HomeMy WebLinkAbout7/15/2015 - STAFF REPORTS - 4.A. iy
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c441poA"�P CITY COUNCIL STAFF REPORT
DATE: JULY 15, 2015 UNFINISHED BUSINESS
SUBJECT: CITY COUNCIL DIRECTED INDEPENDENT LEGAL AND ACCOUNTING
REVIEW OF POLICY, PROCEDURES, REGULATIONS AND
PRACTICES FOR THE TRANSFER AND/OR SALE OF CITY AND
SUCCESSOR AGENCY OWNED REAL PROPERTY AND CITY
ECONOMIC DEVELOPMENT INCENTIVE PROGRAMS.
FROM: David H. Ready, City Manager
RECOMMENDATION:
Receive the Certified Public Accountants report on the Economic Development
Incentive Programs, from Brabo & Carlsen, LLP, Certified Public Accountants.
STAFF ANALYSIS:
On June 3, 2015, the City Council authorized the law firm of Kane, Ballmer, and
Berkman to review the transfer and/or sale of City and Successor Agency owned real
property, and requested an outside accounting review of the City's Economic
Development Incentive Programs.
The Certified Public Accounts will present its report and findings to the City Council on
the economic development programs. According to the law firm, the report on the
Property Disposition Plan and the Redevelopment property transaction is not yet
complete and will be made available to the City Council and the public when received,
later this month.
With the exception of providing all records and documents as requested by the outside
firms, City Staff has not been involved in the independent review.
DAVID H. READY
City Manager
ITEM NO.
RABO & ARLSEN, LLP MICHAH.J. BRABO, CPA
CERTIFIED PUBLIC WAYNE E. CAKLSEN, CPA
ACCOUNTANTS w,„!he, C I,„r>
Pmcti,e Srdion afllie Anreritrru loaihik
I C•rti�od Puhlic ArnnoJmtls
July 13, 2015
City of Palm Springs
3200 E.Tahquitz Canyon Way
Palm Springs, CA 92262
In planning and performing our examination of City Management's Assertion of Compliance with
Economic Incentive Programs as of June 30, 2015, we considered the City's internal control in order to
determine our procedures for the purpose of expressing our opinion on management's assertions and not
to provide assurance on the internal control. Our assessment of the internal control was limited to
obtaining an understanding of the internal control sufficient to plan our examination and did not include
tests of controls.
Description of Procedures Performed
Our examination included three major vacancies grants and approximately twenty interior remodel grants;
it is our understanding that these grants represents all of the completed City grants in excess of$5,000
from 2008 through June 30, 2015. We also selected and examined a sample of approximately fourteen
fagade improvements grants which we understand represents about ten percent of the grants of$5,000 or
less during the same period.
During our audit we preformed the following procedures based on information provided to us by the City:
We examined the City's grant documentation — including grant files, grant applications, grant
contracts, legal files, and program descriptions — that were provided to us by the City Clerk's office,
the Finance Department,the Economic Development Department, and the City Attorney's office;
We conducted formal interviews and held informal conversations with City Manager David Ready,
Finance Director Geoffrey Kiehl, Economic Development Administrator Cathy Van Horn, and City
Attorney Doug Holland;
We examined the City's documentation of denied applications including a spreadsheet with
explanations maintained by the Economic Development Department;
We examined copies of meeting minutes and resolutions of the City Council and the Community
Redevelopment Agency including related staff reports that were provided to us by the City Clerk's
office; and
We reviewed the results of the City's internal examination of certain grant programs.
ilk Y- A ,
1111 E.TAHdurrz CAVYON WAY,SUITE 203,PALM SPRINGS CA 92262
ph:760-320-0848 •fax:760-322-4626 • www.bribo-carlsen.com / 4-�
City of Palm Springs
July 13, 2015
Page Two
Recommendations
The following summarizes our comments and suggestions regarding these matters. This letter does not
affect our report dated July 10, 2015, on the City Management's Assertion of Compliance with Economic
Incentive Programs.
The following recommendations should allow the City to strengthen its documentation and procedures
regarding the City's grant programs. The costs of implementing any of the following controls or
procedures should be weighed against the benefits to be gained from their implementation.
Grant Documentation
During our audit, we noted that grant files and other files were sometimes not complete based on the
City's internal guidelines for documentation. For example, City checklists and program descriptions
specified that cancelled checks should be included in grant files to support grant recipients' claims for
expenditures made. Other means of supporting expenditures were on file, such as photographs, on-site
inspection, check copies (not showing cancellation), contractor invoices, etc. It appeared that the City's
documentation substantially showed that grants funds were distributed in a manner that is materially
consistent with program objectives and guidelines as established in Council minutes, staff reports, and
program summaries. However,the City's procedures for meeting internal documentation standards should
be strengthened to comply with established internal policies.
Grant files and documentation should be prepared and maintained in a manner that facilitates third parties
being able to review files and make uniform conclusions. Toward that objective, documentation standards
should include the following:
Grant files should have a checklist that serves as a table of contents and chronology for the file. Sign
offs on the checklist should be initialed and dated after that particular requirement is satisfied.
Fastener files such as two-prong fastener files should be used to reduce documents being misfiled or
misplaced. All documents should be bound into the file using the fasteners.
File dividers or tabs should be used for the standard set of items and/or sections identified in the
checklist/table of contents.
File sections should work backward in reverse chronological order, beginning with post-grant follow-
up notes if required.
Photos of recipients' premises both before and after completed work, with dates indicated, should be
obtained whenever possible.
