In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor (OSA) has conducted a performance audit of certain activities of Roxbury Community College (RCC) for the period July 1, 2017 through June 30, 2019.
We conducted this performance audit in accordance with generally accepted government auditing standards. 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 objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives, although we encountered some limitations (see Finding 1 and Finding 3) regarding Objectives 1a and 1b. For those two objectives, RCC’s staff did not provide all the documentation needed to complete our substantive procedures. If this documentation had been available, it is possible that our audit procedures would have identified further issues.
Below is a list of our audit objectives, indicating each question we intended our audit to answer; the conclusion we reached regarding each objective; and, if applicable, where each objective is discussed in the audit findings.
a. the Reggie Lewis Track and Athletic Center (RLTAC) rental process and related fees according to Section 22A of Chapter 15A of the General Laws; RCC’s “Facilities Reservation Policy”; and the Massachusetts Statewide Records Retention Schedule Quick Guide Schedule Number 06-18, revised December 2018
b. administration of RLTAC employee contracts in accordance with the contract terms and the Massachusetts Statewide Records Retention Schedule Quick Guide Schedule Number 06-18, revised December 2018
No; see Finding 3
c. performing Sex Offender Registry Information (SORI) checks in accordance with its internal policy
No; see Finding 4
d. purchasing and receiving goods in accordance with its internal policies
To achieve our objectives, we gained an understanding of RCC’s internal control environment related to the objectives by reviewing RCC’s policies and procedures, as well as inspecting documents, conducting observations, and performing inquiries with RCC’s staff and management.
We performed the following procedures to obtain sufficient, appropriate audit evidence to address the objectives.
Rental Process and Track-Related Payments
In our prior audit, we found deficiencies in RCC’s rental process for RLTAC: RCC lacked adequate internal controls over the establishment and collection of rental fees for nonpublic events, did not enter into a rental agreement or collect rental fees from a local nonpublic university, and lacked policies and procedures for the collection of admission fees at public events. Further, RCC inappropriately charged and collected $24,280 in fees from public high school track leagues. We also found that RLTAC had traditionally operated as a separate entity from RCC and that RLTAC activities were not incorporated into RCC’s internal control plan (ICP) or set forth in policies and procedures specific to RLTAC.
In response to our prior audit, RCC changed its rental process for RLTAC for external events:
- RCC no longer collects admission fees.
- The RCC board of trustees approves rental fee schedules that RCC uses to charge and collect fees for the use of RLTAC.
- RCC has documented the rental process for RLTAC external events in its “Facilities Reservation Policy.”
- RLTAC no longer operates as a separate entity from RCC and, similarly to other RCC departments, follows the policies and procedures in RCC’s ICP.
During our current audit, we selected a statistical, random sample of 60 external events from a population of 1,208 external events that took place at RLTAC during the audit period (using an expected error rate1 of 0%, a tolerable error rate2 of 5%, and a confidence level3 of 95%) to determine whether RCC had followed its rental process for RLTAC external events. However, RCC’s staff did not provide documentation for 26 of the 60 external events selected. We inspected documentation for the other 34 events to verify that RCC had followed its “Facilities Reservation Policy” for RLTAC external events. The documentation included executed written agreements between RCC and nonpublic entities, approved applications, fee addenda, invoices, and proofs of payment (i.e., copies of checks, credit card payment receipts, or money orders). We also determined whether the amounts RCC charged on the invoices and fee addenda for the use of RLTAC were charged in accordance with the fee schedules approved by the RCC board of trustees and whether the amounts were collected in accordance with RCC’s rental process for external events.
Additionally, RCC could not generate a list of the amounts it had charged for all RLTAC external events held during the audit period. However, RCC gave us a list of event payments it received from public and nonpublic entities for the use of RLTAC during the audit period, using its Jenzabar general ledger system. From this list, we identified a total population of 22 payments made to RCC by public high school track leagues for the use of RLTAC during the audit period. To determine whether RCC improperly charged public high school track leagues for the use of RLTAC during the audit period, we inspected the invoices, proofs of payment, and related bank statements for all 22 payments, except two invoices that RCC could not provide.
In our prior audit, we found that some contract employees worked without current contracts. One contract employee was paid more than the contract allowed. Additionally, RCC did not have Employment Status Forms (ESFs) on file for some employees to establish that they were contract employees, not independent contractors.
During our current audit, 74 individuals had RLTAC employee contracts. Some of them had multiple contracts during the audit period. For these 74 individuals, a total of 98 RLTAC employee contracts should have been signed and maintained on file. We requested all 98, but RCC did not provide 39 of them (9 for fiscal year 2018 and 30 for fiscal year 2019). Although we could not inspect all 98, we were able to inspect 59 contracts, totaling $363,162 (43 for fiscal year 2018, totaling $236,626, and 16 for fiscal year 2019, totaling $126,537)4 to verify that RCC renewed contracts in a timely manner and that it signed and retained contracts. Additionally, to determine whether RCC had ESFs for its contract employees, we requested ESFs from RCC personnel; however, RCC did not provide any.
