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2014-12-31 KDV Communications Letter CITY OF ALBERTVILLE Wright County, Minnesota COMMUNICATIONS LETTER Year Ended December 31, 2014 CITY OF ALBERTVILLE TABLE OF CONTENTS REPORT ON MATTERS IDENTIFIED AS A RESULT OF THE AUDIT OF THE FINANCIAL STATEMENTS ............................................................... 1 MATERIAL WEAKNESS .............................................................................................................. 3 SIGNIFICANT DEFICIENCY....................................................................................................... 4 REQUIRED COMMUNICATION ................................................................................................ 5 FINANCIAL ANALYSIS ................................................................................................................ 8 EMERGING ISSUES ...................................................................................................................... 19 REPORT ON MATTERS IDENTIFIED AS A RESULT OF THE AUDIT OF THE FINANCIAL STATEMENTS Honorable Mayor, Management and Members of the City Council City of Albertville Albertville, Minnesota In planning and performing our audit of the financial statements of the City of Albertville, Minnesota, as of and for the year ended December 31, 2014, in accordance with auditing standards generally accepted (internal control) as a basis for designing auditing procedures that are appropriate in the circumstances for the purpose of expressing our opinions on the financial statements, but not for the purpose of Accordingly, we do not expre Our consideration of internal control was for the limited purpose described in the preceding paragraph and was not designed to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies and, therefore, material weaknesses or significant deficiencies may exist that were not identified. A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies in internal control, such that there is a reasonable possibility that a material , or detected and corrected on a timely basis. The material weakness identified is stated within this letter. A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance. The significant deficiency identified is stated within this letter. The accompanying memorandum also includes financial analysis provided as a basis for discussion. The matters discussed herein were considered by us during our audit and they do not modify the opinion April 7, 2015, on such statements. 1 This communication is intended solely for the information and use of management, the City Council, others within the City and State oversight agencies, and is not intended to be and should not be used by anyone other than these specified parties. KERN, DEWENTER, VIERE, LTD. Minneapolis, Minnesota April 7, 2015 2 CITY OF ALBERTVILLE MATERIAL WEAKNESS December 31, 2014 PRIOR PERIOD ADJUSTMENT During the course of our engagement, a prior period audit adjustment was required that would not have al statements. In order to ensure financial statements were free from material misstatement, a prior period adjustment was required to remove the $ City 2006 when the City advanced the funding for the locker room addition. The City has otherwise properly identified and maintained separate capital asset listings for the City and the Ice Arena and will not be an issue going forward. 3 CITY OF ALBERTVILLE SIGNIFICANT DEFICIENCY December 31, 2014 LACK OF SEGREGATION OF ACCOUNTING DUTIES Four areas related to each transaction cycle should be segregated: authorization, custody, recording and reconciliation. During the year ended December 31, 2014, the City had a lack of segregation of accounting duties due to a limited number of office employees. The lack of adequate segregation of data consistent with the assertions of management in the financial statements. This lack of segregation of accounting duties can be demonstrated in the following areas, which is not intended to be an all- inclusive list: The Finance Director is able to receive cash receipts at the front window and has read/write access to the general ledger. The Finance Director verifies purchase orders to invoices and can also enter disbursements into the accounts payable module. Additionally, the Finance Director can print checks, is an authorized signer and reconciles the bank accounts. The Finance Director has the ability to post utility billing information into the general ledger, make adjustments to bills and maintain customers and rates. The Administrative Assistant II imports, calculates and sends out the utility billings, maintains customer accounts, enters the billing payments, posts receipts to the general ledger and maintains the billing register. The Finance Director sets up and maintains employee payroll records, posts payroll to the general ledger, issues direct deposits, reconciles the bank account, prepares the payroll taxes, prepares all W-2s, as well as maintains all data files and the payroll program. The Building Technician fills out permit fees schedules, has access to receive payments and scans all permits and/or inspections into a house file. The Finance Director enters all accounts receivable invoices, maintains the accounts receivable billings, reports all outstanding bills to the City Council and can post payments to the general ledger. The Administrative Assistant II collects fines and fees, receives payments and enters them into the POS module. We recommend management, along with the City Council, remain aware of this situation and look for opportunities to provide additional segregation. The City is aware of the lack of segregation, which is due to limited office staff, and continues to look for opportunities to provide additional segregation in a cost effective manner. 