Where dollar figures are tallied up based on invoices,checks, receipts, etc., a lead sheet of some type,
such as a spread sheet, or list, should be used rather than adding machine tapes. Documents
supporting the figures on the lead sheet could be organized in order, following the lead sheet.
Multiple copies of the same document should be avoided when possible.
Checklists should include verification that all required signatures have been obtained before
disbursements are made.
City of Palm Springs
July 13, 2015
Page Three
Policies,Procedures,and_Trainine
When programs such as new grant programs are initiated, the City should develop a set of written
procedures and policies which should be communicated to staff. Staff should receive any training
necessary to comply with program requirements.
City's Remedies
In its City Management's Assertion of Compliance with Economic Incentive Programs,the City describes
revisions to its practices and procedures which the City is implementing. The City should provide
oversight and follow up to ensure these revisions are carried out ongoing.
We would like to thank the City Council and especially the City staff for their cooperation and assistance
during our audit.
Very truly yours,
BRABO& CARLSEN, LLP
Certified Public Accountants
141-(44L�I 1�;/210
Michael J. Brabo, CPA
MJB/Imf
Report on Assertion of
Compliance with Economic
Incentive Programs
CITY OF PALM SPRINGS
JUNE 30, 2015
BR W&CARLSEN,LLP
Certified Public Accountants
L�7) A 12O A��X AMEN, LLP MICHAEL J. BRABO, CPA
t1U CERTIFILD PUBLIC WAYNE L. CARLSEN, CPA
ACCOUNTANTS Member of th,Prk rtte Cornpnuies
Pmcfice Sectiot of the American lusatute
of C,,hf,d Pn GLcA¢ounfnnts
INDEPENDENT ACCOUNTANT'S REPORT
City of Palm Springs
We have examined management's assertion, included in the accompanying City Management's Assertion
of Compliance with Economic Incentive Programs as of June 30, 2015. Management is responsible for
the City's compliance with those requirements. Our responsibility is to express an opinion on
management's assertion about the City's compliance based on our examination.
Our examination was conducted in accordance with attestation standards established by the American
Institute of Certified Public Accountants and, accordingly, included examining, on a test basis, evidence
about the City's compliance with those requirements and performing such other procedures as we
considered necessary under the circumstances. We believe that our examination provides a reasonable
basis for our opinion. Our examination does not provide a legal determination on the City's compliance
with specified requirements.
In our opinion, management's assertion that the City complied with the aforementioned requirements for
the period ended June 30, 2015 is fairly stated in all material respects.
BRABO&CARLSEN, LLP
Palm Springs,California
Piha.n .4 dil im , 1P
July 10, 2015
1111 E.TAIIQUITZ CANYON WAY,SUITE 203,PALM SPRINGS,CA 92262
ph:760-320-0848 •fax:760-322-4626 • www.brabo-carlsen.com
Sp
City of Palm Springs
David H. Ready, Esq., Ph.D.
+ City Manager
A(/FORN�t- 3200 E.Tahquitz Canyon Way,Palm Springs,CA 92262
Tel 760.322.8350 • Fax 760.323.8207 •TDD 760.864.9527
David.Ready@palmspringsca.gov • w .palmspingsca.gov
June 30, 2015
Mike Brabo
Brabo & Carlsen, LLP
1111 E. Tahquitz Canyon Way, Suite 203
Palm Springs, CA 92262
RE: City Management's Assertion of Compliance with Economic Incentive Programs
Dear Mr. Brabo,
The City has implemented a series of certain grants from 2008 to 2015, consisting of Facade
Improvement Grants, Retail Interior Remodel Grants, and Special Focus Area Grants. In the
administration of these grant programs, City Management asserts:
1. Applications were submitted and reviewed for each grant.
2. For each grant approved, the applicant was found to be qualified and otherwise
eligible for the grant applied for.
3. In the case of each of the Major Vacancies Grants, the City conducted a public
meeting and made findings for the approval of the grant consistent with the
requirements under California Government Code Section 53083.
4. Each grant was evidenced by a written agreement.
5. Each agreement described the conditions and requirements of payment under
the terms of the grant.
6. For each grant payment made, there was reasonable evidence of compliance
with the conditions of payment under the terms of the grant agreement with
certain exceptions which are in review and enforcement by the City Attorney.
7. City Management has implemented the following revisions to the practices and
procedures in the administration of all future grant programs and these
modifications will strengthen consistent, uniform, and fair treatment of applicants
and ensure that the goals of the grant programs are achieved:
Modify agreements to provide express disclosure of the manner in which
the work will be performed: a general contractor, business owner acting
as the general contractor, and or combination of both methods, so that
PO Box 2743,Palm Sizings, California 92263
July 7, 2015
Page Two
the evidence of payment can be specifically tailored to meet the needs of
the City and the grant recipient.
• The City Council currently authorizes funding for incentive programs;
however, the Council formally approves the agreements for over$25,000.
Going forward, City Council will approve all incentive agreements.
• Payment requests were previously reviewed and approved by the
Department Manager. Going forward, payment requests will also be
reviewed and approved by both the City Manager and City Attorney
before the Finance Department will release any funds.
• The Finance Department will process all pay requests—Community
Development will be responsible for the application process and serve as
liaison for recipients. Finance Department will implement uniform
procedures for organizing Grant files.
• All City incentive grants will be included in the City's annual independent
audit.
Sincerely,
David H. Ready, ., h.D.
City Manager