Roxbury Community College (RCC) did not address issues in prior audit findings regarding the rental process and related fees for the Reggie Lewis Track and Athletic Center (RLTAC). Specifically, our prior audit contained recommendations about establishing fees, instituting policies for facility use (i.e., who can use the facility for public, nonpublic, and charitable purposes), and executing written agreements with nonpublic entities.
In our current audit, neither RCC’s “Facilities Reservation Policy” nor its internal control plan (ICP) addressed event processes for all of the events during the audit period. RCC did not always retain documentation in compliance with its rental process for RLTAC external events.
In addition, RCC’s staff did not provide documentation for 21 of the 60 external events for which we requested documentation. RCC’s staff explained that these 21 events followed a different process from the RCC “Facilities Reservation Policy” and that documentation (such as executed written agreements between RCC and nonpublic entities, approved applications, fee addenda, and invoices) would not be available to inspect. RCC did not provide us with a documented policy or procedure for this different process. These 21 events did not have common characteristics we could use to identify them or exclude them from the population. For example, they included, but were not limited to, state-agency-sponsored events for children and families, events for senior citizens, and track-related events for high schools. Therefore, we could not perform further audit procedures for these 21 external events and considered them noncompliant.
RCC also could not provide any documentation for 5 of the remaining 39 events. Of the 34 external events for which we received documentation, 19 had all the documentation to support that the rental process had been followed; 15 were missing some of the documentation, such as approved applications, executed agreements between RCC and the nonpublic entities, fee addenda, invoices, and proofs of payment (e.g., check copies, money orders, and credit card payment receipts). We are 95% confident that 35% to 67% of the external event files were missing documentation to show that RCC’s rental process for RLTAC external events was followed.
Without retaining this supporting documentation and completely documenting its rental process for all RLTAC events, RCC increases the risk that RLTAC could miss a step in the rental process, which may result in a loss of funds. Also, RCC is not in compliance with the Massachusetts Statewide Records Retention Schedule Quick Guide Schedule Number 06-18, revised December 2018.
Regarding the rental agreement process, according to RCC’s “Facilities Reservation Policy,” external events require an approved application, an executed written agreement between RCC and the nonpublic entity, and a fee addendum. In addition, payment (by money order, bank or corporate check, or credit card) must be made five business days before the event date.
Regarding documentation of the rental process being followed, according to the Massachusetts Statewide Records Retention Schedule Quick Guide Schedule Number 06-18, revised December 2018, payment documentation must be retained for three years and all other records related to events, including schedules and calendars, must be retained until administrative use ceases.
Regarding the rental process for RLTAC external events not being included in RCC’s ICP, the Office of the Comptroller of the Commonwealth’s (CTR’s) Internal Control Guide states,
Departments are obligated to revise their ICPs whenever significant changes occur in objectives, risks, management structure, program scope, etc. At the very least, the ICP must be reviewed and updated annually.
Reasons for Missing Documentation
In a memo to the Office of the State Auditor (OSA), RCC officials explained,
In the current audit there has been documentation that could not be found. These outstanding items include contracts for event staff, paper files for a few events and payment documentation. . . .
Within the audit period of [fiscal year 2018 through fiscal year 2019], several events took place that impacted record-keeping:
The event software that was used to book, invoice and record payment receipts—FastBook—was determined to not meet the full needs of the College. The migration to the new application, Tripleseat, was completed in [fiscal year] 2020. At that time, a decision was made to migrate events from that current fiscal year. The data in Fastbook relating to the audit period could not be retrieved until March 5, 2021 after multiple attempts by a technical consultant. Those invoices were sent via email on that date. . . .
Since [fiscal year 2018 through fiscal year 2019], there have been staffing changes which has impacted locating all pertinent documentation. These changes include the former Auxiliary Services Manager (responsible for invoicing clients and recording payments received).
According to RCC officials, in response to our prior audit, RCC updated its ICP to include RLTAC operations, and RLTAC now follows all RCC policies and procedures. RCC officials considered this ICP update to be sufficient. However, RCC’s ICP does not explicitly mention the RLTAC rental process.
- RCC should ensure that all event documentation is completed and retained.
- RCC should completely document its rental agreement process for all RLTAC events and integrate this process into its ICP.
After the last audit, it was found that College did not have a systematic, electronic means to keep all documents for all events held at the RLTAC. The Events Office and the Business Office needed to design a system to share and maintain records. The College hired additional staff to work in the Business Office to complete this work.
The first attempt (in 2018) was to purchase an expanded license for FastBook, which was a software package that the College had been using for scheduling the RLTAC events. However, the College staff soon learned that this system was inadequate for the work needed and started researching a comprehensive solution. Staff researched and found another electronic system to ensure that all records were maintained and processed. In FY2020, Tripleseat was purchased and the system was programmed. The system was fully implemented in February 2020, slightly before the College canceled on-campus events as a result of the COVID-19 pandemic.
While this system change and staff turnover are not acceptable explanations for the missing documents, there are several actions the College has taken to mitigate future issues.
The new event-booking platform in use by the College, Tripleseat, provides an electronic repository for all event-related documents, including the initial request, the signed agreement/license, invoices, method of payment, and all other event-related documentation. The College believes that this software will ensure that all events are completely documented and that the documentation is retained according to the Statewide Records Retention Schedule.
The RCC Internal Control Plan is being updated to include the process for external events held at the RLTAC. This update – explicitly highlighting the RLTAC rental process – includes a detail of the process for booking and documenting external events, as well as a clear separation of duties for approving events and the collection and recording of fees received.
All staff involved in the collection of documentation for events related to the RLTAC have been trained and understand the Statewide Records Retention Schedule.
Based on its response, RCC is taking measures to address our concerns on this matter.
|Date published:||October 28, 2021|