be done using hard‐copies or emailing the required forms.

The goal for completing the district level approval process is no more than five school days.

The Field Trip Request Form will be returned to the campus principal at the completion of the approval process with required signatures of approval or justification for denial of the request.

E. Special Events

1. UIL Tournaments and Athletic/Academic Events Athletic, academic, and UIL related tournament events do not require the submission of a Field Trip Request Form.

I. The Trip, page Nos. 8‐9

• Forms and Documents

All additional documents listed on the Field Trip Checklist must be completed one week prior to departure (two weeks for trips outside the continental United States).

One copy of the following forms must be given to the campus principal (or designee) prior to the trip and kept on file in the office: Field Trip Checklist, Field Trip Itinerary, Field Trip Student Roster, Parent/Guardian Approval and Release Forms (one per student – signed by parent), Night Shift Schedule, and Field Trip Chaperones and Accessibility Assistants.

II. Supervision The principal and organizing teacher are responsible for ensuring that adequate and proper supervision is provided during any field trip or out‐of‐school activity. The following guidelines are minimal and may be enhanced if the principal or teacher/sponsor/coach deems the activity warrants additional adult supervision. 3. Chaperones must have applied and been approved as volunteers in the

Raptor system and meet District requirements noted in the Chaperone Statement Acknowledging Responsibilities and Duties, which must be signed prior to departure.

B. Sponsors will complete the Field Trip Chaperones and Accessibility Assistants form and share with indicated personnel.

C. Chaperones must be given a Field Trip Chaperone Roster of all students assigned to them.

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School Board Policies, TEA Guidelines, Title I Guidelines and UIL Regulations TEA Field Trip Guidelines, page No. 25 Educational field trips are approved, planned instructional activities that involve students in learning experiences that are difficult to duplicate in a classroom situation. These field trips should provide hands‐on activities that encourage students to experiment and ask questions. For audit purposes, your organization must maintain documentation of the field trip and must provide clear evidence of how the expense ties back to an instructional objective. Documentation should include the following:

Destination of each field trip

Costs associated with each field trip

Objectives to be accomplished from conducting the field trip

Teacher’s lesson plan and follow‐up activities Unallowable Costs Related to Field Trips The following costs are not allowable:

Field trips that are not properly documented (as described above) See GISD Field Trip Checklist, Field Trip Request Form, Manual page Nos. 29 – 31, and Field Trip Approval Process flow chart on the following pages:

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Process Flow Chart

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Appendix Eleven

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Appendix Twelve

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Appendix Thirteen Applicable Portions of GISD Oracle iProcurement Technology Purchase Order Directions

Directions Computers Printers Data Drops Apple iPads Classroom Projectors Technology Purchase Order Directions Click on a link at the top of the page and choose the approved Technology item you want to purchase and the current item description. PO Check List:

Create Purchase Orders in Oracle (i.e., cameras, tablets, data drop, computers, printers).

Change the Delivery information in the Deliver To Location box to read Technology Center except for Data Drops. This is for configuration and installation purposes.

Directions Computers Printers Data Drops Apple iPads Classroom Projectors Printers & Scanners

The Technology approved printers & scanners that GISD will support are listed below.

Staples Technology Solutions is the district approved/awarded vendor for Printers and Scanners. Please only order printer/scanner products from this list for district use.

Requisition‐Purchase Orders shall be processed within Oracle I‐Procurement (Staples Corporate Express Punch‐Out). Enter the Oracle

I‐Procurement Staples Punch Out, click on the Shopping List Tab and scroll down to Printer/Scanners. All awarded products should be listed for ordering.

Special Notes:

• All printer/scanner products ordered must be shipped to the District’s Technology Department for configuration prior to delivery and installation to your department/school.

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Appendix Fourteen Applicable Portions of GISD Intranet Tech Bids – Printers

The Technology approved printers & scanners that GISD will support are listed below.