4 CITY OF ALBERTVILLE REQUIRED COMMUNICATION December 31, 2014 We have audited the financial statements of the City for the year ended December 31, 2014, and have issued our report dated April 7, 2015. Professional standards require that we provide you with the following information related to our audit. OUR RESPONSIBILITY UNDER AUDITING STANDARDS GENERALLY ACCEPTED IN THE UNITED STATES OF AMERICA AND GOVERNMENT AUDITING STANDARDS As stated in our engagement letter, our responsibility, as described by professional standards, is to express an opinion about whether the financial statements prepared by management with your oversight are fairly presented, in all material respects, in conformity with accounting principles generally accepted in the United States of America. Our audit of the financial statements does not relieve you or management of your responsibilities. As part of our audit, we considered the internal control of the City. Such considerations were solely for the purpose of determining our audit procedures and not to provide any assurance concerning internal control. As part of obtaining reasonable assurance about whether the financial statements are free of material misstatement, we performed tests of the City contracts and grant agreements. However, the objective of our tests was not to provide an opinion on compliance with such provisions. Our responsibility for the supplementary information accompanying the financial statements, as described by professional standards, is to evaluate the presentation of the supplementary information in relation to the financial statements as a whole and to report on whether the supplementary information is fairly stated, in all material respects, in relation to the financial statements taken as a whole. PLANNED SCOPE AND TIMING OF THE AUDIT An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements; therefore, our audit involved judgment about the number of transactions to be examined and the areas to be tested. Our audit included obtaining an understanding of the City and its environment, including internal control, sufficient to assess the risks of material misstatement of the financial statements and to design the nature, timing and extent of further audit procedures. Material misstatements may result from (1) errors, (2) fraudulent financial reporting, (3) misappropriation of assets or (4) violations of laws or governmental regulations that are attributable to the City or to acts by management or employees acting on behalf of the City. QUALITATIVE ASPECTS OF ACCOUNTING PRACTICES Management is responsible for the selection and use of appropriate accounting policies. The significant accounting policies used by the City are described in Note 1 to the financial statements. No new accounting policies were adopted and the application of existing policies was not changed during the year ended December 31, 2014. We noted no transactions entered into by the City during the year for which there is a lack of authoritative guidance or consensus. All significant transactions have been recognized in the financial statements in the proper period. 5 CITY OF ALBERTVILLE REQUIRED COMMUNICATION December 31, 2014 QUALITATIVE ASPECTS OF ACCOUNTING PRACTICES Accounting estimates are an integral part of the financial statements prepared by management and are future events. Certain accounting estimates are particularly sensitive because of their significance to the financial statements and because of the possibility that future events affecting them may differ significantly from those expected. The most sensitive estimates affecting the financial statements were: Depreciation The City is currently depreciating its capital assets over their estimated useful lives, as determined by management, using the straight-line method. Expense Allocation Certain expenses are allocated to functions based on an estimate of the benefit to that particular function. Examples are salaries, benefits and supplies. Land Held for Resale Land held for resale is recorded using either the lower of historical cost or estimated resale value. The financial statement disclosures are neutral, consistent and clear. DIFFICULTIES ENCOUNTERED IN PERFORMING THE AUDIT We encountered no significant difficulties in dealing with management in performing and completing our audit. CORRECTED AND UNCORRECTED MISSTATEMENTS Professional standards require us to accumulate all misstatements identified during the audit, other than those that are clearly trivial, and communicate them to the appropriate level of management. Management did not identify and we did not notify them of any uncorrected financial statement misstatements. The following material misstatement detected as a result of audit procedures was corrected by management. Locker Room Capital Asset Prior Period Adjustment DISAGREEMENTS WITH MANAGEMENT For purposes of this letter, a disagreement with management is a financial accounting, reporting or auditing matter, whether or not resolved to our satisfaction that could be significant to the financial the course of our audit. MANAGEMENT REPRESENTATIONS We requested certain representations from management that are included in the management representation letter. 