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							OFFICE   OF THE   NEW YORK STATE COMPTROLLER
                  D IVISION OF LOCAL GOVERNMENT
                      & SCHOOL ACCOUNTABILITY




          Bath
 Central School District
    Internal Controls Over
      Payroll Processing

           Report of Examination
                   Period Covered:
          July 1, 2007 — November 30, 2008
                      2009M-44




               Thomas P. DiNapoli
                                Table of Contents



                                                                                Page

AUTHORITY LETTER                                                                 2


INTRODUCTION                                                                     3
           Background                                                            3
           Objective                                                             3
           Scope and Methodology                                                 3
           Comments of District Officials and Corrective Action                   4


PAYROLL PROCESSING                                                               5
            Recommendations                                                      6


APPENDIX    A   Response From District Officials                                  7
APPENDIX    B   Audit Methodology and Standards                                  9
APPENDIX    C   How to Obtain Additional Copies of the Report                   11
APPENDIX    D   Local Regional Office Listing                                    12




                       DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY          1
                                                                                       1
                                                 State of New York
                                    Office of the State Comptroller


Division of Local Government
and School Accountability

May 2009

Dear School District Officials:

A top priority of the Office of the State Comptroller is to help school district officials manage their
districts efficiently and effectively and, by so doing, provide accountability for tax dollars spent to
support district operations. The Comptroller oversees the fiscal affairs of districts statewide, as well
as districts’ compliance with relevant statutes and observance of good business practices. This fiscal
oversight is accomplished, in part, through our audits, which identify opportunities for improving
district operations and Board of Education governance. Audits also can identify strategies to reduce
district costs and to strengthen controls intended to safeguard district assets.

Following is a report of our audit of the Bath Central School District, entitled Internal Controls Over
Payroll Processing. This audit was conducted pursuant to Article V, Section 1 of the State Constitution
and the State Comptroller’s authority as set forth in Article 3 of the General Municipal Law.

This audit’s results and recommendations are resources for district officials to use in effectively
managing operations and in meeting the expectations of their constituents. If you have questions about
this report, please feel free to contact the local regional office for your county, as listed at the end of
this report.

Respectfully submitted,


Office of the State Comptroller
Division of Local Government
and School Accountability




   2         OFFICE OF THE NEW YORK STATE COMPTROLLER
                           Introduction
Background         The Bath Central School District (District) is located in Steuben
                   County. The District is governed by the Board of Education (Board)
                   which comprises seven elected members. The Board is responsible
                   for the general management and control of the District’s financial and
                   educational affairs. The Superintendent of Schools (Superintendent)
                   is the chief executive officer of the District and is responsible, along
                   with other administrative staff, for the day-to-day management of the
                   District under the direction of the Board.

                   There are four schools in operation within the District, with
                   approximately 1,830 students and 400 employees. The District’s
                   general fund expenditures for the 2007-08 fiscal year were $27.4
                   million and the 2008-09 adopted budget includes $30.3 million in
                   expenditures. These are funded primarily with State aid, real property
                   taxes, and grants.

                   The District employs a full-time Business Administrator to oversee
                   the District’s business operations, and employs a District Treasurer
                   and a payroll clerk to carry out its payroll duties. The District’s
                   payroll clerk processes payroll for approximately 400 employees on
                   a bi-weekly basis. For the 2007-08 fiscal year, the District’s payroll
                   expenditures totaled $17.3 million.

Objective          The objective of our audit was to examine the District’s internal
                   controls over payroll processing. Our audit addressed the following
                   related question:

                      •   Are internal controls over payroll processing appropriately
                          designed and operating effectively to adequately safeguard
                          District assets?

Scope and          Our overall goal was to assess the adequacy of the internal controls
Methodology        put in place by officials to safeguard District assets. To accomplish
                   this, we performed an initial assessment of the internal controls so
                   that we could design our audit to focus on those areas most at risk.
                   Our initial assessment included evaluations of the following areas:
                   financial oversight, cash receipts and disbursements, purchasing, and
                   payroll and personal services and information technology. Based on
                   that evaluation, we determined that controls appeared to be adequate
                   and limited risk existed in most of the financial areas we reviewed.
                   We did determine that risk existed in the payroll area and, therefore,
                   we examined internal controls over payroll processing for the period
                   July 1, 2007 to November 30, 2008.

              DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                 3
                                                                                     3
                           We conducted our audit in accordance with generally accepted
                           government auditing standards (GAGAS). More information on
                           such standards and the methodology used in performing this audit is
                           included in Appendix B of this report.

Comments of District       The results of our audit and recommendations have been discussed
Officials and Corrective    with District officials and their comments, which appear in Appendix
Action                     A, have been considered in preparing this report. District officials
                           agreed with our findings and recommendations and have initiated
                           corrective action.

                           The Board has the responsibility to initiate corrective action.
                           Pursuant to Section 35 of the General Municipal Law, Section 2116-
                           a (3)(c) of the Education Law, and Section 170.12 of the Regulations
                           of the Commissioner of Education, a written corrective action plan
                           (CAP) that addresses the findings and recommendations in this report
                           must be prepared and forwarded to our office within 90 days. To the
                           extent practicable, implementation of the CAP must begin by the end
                           of the next fiscal year. For more information on preparing and filing
                           your CAP, please refer to our brochure, Responding to an OSC Audit
                           Report, which you received with the draft audit report. The Board
                           should make the CAP available for public review in the District
                           Clerk’s office.




  4        OFFICE OF THE NEW YORK STATE COMPTROLLER
         Payroll Processing

      The primary objective for internal controls over payroll processing is
      to ensure that employees are paid wages and salaries, and provided
      benefits, to which they are duly entitled. An important component of
      any internal control system is proper segregation of duties, ensuring
      that no one person controls all phases of a transaction. Concentrating
      key duties (i.e. authorization, recordkeeping and custody) with one
      individual with little or no oversight weakens internal controls and
      significantly increases the risk that errors and/or irregularities might
      occur and go undetected and uncorrected in a timely manner. Internal
      controls also require limiting user rights to only the people who are
      involved in processing the payroll and need the access to perform
      their job duties.

      Internal controls over the District’s payroll processing are not
      appropriately designed because the payroll clerk performs virtually
      every phase of the payroll process. Specifically, the payroll clerk has
      user rights to the District’s payroll module which allow her to enter
      new employees, activate and inactivate existing employees and make
      changes in employees’ hourly and annual salary rates without any
      oversight. She is also responsible for setting up employee payroll
      deductions and direct deposits, processing the payroll, maintaining
      payroll records and distributing the payroll checks.

      The payroll clerk processes the District’s payroll by entering data
      into the payroll system from the daily attendance reports and the
      employee timesheets that are signed by the individual employee’s
      department head. After the data is entered, the payroll clerk sends the
      payroll to the Treasurer to be printed. The payroll clerk forwards the
      payroll register to the Superintendent, who reviews and certifies the
      payroll. During the review, the Superintendent randomly selects five
      employees and verifies that the payment amount listed on the register
      is correct. However, this review does not include a comparison
      against the actual printed checks. The approved payroll register is
      returned to the payroll clerk. The payroll clerk files the register and
      distributes the payroll checks. The payroll clerk’s incompatible duties
      of recordkeeping, custody and distribution of payroll checks without
      any significant mitigating controls increases the risk of unauthorized
      changes or that errors may occur without being detected and
      corrected in a timely manner.

      We also found that the accounts payable clerk has user rights to the
      payroll module in the District’s computerized financial system. This
      employee does not have any payroll responsibilities and does not
      need access to the payroll module in order to perform her job duties.
DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                55
                         Based on these control weaknesses, we verified that 20 employees
                         were bona fide District employees by reviewing key supporting
                         documentation in their personnel file. We also compared the annual
                         payroll salary payments of an additional 20 employees, which
                         included key District officials,1 to salary and benefit entitlements that
                         were documented in written employee contracts, personnel records,
                         and Board-approved minutes. We then compared this information
                         to the salary information filed in the employees’ payroll records.
                         In addition, we verified that these 20 employees’ mandatory
                         withholdings were being deducted. Lastly, we reviewed the audit
                         logs from the payroll module for the audit period to check for any
                         unauthorized access by employees who are able to access and make
                         changes in the payroll module. Our audit did not identify any material
                         deficiencies. However, to prevent manipulation of payroll records in
                         the future, District officials need to strengthen internal controls over
                         the payroll process.