CDW is the district approved/awarded vendor for Printers and Scanners. Please only order printer/scanner products from this list for district use. Special Notes: All printer/scanner products ordered must be shipped to the District’s Technology Department for configuration prior to delivery and installation to your department/school. Shipping Instructions: Change the Deliver‐To Instructions on ALL Technology equipment to read Dr. Marvin D Roden Technology Center. This is for configuration and installation purposes.

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Appendix Fifteen Applicable portions of the Texas Education Agency Financial Accountability System Resource

Guide (TEA FASRG): Module 3. Purchasing Update 14 3.1.1. Purchasing Policy, page No. 3 (pdf page No. 8) Accurate record‐keeping and documentation should be a fundamental element of the procurement process. Precise and systematic record‐keeping and records management withstands the constant scrutiny of various interest groups including vendors, the general public, and outside agencies as well as internal groups which are the users or customers of the purchasing system. This records management function should support the school district's overall information management plan described in the Data Collection and Reporting module and generally provide for:

• Both the flow and retention of forms including requisitions, purchase orders, petty cash and cash reimbursement receipts.

3.2.3.8. Petty Cash Purchases, page No. 27 (pdf page No. 32) A petty cash fund is used to reimburse employees for small expenditures for district supplies or services and to make small district purchases. Such a fund can save time, paperwork, and associated administrative costs. Authorization to purchase from this source should be clearly defined in district or campus procedures and the dollar amount for each purchase should be limited (usually between $50‐$100). Purchases made with petty cash may occur at both the campus and departmental level. It is important that petty cash purchases be kept at a minimum and that accurate accounting records be maintained for all purchases by employees who have been assigned as custodians of the petty cash funds.

3.2.4. Purchase Orders, page No. 28 (pdf page No. 33) Purchase orders are among the most commonly utilized method for procuring goods and services. As its name indicates, this document serves as a formal order for goods, materials and/or services from a vendor. A purchase order, once approved, is a binding commitment for a district to remit payment to the vendor after the item(s) and an invoice are received by the district.

A purchase order is also an important accounting document. It contains information on the expenditure to be made and the account code to be charged. Once issued, the purchase order encumbers funds, which serves as an expenditure control mechanism. Finally, the purchase order is utilized in the accounts payable process as it documents that an order has been received and accepted by the user and payment can be made to the vendor.

3.2.5. Requisition Process, page No. 28 (pdf page No. 33) A requisition is an internal document by which a campus or department of the district requests the purchasing department to initiate a purchase order. It is a request

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generated manually or electronically (through use of automated systems) for the purchase of supplies, services, equipment, etc.

3.2.5.1. Approval of Requisitions, page No. 28 (pdf page No. 33) Requisitions should be initiated by those having proper authority, as defined in the district purchasing policy manual. Requisitions initiated by instructional, maintenance and support personnel should then be approved by the appropriate person, either the principal, department head or superintendent. Requisitions which require expenditures from the Special Revenue Fund should be approved by the program administrator. Section 44.052 Texas Education Code states that a superintendent that approves any expenditure of school funds in excess of the amount appropriated for that item(s) in the adopted budget commits a Class C misdemeanor offense. Consequently, close supervision and monitoring of the availability of budget dollars and of the approval process for requisition are important elements of a district’s purchasing process.

3.2.5.2. Requisition Format, page No. 29 (pdf page No. 34) Requisitions should include certain items: • A description of items to be purchased • The quantity needed • A suggested vendor (should be from the district’s approved vendor list) • The code of the account to be charged The requisition should be in a standard format so that the information can be readily identified and transferred to a purchase order. If proper control procedures are used, the requisition and the purchase order can be combined on one form. For example, an unnumbered requisition, once properly approved, may become a numbered purchase order.

3.2.5.3. Flow of Requisitions, page Nos. 31‐32 (pdf page Nos. 36‐37) Requisitions are received by the district’s central purchasing department or department responsible for this function. In smaller districts requisitions may be received by the business office or by the superintendent. At this time, the requisition should be reviewed for the following: • Accuracy • Availability of funds • Proper signatures • Adequate description • Proper account coding • Overall completeness The request is then assigned a purchase order number, vendor number (if applicable), purchase order date, and a cancellation date. The district should ensure that the

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appropriate competitive purchasing method is determined and performed before the requisition is approved for processing. After approval by the designated authority, a purchase order is issued to the vendor.