6 CITY OF ALBERTVILLE REQUIRED COMMUNICATION December 31, 2014 MANAGEMENT CONSULTATIONS WITH OTHER INDEPENDENT ACCOUNTANTS In some cases, management may decide to consult with other accountants about auditing and consultation standards require the consulting accountant to check with us to determine that the consultant has all the relevant facts. To our knowledge, there were no such consultations with other accountants. OTHER AUDIT FINDINGS OR ISSUES We generally discuss a variety of matters, including the application of accounting principles and discussions occurred in the normal course of our professional relationship and our responses were not a condition to our retention. OTHER MATTERS With respect to the supplementary information accompanying the financial statements, we made certain inquiries of management and evaluated the form, content and methods of preparing the information to determine that the information complies with accounting principles generally accepted in United States of America, the method of preparing it has not changed from the prior period, and the information is appropriate and complete in relation to our audit of the financial statements. We compared and reconciled the supplementary information to the underlying accounting records used to prepare the financial statements or to the financial statements themselves. 7 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 The following pages provide graphic representation of select data pertaining to the financial position and operations of the City for the past five years. Our analysis of each graph is presented to provide a basis for discussion of past performance and how implementing certain changes may enhance future performance. We suggest you view each graph and document if our analysis is consistent with yours. A subsequent discussion of this information should be useful for planning purposes. GENERAL FUND General Fund revenues increased $ 65,711, or 1.9%, from 2013 to 2014. Intergovernmental revenue increased $ 58,950, or 58.5%, due to the return of local government aid for the City. Miscellaneous revenue increased $ 80,511 due to improvements in market value of investments. These increases were offset by a decrease in licenses and permits of $ 45,693, or 21.4%, as a result of the Guardian Angels Senior Housing and Fraser Steel expansion tax increment financing projects in 2013. The graphs below and on the following page present the General Fund revenues by source in graph and pie chart formats. General Fund Revenues $3,750,000 $3,500,000 $3,250,000 $3,000,000 $2,750,000 $2,500,000 $2,250,000 $2,000,000 $1,750,000 $1,500,000 $1,250,000 $1,000,000 $750,000 $500,000 $250,000 $- 20102011201220132014 Miscellaneous $174,152$164,670$108,723$47,698$128,209 Special Assessments 21,75721,73016,25621,15123,385 Intergovernmental 78,76188,21979,038100,717159,667 Charges for Services392,175585,742609,905693,707694,799 Licenses and Permits 217,530125,273129,088213,277167,584 Taxes 2,319,8102,329,5752,440,6762,409,7952,378,412 8 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 GENERAL FUND 2014 General Fund Revenues Licenses and Permits Taxes 5% 67% Intergovernmental 4% Charges for Services 19% Special Assessments Miscellaneous 1% 4% 2013 General Fund Revenues Taxes 69% Licenses and Permits 6% Intergovernmental 3% Charges for Services 20% Special Assessments Miscellaneous Less Than 1% 1% 9 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 GENERAL FUND General Fund expenditures decreased from $ 3,054,447 in 2013 to $ 2,772,891 in 2014, a change of 9.2%. General government expenditures decreased $ 44,927, or 5.4%, due primarily to 2013 costs related to Guardian Angels and Fraser developments and building renovation professional services for the soccer club. Public works expenditures decreased $ 315,903, or 40.9%, as a result of more significant sealcoating projects in 2013 compared to 2014. Public safety expenditures increased $ 30,415, or 3.05%, as a result of increased costs for County police protection services. For governmental fund types, capital outlay items are included in total expenditures. Capital expenditures decreased from $ 497,459 in 2013, to $ 176,334 in 2014. In 2013, the City had significant street and trail reconstruction projects, while only undertaking smaller projects in 2014. Without taking capital outlay into consideration, total General Fund expenditures increased 1.5%. A graph depicting the expenditures for the General Fund for each of the past five years is illustrated below. General Fund Expenditures $1,200,000 $1,000,000 $800,000 $600,000 $400,000 $200,000 $- 20102011201220132014 General Government $755,356$743,560$922,154$832,558$787,631 Public Safety1,006,9241,014,5831,052,320997,8441,028,259 Public Works 592,932598,814377,422771,854455,951 Culture and Recreation264,403365,233363,269384,850429,028 Economic Development 12,74281,11515,14667,34172,022 10 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 GENERAL FUND The charts below represent the 2014 and 2013 expenditures as a percentage by function. With the decrease in public works expenditures, as explained on the previous page, there was a shift in public safety and culture and recreation expenditures as a percentage of total expenditures. 