Recommendations          1. District officials should segregate the payroll processing duties
                            to ensure adequate safeguarding of District assets. If segregation
                            of duties is not feasible, District officials should implement
                            sufficient mitigating controls over payroll processing.

                         2. District officials should ensure that employees are assigned user
                            rights that are consistent with their job descriptions.




                         1
                           We selected seven District central office staff persons and judgmentally selected
                         the remaining 13 employees from various departments.

  6      OFFICE OF THE NEW YORK STATE COMPTROLLER
                                          APPENDIX A

                      RESPONSE FROM DISTRICT OFFICIALS

The District officials’ response to this audit can be found on the following page.




                          DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY    7
                                                                                    7
8   OFFICE OF THE NEW YORK STATE COMPTROLLER
                                          APPENDIX B

                     AUDIT METHODOLOGY AND STANDARDS

Our overall goal was to assess the adequacy of the internal controls put in place by officials to
safeguard District assets. To accomplish this, we performed an initial assessment of the internal
controls so that we could design our audit to focus on those areas most at risk. Our initial assessment
included evaluations of the following areas: financial oversight, cash receipts and disbursements,
purchasing, and payroll and personal services and information technology.

During the initial assessment, we interviewed appropriate District officials, performed limited tests
of transactions and reviewed pertinent documents, such as District policies and procedures manuals,
Board minutes, financial records and reports. In addition, we obtained information directly from
the computerized financial databases and then analyzed it electronically using computer-assisted
techniques. This approach provided us with additional information about the District’s financial
transactions as recorded in its databases. Further, we reviewed the District’s internal controls and
procedures over the computerized financial databases to help ensure that the information produced by
such systems was reliable.

After reviewing the information gathered during our initial assessment, we determined where
weaknesses existed, and evaluated those weaknesses for the risk of potential fraud, theft and/or
professional misconduct. We then decided on the reported objective and scope by selecting for audit
those areas most at risk. We selected the payroll for further audit testing.

We focused our payroll testing on segregation of duties. Based on the lack of segregation of duties, we
tested for fictitious employees by reviewing the personnel records for 20 employees and verifying that
they were District employees. We selected the 20 employees based on hire date and using computer-
assisted analysis techniques for fictitious employee testing. In addition, we selected an additional 20
employees, and compared actual payroll earnings to Board-approved or negotiated contract salaries
and verified withholding amounts. We examined the following records to determine the effectiveness
of internal controls pertaining to the payroll function and to identify any associated deficiencies found
in those controls:

   •   Employee personnel files

   •   Collective bargaining agreements and individual employment contracts

   •   Payroll registers and employee earnings records generated from the District’s computerized
       financial system

   •   Board minutes.

We also reviewed user rights and access permissions to the payroll module for our audit period to
determine if the assigned user rights and access were appropriate. We interviewed employees in
the District’s Information Technology Department and the District Business Office concerning the
administrative rights to the computerized financial system.


                          DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY                   9
                                                                                                   9
We conducted this performance audit in accordance with generally accepted government auditing
standards (GAGAS). Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit
objective. We believe that the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objective.