3.2.5.4. Purchase Order Process, page Nos. 32‐33 (pdf page Nos. 37‐38) The purchase order is the written evidence of orders placed as a result of properly initiated and approved purchase requisitions. A purchase order should be of a standard format to facilitate processing and should contain the following items: As indicated earlier, purchase orders start with a requisition which may be prepared manually or electronically. Requisitions originate with the user or user department and describe the item to be purchased, the quantity, pricing (if known), the account to be charged, and normally a suggested vendor. From the requisition a purchase order authorizing the purchase is prepared. Most purchase orders have multiple copies which may include a(n): • Vendor Copy which is sent to the selected vendor • Accounting Copy which is sent to the district's business office and used for encumbering funds from the proper account • Receiving Copy which is sent to the accounting department when the order is received confirming that payment should be made according the district's accounts payable process • User or File Copy which is kept by the user department for financial management purposes

3.2.5.5. Approving and Processing, page Nos. 33‐34 (pdf page Nos. 38‐39) The purchase order should be approved through one central office by a responsible, designated official who is educated about purchasing law, policies, and procedures. In larger districts the purchase order may be approved by the purchasing agent; in smaller districts, by the superintendent. The purchasing department may maintain a record of all purchase orders issued for control purposes. The log should include the date of submission, purchase order number, vendor name and campus/department name.

3.2.5.7. Emergency Purchases, page Nos. 34‐35 (pdf page Nos. 39‐40) Two types of emergency purchases are made in districts. One type results from an eminent threat to the health, safety, or welfare of students. Such purchases must comply with state law and may be made only after a formal board action declaring an emergency and authorizing the purchase. An example of an emergency purchase of this type is the authorization to repair a school after a fire or a natural disaster. Emergency purchases exceeding the dollar amount triggering competitive procurement requirements shall be made in conformance with subsection (h) Section 44.031 Texas Education Code.

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The second type of emergency purchase usually is defined by local policy to provide for the acquisition of goods or services to meet an immediate need such as purchases to repair damage to a facility which may imperil students or the security of the facility. For example, if windows are broken at a school by vandals, an immediate need exists to not only secure the building, but also to protect the contents from damage by the elements. This type of emergency purchase is normally utilized after regular business hours or on weekends and holidays. After purchases of this type are made, a purchase order should be issued after the fact on the next business day. Care should be taken that emergency purchases do not result from improper planning rather than from a true emergency. It is important that the district attempts to eliminate emergency purchases for non‐emergency situations as much as possible and requires that all emergency purchases be fully justified.

3.2.7. Control Environment, page Nos. 37‐38 (pdf page Nos. 42‐43) A district needs a strong control environment in which to perform the purchasing function. The purchasing manual is the primary tool for establishing a strong control environment, and it should be strictly adhered to by employees of the district. If a situation occurs which is not addressed in the purchasing manual, it should be referred to the department responsible for purchasing to determine the proper course of action. If it is likely that this situation may reoccur, it should be considered for inclusion in the purchasing manual. Also, the central purchasing authority should prepare written procedures designed to detect and prevent the circumvention of purchasing laws and rules. If a comprehensive purchasing manual is provided to guide employees and if monitoring procedures are performed by central purchasing, the result will be a strong control environment and few problems. On‐going training on purchasing procedures can enhance controls.

3.3.3.2. Purchasing card (P‐Card) benefits, page No. 49 (pdf page No. 54) Purchasing cards can provide efficiency, transparency and security when utilized correctly. As the volume of transactions increases, more transactions can be processed without the addition of staff to handle labor‐intensive purchase order processes, and employees can focus on doing the job at hand rather than the paperwork (requesting, approving, logging, and ordering). The software tools provided allow supervisors to review details on vendors, timing of purchases, and the actual amount spent. Purchasing staff can focus their attention on the larger dollar, infrequent purchases and their compliance requirements.