2014 General Fund Expenditures Economic Development 3% Culture and Recreation 16% General Government 28% Public Works 16% Public Safety 37% 2013 General Fund Expenditures Economic Development 2% Culture and Recreation General Government 13% 27% Public Works 25% Public Safety 33% 11 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 GENERAL FUND The graph below shows the overall trend of the General Fund balance and the cash and investment balance for the last five years. The Capital Outlay Reserve Fund balance is also included for comparison purposes since the City began recording more capital outlay related purchases there in recent years. The General Fund cash and investment balance at December 31, 2014 was $ 1,836,623, an increase of 25.8% over 2013. The unassigned fund balance has also shown this trend, ending in 2014 at $1,798,358, an increase of $ 347,772 over 2013. During 2011, the City approved a GASB Statement No. 54 fund balance policy that strives to maintain a minimum fund balance not less than 35% of balance. The CitDecember 31, 2014 was 51% of budgeted General Fund expenditures, compared to 46% as of December 31, 2013. The General Fund had a nonspendable fund balance of $ 51,000 in 2014 relating to the land held for resale. The total fund balance at December 31, 2014 was $ 1,849,358. General Fund $7,000,000 $6,000,000 $3,747,939 $3,284,274 $5,000,000 $2,917,672 $4,000,000 $2,447,933 $2,222,211 $3,000,000 $1,836,623 $2,000,000 $1,459,119 $1,262,211 $1,262,998 $1,190,973 $1,798,358 $1,450,586 $1,000,000 $1,248,815 $1,120,455 $1,070,100 $- 20092010201120122013 General Fund Unassigned Fund BalanceCapital Outlay Reserve FundGeneral Fund Cash and Investments 12 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 GENERAL FUND The graph below shows the budget to actual results for the General Fund revenue by source. In total, actual revenues were greater than the budget by $ 328,152, or 10.2%. In 2014, every category of revenue was over budget, except for tax revenue. Of these variances, charges for services, licenses and permits and miscellaneous revenue had the most significant variances. Charges for services were over budget by $ 168,929 as a result of an increase in building activity in 2014 and also because of the presentation of arena activity. Licenses and permits revenue was over budget $ 59,384 with the increase in building activity in 2014. Miscellaneous revenue was $ 94,209 over budget due to the improvement of investment market values in 2014. Taxes and intergovernmental revenue were not significantly over or under budget. Additionally, special assessments are not budgeted for by the City, and as a result, the full amount of $ 23,385 received is over budget. 2014 Revenues Budget and Actual $3,000,000 $2,378,412 $2,500,000 $2,397,983 $2,000,000 $1,500,000 $1,000,000 $694,799 $525,870 $500,000 $167,584 $128,209 $159,667 $157,851 $108,200 $34,000 $23,385 $- TaxesLicenses andIntergovernmentalCharges forSpecialMiscellaneous PermitsServicesAssessments BudgetActual 13 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 GENERAL FUND The graph below shows the budget to actual results for General Fund expenditures by department. Overall, the City was under budget by $ 19,620, or 0.7%. 2014 Expenditures Budget and Actual $1,200,000 $1,046,476 $1,028,259 $1,000,000 $942,771 $787,631 $800,000 $600,000 $455,951 $446,333 $429,028 $400,000 $323,931 $200,000 $72,022 $33,000 $- General GovernmentPublic SafetyPublic WorksCulture and RecreationEconomic Development BudgetActual General Government showed the largest variance with actual amounts coming in $ 155,140 under budget. The City budgets for street projects annually, but only conducts a street project every other year, causing some of the future project costs to be budgeted in the current year. Culture and recreation which is not included in the budget. Economic development expenditures exceeded the budget by $ 39,022 due to increased costs for City tax payments. Public works and public safety expenditures did not vary significantly with budgets. 14 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 SEWER FUND The following graph provides a history of operating income for the past five years for the Sewer Fund. The orange bar represents a true measurement of operations to be used as a factor in determining whether sewer rates are sufficient to cover operating costs. As the graph indicates, in 2010, the City experienced operating income, which continued in 2011 and 2012 due to an effective increase in utility rates to counteract . However, an increase in operating expenses in 2013 while operating revenues remained stable led to an operating loss of $ 51,664. This trend continued into 2014 when the City had an operating loss of $ 46,225. Operating expenses remained consistent with a decrease of $ 8,064, or 1.0%. Revenues decreased $ 2,625, or 