We used the contracts’ stated hours and pay rates to calculate the total annual pay amount for each of the 59 RLTAC employee contracts we inspected. Next, we used the calculated annual pay amounts and compared them to payroll reports provided by RCC’s staff to determine whether RCC had adhered to the contract terms regarding hours and pay amounts.
In our prior audit, we found that RCC’s Human Resources (HR) Office, contrary to RCC’s HR policies and procedures, did not submit requests to the Sex Offender Registry Board (SORB) to conduct SORI checks of RCC employees.
In our current audit, we performed the following procedures to determine whether the HR Office submitted requests to SORB to conduct SORI checks for RLTAC employees during the audit period. From a population of 81 RLTAC employees, we judgmentally selected 16 employees who were hired during the audit period and 3 who were hired in 2016, 2014, and 2010. We requested from HR Office personnel the supporting documentation (e.g., original emails with attachments detailing the results of the SORI checks sent by SORB to the HR Office) showing that SORI checks had been conducted for these 19 employees. However, RCC’s staff only provided the requested supporting documentation for 6 employees. We inspected the original emails and attachments for these 6 employees.
Purchase of Goods
In our prior audit, we found that RLTAC did not adhere to RCC’s established policies and procedures for the purchase of, receipt of, and payment for goods and services. We found that RLTAC lacked evidence of required verification from receiving departments that the goods purchased were received in good condition before they were paid for.
In our current audit, from the total population of 52 RLTAC purchases of goods during the audit period, we selected a nonstatistical, random sample of 20 purchases. We obtained from RCC personnel, and inspected, the purchase orders, receiving documents, and proof of payment (check copies, credit card payment receipts, and/or receipts from electronic transfer of funds) to determine whether goods purchased were received in good condition before they were paid for.
When using a nonstatistical sampling approach, we did not project our results to the entire population.
In 2018, OSA performed a data reliability assessment of the Massachusetts Management Accounting and Reporting System (MMARS) that focused on testing selected system controls (access controls, application controls, configuration management, contingency planning, and segregation of duties) for the period April 1, 2017 through March 31, 2018. As part of the current audit, we tested security management controls, such as personnel screening and security awareness training, at RCC during the audit period. Additionally, we randomly selected 10 purchases from the MMARS list of goods purchased by RCC during the audit period and traced each one’s fiscal year, unit name (RLTAC), cash expense amount, vendor invoice number, vendor invoice date, appropriation number, appropriation name, object code (a code indicating type of goods or services), vendor customer code, and vendor’s legal name to source documents such as invoices, Authorization to Pay Invoice Forms, and MMARS authorization forms.
To test the reliability, and determine the completeness and accuracy, of the list of events (from RCC’s FASTbook5 system) held at RLTAC during the audit period, we conducted interviews with college officials who were knowledgeable about FASTbook. We also traced the organization names, event dates, event purposes, and organization event types to and from source documents such as approved applications, invoices, and executed written agreements between RCC and nonpublic entities.
To test the reliability, and determine the completeness and accuracy, of the list of event payments (from Jenzabar) that RCC received from public and nonpublic entities for the use of RLTAC during the audit period, we conducted interviews with college officials who were knowledgeable about Jenzabar. We also traced the transaction dates, transaction amounts, transaction descriptions, and payer names to and from source documents such as check copies and credit card payment receipts. Finally, we reconciled the total amount RCC received during the audit period from the list of event payments to RCC’s independently audited financial statements.
To test the reliability, and determine the accuracy, of the HR Office’s list of RLTAC employees who were active during the audit period, we conducted interviews with college officials who were knowledgeable about the HR Office data. In addition, we selected a random sample of 10 employees and traced the employee identification numbers, names, job titles, and service dates from the list to hardcopy HR Office personnel files. To test completeness, we compared employee names from the payroll reports provided by RCC’s comptroller for the fiscal years in our audit period (2018 and 2019) to the HR Office’s list of RLTAC employees who were active during the audit period. We calculated the number of RLTAC employee contracts from the HR Office’s list of RLTAC employees who were active during the audit period.
To test the reliability, and determine the completeness and accuracy, of the payroll reports provided by RCC’s comptroller for the fiscal years in our audit period (2018 and 2019), we conducted interviews with college officials who were knowledgeable about the payroll data. We also reconciled RLTAC’s total payroll from these reports to RCC’s independently audited financial statements. When we found discrepancies (such as variances in the reconciliation), we brought them to RCC management’s attention and worked with the independent external auditors to obtain reasonable explanations for the discrepancies before conducting our analyses. We also analyzed the payroll reports to ensure that pay dates did not fall outside our audit period.
Based on the results of our data reliability assessments, we determined that the information obtained for our audit period was sufficiently reliable for the purpose of our audit objectives.
|Date published:||October 28, 2021|