3.3.3.3. Purchasing card (P‐Card) benefits, page Nos. 49‐50 (pdf page Nos. 54‐55) In order to avoid fraud and waste, purchasing cards must be controlled closely. Do not expect to free‐up 100percent of the time spent processing purchase orders due to implementation of a P‐Card system.

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Management and Policies The superintendent, business manager, human resources director, and procurement director must work together to set and enforce policies and procedures. It should be clear that misuse and abuse will not be tolerated. Two ways of demonstrating this are including the use of the card as a factor in performance appraisals and employing a 3‐strikes‐you’re‐out feature, where an employee who misused the card or couldn’t provide receipts would have card privileges revoked or be terminated. Reviewers should be held to the same standards as cardholders. The same set of rules should be applied to all card users, although spending limits may vary. Restrict card usage by spending limits, unauthorized merchant category codes, and time of use to business hours. Only issue cards to employees after they have completed training on the purchasing card program. Segregation of Duties • The same employee should not buy, receive, approve, and reconcile card purchases. • Different employees should set up cardholders and reviewers in the P‐Card system and the banking system.

Cardholders • Cardholders must turn in detailed receipts in accordance with policies and document the business reason. Restaurant receipts should include line‐by‐line detail of the order.

• Cardholders must complete training prior to receiving a card and acknowledge in writing receipt of the policy and procedure manual.

Reviewers • If a reviewer does not review and approve transactions according to policy, that department’s card privileges should be revoked.

• Reviewers should call the employee immediately upon noticing a questionable transaction rather than waiting for the due date of receipts.

• Reviewers must complete training prior to reviewing transactions and acknowledge in writing receipt of the policy and procedure manual.

• Reviewers should be responsible for 4 to 10 cardholders at most in order to be effective.

Monitoring and Oversight • Be selective when issuing cards‐‐focus on repetitive, small‐dollar purchases. • Keep limits as low as possible to accommodate normal business needs. If there is a need to allow for emergency purchases, certain employees can have a higher limit.

• Selection of card reviewers should follow the same high standards applied to cardholders.

• The business office staff should review the work of the card reviewers and the list of P‐Card users should be reviewed annually.

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• Use the software to review the average spend by cardholder, purchases from unauthorized suppliers, purchases shipped to the cardholder’s home, and purchase amounts slightly below purchase limits.

• Review reports provided by the P‐Card programs such as declined authorizations report, disputes report, and lost/stolen card report which can reveal employees in need of additional training or attempting to misuse the card.

• Review district‐wide activity periodically to identify frequently used vendors or products to consider negotiating volume discounts in order to obtain best prices for the district.

• Encourage staff to contact the hotline used to report any fraud.

3.3.5. Control Environment, page Nos. 51‐52 (pdf page Nos. 56‐57) Expenditure of public money requires a strong control environment. The following items should be present in the purchasing control environment:

• Approval of purchase requisitions at the campus and departmental levels. The campus principal or department head should review for need and approve purchase requisitions before they are submitted to the centralized purchasing department for processing.

• Approval of purchase orders. The purchasing director or other designated official should review for compliance before approving purchase orders for issuance to vendors. If a purchase is to be federally funded, approval should first be obtained from a special programs administrator.

• Supervision of purchasing process. Vigilance in the supervision of the entire purchasing function on a daily basis is essential.

• Segregation of duties among purchasing and accounting personnel. The purchasing director, along with the finance director, and ultimately the superintendent are responsible to ensure that duties among purchasing and accounting personnel are properly segregated (to the degree possible) to provide a checks‐and‐balances environment.

• Maintenance of purchasing files and records. The purchasing clerks should be trained and supervised so that purchasing files and records are complete and maintained in an orderly fashion for the period required by law.