0.4%, as a result of a decrease in customer water usage. Revenues that are sufficient to cover operating costs, including depreciation, allow for an accumulation of cash to help fund replacement of depreciable assets. We recommend the City continue to review regarding renewal and replacement costs in an attempt to continue to realize an operating income. Sewer Fund $900,000 $800,000 $700,000 $600,000 $500,000 $400,000 $300,000 $200,000 $100,000 $- $(100,000) 20102011201220132014 Operating Revenues $602,407$690,745$716,448$730,933$728,308 Operating Expenses 586,702624,819664,872782,597774,533 Operating Income (Loss) 15,70565,92651,576(51,664)(46,225) Operating Income Without Depreciation324,730385,059369,554277,693288,821 15 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 WATER FUND As shown in the graph below, the Water Fund realized an operating loss in 2014 for the fourth time in the past five years. Operating revenues, excluding Water Access Charges (WAC), for the Water Fund experienced a 2.9% increase from $ 228,548 in 2013 to $ 235,185 in 2014 due to an increase in customers. Operating expenses, excluding reimbursements made to the Joint Powers Board, increased 23.5%, resulting in an operating loss of $ 181,163. We recommend the City continue to review these rates and the operations of this Fund to ensure continuing operations are self-supporting. Water Fund $500,000 $400,000 $300,000 $200,000 $100,000 $- $(100,000) $(200,000) 20102011201220132014 Operating Revenues, Net of Joint Powers Portion $236,439$209,917$252,796$228,548$235,185 Operating Expenses, Net of Joint Powers 213,528232,833295,634337,250416,348 Reimbursement Operating Income (Loss)22,911(22,916)(42,838)(108,702)(181,163) Operating Income (Loss) Without Depreciation 65,26821,0371,283(51,759)(119,135) 16 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 MARKET VALUE, TAX CAPACITY AND TAX CAPACITY RATES The graph below depicts market value of all taxable property within the City limits, along with tax capacity generated. As is evident from the graph, property market value has decreased from $639,896,127 in 2010 to $ 505,828,100 in 2014, which is a decline of 20.9%. During the same time, tax capacity has decreased from $ 8,038,215 in 2010 to $ 6,459,137, or 19.6%. Tax Capacity and Market Value $700,000,000 $9,000,000 $665,000,000$639,896,127 $630,000,000 $8,000,000 $588,889,273 $595,000,000 $8,038,215 $560,000,000 $529,263,960 $7,000,000 $505,828,100 $7,406,967 $525,000,000 $474,240,000 $490,000,000 $6,764,366 $6,000,000 $6,459,137 $455,000,000 $6,170,203 $420,000,000 $5,000,000 $385,000,000 $350,000,000 $315,000,000 $4,000,000 $280,000,000 $245,000,000 $3,000,000 $210,000,000 $175,000,000 $2,000,000 $140,000,000 $105,000,000 $1,000,000 $70,000,000 $35,000,000 $- $- 20102011201220132014 Market ValueTax Capacity 17 CITY OF ALBERTVILLE FINANCIAL ANALYSIS December 31, 2014 MARKET VALUE, TAX CAPACITY AND TAX CAPACITY RATES Tax Capacity Rate 60.000 51.945 51.092 50.000 46.645 41.933 40.000 36.705 30.000 20.000 10.000 0.000 20102011201220132014 As noted above, actual levies increased from 2010 to 2013, and decreased slightly in 2014. The main factor in the decreased tax rate for 2014 shown above is the increase in tax capacity and market value presented on the previous graph. 18 CITY OF ALBERTVILLE EMERGING ISSUES December 31, 2014 Executive Summary The following is an executive summary of financial and business related updates to assist you in staying current on emerging issues in accounting and finance. This summary will give you a preview of the new standards that have been recently issued and what is on the horizon for the near future. The most recent and significant updates include: Internal Control Integrated Framework COSO has issued an updated integrated framework for internal control. The update is expected to make the integrated internal control framework easier to use and apply. In addition, the update takes into account globalization of businesses today and its interdependence on technology. The updated framework superseded the original framework beginning January 1, 2015. Accounting Standard Update Accounting for Pensions GASB has issued new statements relating to accounting and disclosures for pension. The new statements require governments providing defined benefit pensions to recognize their long-term obligation for pension benefits as a liability. In addition, the statement includes new requirements for required supplementary information and more extensive footnote disclosures. Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards The Office of Management and Budget (OMB) issued grant reform rules on December 23, 2013. This reform streamlines the language from eight existing OMB Circulars (listed below) into one consolidated set of guid COSO PROJECT INTERNAL CONTROL INTEGRATED FRAMEWORK In 1992, the Committee on Sponsoring Organizations of the Treadway Commission (COSO) developed an internal control framework that has been adopted and used by entities worldwide. In 2013, COSO finalized and released an updated integrated internal control framework. The update is expected to make the integrated framework easier to use and apply. In addition, the update takes into account, the business environment of today and the reliance on and interdependence of technology within business systems. The internal control update is not changing the core definition of internal control, the three categories of objectives or the five components of internal control. other personnel. This process is designed to provide reasonable assurance regarding the achievement of the three objectives, as follows: effectiveness and efficiency of operations; reliability of financial reporting; and compliance with applicable laws and regulations. 