  10        OFFICE OF THE NEW YORK STATE COMPTROLLER
                                           APPENDIX C

           HOW TO OBTAIN ADDITIONAL COPIES OF THE REPORT


To obtain copies of this report, write or visit our web page:




                                    Office of the State Comptroller
                                    Public Information Office
                                    110 State Street, 15th Floor
                                    Albany, New York 12236
                                    (518) 474-4015
                                    http://www.osc.state.ny.us/localgov/




                           DIVISION OF LOCAL GOVERNMENT AND SCHOOL ACCOUNTABILITY   11
                                                                                    11
                                                    APPENDIX D
                             OFFICE OF THE STATE COMPTROLLER
                              DIVISION OF LOCAL GOVERNMENT
                               AND SCHOOL ACCOUNTABILITY
                                            Steven J. Hancox, Deputy Comptroller
                                            John C. Traylor, Assistant Comptroller

                                      LOCAL REGIONAL OFFICE LISTING
BUFFALO REGIONAL OFFICE                                      GLENS FALLS REGIONAL OFFICE
Robert Meller, Chief Examiner                                Karl Smoczynski, Chief Examiner
Office of the State Comptroller                               Office of the State Comptroller
295 Main Street, Suite 1032                                  One Broad Street Plaza
Buffalo, New York 14203-2510                                 Glens Falls, New York 12801-4396
(716) 847-3647 Fax (716) 847-3643                            (518) 793-0057 Fax (518) 793-5797
Email: Muni-Buffalo@osc.state.ny.us                          Email: Muni-GlensFalls@osc.state.ny.us

Serving: Allegany, Cattaraugus, Chautauqua, Erie,            Serving: Clinton, Essex, Franklin, Fulton, Hamilton,
Genesee, Niagara, Orleans, Wyoming counties                  Montgomery, Rensselaer, Saratoga, Warren, Washington
                                                             counties

ROCHESTER REGIONAL OFFICE                                    ALBANY REGIONAL OFFICE
Edward V. Grant, Jr., Chief Examiner                         Kenneth Madej, Chief Examiner
Office of the State Comptroller                               Office of the State Comptroller
The Powers Building                                          22 Computer Drive West
16 West Main Street – Suite 522                              Albany, New York 12205-1695
Rochester, New York 14614-1608                               (518) 438-0093 Fax (518) 438-0367
(585) 454-2460 Fax (585) 454-3545                            Email: Muni-Albany@osc.state.ny.us
Email: Muni-Rochester@osc.state.ny.us
                                                             Serving: Albany, Columbia, Dutchess, Greene,
Serving: Cayuga, Chemung, Livingston, Monroe,                Schenectady, Ulster counties
Ontario, Schuyler, Seneca, Steuben, Wayne, Yates
counties

SYRACUSE REGIONAL OFFICE                                     HAUPPAUGE REGIONAL OFFICE
Eugene A. Camp, Chief Examiner                               Jeffrey P. Leonard, Chief Examiner
Office of the State Comptroller                               Office of the State Comptroller
State Office Building, Room 409                               NYS Office Building, Room 3A10
333 E. Washington Street                                     Veterans Memorial Highway
Syracuse, New York 13202-1428                                Hauppauge, New York 11788-5533
(315) 428-4192 Fax (315) 426-2119                            (631) 952-6534 Fax (631) 952-6530
Email: Muni-Syracuse@osc.state.ny.us                         Email: Muni-Hauppauge@osc.state.ny.us

Serving: Herkimer, Jefferson, Lewis, Madison,                Serving: Nassau, Suffolk counties
Oneida, Onondaga, Oswego, St. Lawrence counties

BINGHAMTON REGIONAL OFFICE
Patrick Carbone, Chief Examiner                              NEWBURGH REGIONAL OFFICE
Office of the State Comptroller                               Christopher Ellis, Chief Examiner
State Office Building, Room 1702                              Office of the State Comptroller
44 Hawley Street                                             33 Airport Center Drive, Suite 103
Binghamton, New York 13901-4417                              New Windsor, New York 12553-4725
(607) 721-8306 Fax (607) 721-8313                            (845) 567-0858 Fax (845) 567-0080
Email: Muni-Binghamton@osc.state.ny.us                       Email: Muni-Newburgh@osc.state.ny.us

Serving: Broome, Chenango, Cortland, Delaware,               Serving: Orange, Putnam, Rockland, Westchester
Otsego, Schoharie, Sullivan, Tioga, Tompkins                 counties
counties



  12            OFFICE OF THE NEW YORK STATE COMPTROLLER

						
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