• Control over incoming merchandise. Receiving personnel (either centralized or decentralized) should be trained and monitored to ensure that the proper procedures are followed with incoming merchandise (i.e., the counting and inspection of merchandise received, and the completion of receiving reports).

• Verification of invoices with purchase orders and receiving reports. Although receiving personnel are responsible for the initial verification of invoices, accounting personnel verify that the invoice, the purchase order, and the receiving report match before presenting the invoice for approval for payment.

• Verification of delivery. The requesting campus or department is responsible for ensuring that the order is in agreement with its original purchase order.

• Internal review of the purchasing process. An internal review of the purchasing process should be performed periodically. This review usually is made by the district’s internal

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audit department and ensures that purchasing policies and procedures are being followed by district personnel.

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Appendix Sixteen Applicable Portions of

1. Financial Accounting and Reporting Update 14 A MODULE OF THE TEXAS EDUCATION AGENCY

FINANCIAL ACCOUNTABILITY SYSTEM RESOURCE GUIDE Published by Texas Education Agency, Austin, Texas, January 2010

Financial Accounting and Reporting . 85, page No. 86 (pdf page No. 96) January 2010 Texas Education Agency - Resource Guide

1.2.4.2. Basis of Capital Assets The preceding guidelines are the maximum capitalization limits ($5,000) prescribed by TEA. However, school districts may wish to establish accounting policies with a lower capitalization limit for items recorded as capital assets. In addition, a school district may wish to maintain accountability for certain capital assets even if they do not meet the school district’s capitalization policy. For example, certain audiovisual or computer equipment may not be capitalized (i.e. not recorded as capital asset); however a listing of such assets and their location may be maintained for control and accountability purposes. This is common for items with a higher risk of theft (easily transportable or marketable or diverted to personal use). Financial Accounting and Reporting, page No. 293 (pdf page No. 303) January 2010 Texas Education Agency - Resource Guide

1.4.3 Function Codes A function represents a general operational area in a school district and groups together related activities. Most school districts use all of the functions in the process of educating students or organizing the resources to educate students. For example, in order to provide the appropriate atmosphere for learning, school districts transport students to school, teach students, feed students and provide health services. Each of these activities is a function. The

R by a function indicates that the function is required for reporting purposes (PEIMS and/or

Annual Financial and Compliance Report) if such funds are applicable to the school district. R 11 Instruction page No. 295 (pdf page Nos. 305)

This function is used for activities that deal directly with the interaction between teachers and students. Teaching may be provided for students in a school classroom, in another location such as a home or hospital, and in other learning situations. It may also be provided through some other approved medium such as television, radio, telephone, telecommunications, multimedia and correspondence. This function includes expenditures / expenses for direct classroom instruction and other activities that deliver, enhance or direct the delivery of learning situations to students. Certain expenditures must be accounted for by organization code and program intent code. See Organization Code section and Program Intent section for guidance concerning mandatory and optional uses. School districts are encouraged to use appropriate program intent and organization codes for all other costs that are directly attributable to a specific program intent and/or organization. However, benefits to the management of the school district in relation to the

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effort to allocate these costs should be examined before allocating costs that are not mandatory. If specific program intent codes are not used, the school district is to use Program Intent Code 99 (Undistributed). If specific organization codes are not used, the school district is to use Organization Code 999 (Undistributed) or Organization Code 998 (Unallocated, Local Option). R 36 Extracurricular Activities, page Nos. 315‐316 (pdf page Nos. 325‐326)

This function is used for expenditures/expenses for school‐sponsored activities outside of the school day. These activities are generally designed to provide students with experiences such as motivation and the enjoyment and improvement of skills in either a competitive or noncompetitive setting. Extracurricular activities include athletics and other activities that normally involve competition between schools (and frequently involve offsetting gate receipts or fees such as football, baseball, volleyball, track and tennis). Other kinds of related activities are included (such as drill team, pep squad and cheerleading, University Interscholastic League competition such as one‐act plays, speech, debate, band, Future Farmers of America (FFA), National Honor Society, etc.). If the school district has activity funds, the goods purchased for resale are to be classified in this function, with the gross sale of goods recorded in Revenue Object Code 5755, Results from Enterprising Activities, Activity Funds and/or Clearing Accounts. Certain expenditures must be accounted for by organization code and program intent code. See Organization Code section and Program Intent section for guidance concerning mandatory and optional uses. School districts are encouraged to use appropriate program intent and organization codes for all other costs that are directly attributable to a specific program intent and/or organization. However, benefits to the management of the school district in relation to the effort to allocate these costs should be examined before allocating costs that are not mandatory. If specific program intent codes are not used, the school district is to use Program Intent Code 99 (Undistributed). If specific organization codes are not used, the school district is to use Organization Code 999 (Undistributed) or Organization Code 998 (Unallocated, Local Option).

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Financial Accounting and Reporting, page No. 487 January 2010 Texas Education Agency - Resource Guide

1.4.15.4 Compliance Monitoring ‐ Program Intent Codes TEA provides software in PEIMS EDIT+ containing a formula to allocate costs recorded in Program Intent Code 99, Undistributed, according to instructional FTEs (as reported in PEIMS) assigned to Basic and Enhanced Program Intent Codes. The formula‐based allocation will be used for state and federal compliance monitoring purposes, such as monitoring indirect costs, maintenance of effort and comparability requirements. Compliance with indirect cost requirements in state law will be monitored by TEA using allocated cost information in PEIMS. This information will include costs assigned to specific program intent codes and those costs which are allocated by the formula to specific program intent codes for functions specified in State Board of Education rules relating to indirect costs. The allocation process is a report type of template and does not change transaction information within the general ledger system. The allocation process uses payroll and staff data for instructional FTEs, as recorded under function 11, Instruction, as a basis to allocate costs. Accordingly, full use of specific program intent codes in function 11 is essential for the optimum functionality of the allocation process. The R by a code indicates that the code is

required for reporting purposes (PEIMS and/or Annual Financial and Compliance Report) if such codes are applicable to the school district. Shared Services Arrangements cost information which is submitted on a special PEIMS record will also be included in the compliance monitoring calculations. The total costs which will be considered for compliance monitoring purposes are represented by the following formula.

Expenditures coded by the school district to specific Enhanced PICs

+

Allocations of expenditures to Enhanced PICs from the Undistributed PIC (99) based upon instructional FTEs

+

Expenditures associated with a school district as a member of a shared services arrangement which are coded to specific Enhanced PICs

=

Total expenditures used for monitoring purposes such as maintenance of effort, comparability and compliance with State Board of Education rules on indirect costs

9X OTHER, page No. 506 (pdf page No. 516) R 91 Athletics and Related Activities

The costs incurred to provide for participation in competitive athletic activities such as football, basketball, golf, swimming, wrestling, gymnastics, baseball, tennis, track, volleyball, etc. This includes costs associated with coaching as well as sponsors for drill team, cheerleaders, pep squad or any other organized activity to support athletics. However, this does not include band. R 99 Undistributed, page No. 507 (pdf page No. 517)

All charges which are not readily distributed to program intent codes are classified here. Program intent code 99 may be used when recording substitute teachers and on‐behalf teacher retirement payments in all function codes. This code may be used for costs not clearly attributable to a specific program intent.

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Appendix Seventeen Maintenance Fee Calculation

June 21, 2017 Maintenance Fee Calculation

When the Ricoh (formerly Ikon) bid for maintenance was received it was provided in a global lump sum amount ($357,873). In order to allocate the maintenance fee equitably a meeting with the principals was held. From that meeting it was determined that a fair way to charge for maintenance was to calculate the annual copier usage at each school. Each schools total copier count was then divided by the total number of copies made districtwide (102,959,117). The calculated % was then applied to the total cost for maintenance ($357,873) and that number was utilized as each schools annual copier maintenance fee. If someone purchased new equipment then an additional amount was added to cover the cost of maintenance for the new equipment. Don Friedel Assistant Director of Purchasing