1. Internal control is a process. It is a means to an end, not an end in itself. 2. Internal control is not merely documented by policy manuals and forms. Rather, it is put in by people at every level of an organization. 3. management and board. 4. Internal control is geared to the achievement of objectives in one or more separate but overlapping categories. 19 CITY OF ALBERTVILLE EMERGING ISSUES December 31, 2014 COSO PROJECT INTERNAL CONTROL INTEGRATED FRAMEWORK (CONTINUED) The five components of internal control, which are unchanged, are as follows: 1. Control Environment - integrity, ethics, management style, etc. 2. Risk Assessment - identification and analysis of relevant risks 3. Control Activities - policies, procedures and activities, including segregation of duties 4. Information and Communication - ensure information effectively flows up, down and across the organization, both internally and externally 5. Monitoring Activities - assessment of the systems performance over time The updated framework has changed to address the changes in business and operating environments, such as globalization of markets and operations, greater complexities in businesses, reliance on evolving technologies and expectations relating to preventing and detecting fraud. In addition, principles of effective internal controls have been added to each of the components of internal control as follows: Control Environment: 1. Demonstrates a commitment to integrity and ethical values. 2. The board of directors is independent from management and exercises oversight responsibility of the performance of internal controls. 3. Management establishes structure, reporting lines, authority and responsibility. 4. Demonstrates a commitment to attract, develop and retain competent individuals. 5. Enforces accountability for individuals internal control responsibilities. Risk Assessment: 6. Specifies suitable objectives with sufficient clarity. 7. Identifies and analyzes risk as a basis for how risks should be managed. 8. Assesses the potential for fraud risk. 9. Identifies and analyzes significant changes that could impact the system of internal controls. Control Activities: 10. Selects and develops control activities that contribute to the mitigation of risks. 11. Selects and develops general controls over technology. 12. Deploys control activities through policies that establish what is expected and procedures that put policies into place. Information and Communication: 13. Uses relevant information to support the functioning of other components of internal control. 14. Communicates information internally, including objectives and responsibilities necessary to support the internal controls. 15. Communicates with external parties regarding matters affecting internal control. Monitoring Activities: 16. Conducts ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning. 17. Evaluates and communicates deficiencies to those parties responsible for corrective actions. 20 CITY OF ALBERTVILLE EMERGING ISSUES December 31, 2014 COSO PROJECT INTERNAL CONTROL INTEGRATED FRAMEWORK (CONTINUED) The updated framework also has additional examples relevant to operation, compliance and reporting objectives added. While COSO integrated internal control framework is very extensive, this is only a short summary of some of the changes of the updated framework. The updated framework superseded the original framework beginning January 1, 2015. ACCOUNTING STANDARD UPDATE ACCOUNTING FOR PENSIONS GASB Statement No. 68 replaces the requirements of Statement No. 27, Accounting for Pensions by State and Local Governmental Employers and Statement No. 50, Pension Disclosures, as they relate to governments that provide pensions through pension plans administered as trusts or similar arrangements that meet certain criteria. Statement No. 68 requires governments providing defined benefit pensions to recognize their long-term obligation for pension benefits as a liability for the first time, and to more comprehensively and comparably measure the annual costs of pension benefits. GASB Statement No. 71 Pension Transition for Contributions Made Subsequent to the Measurement Date is an amendment of GASB No. 68. -wide statement of net position and the proprietary fund statements of net position contributions The Net Pension Liability is measured as the total pension liability less the amount of the PERA and TRA currently estimating this around $6 7 billion each Governmental Funds will present pension expenditures equal to the total of 1) amounts paid by employer to the pension plan and 2) the change between the beginning and ending balances of amounts normally expected to be liquidated with expendable available financial resources (i.e. No Change) PERA and TRA have been proactive in steps toward implementation and the outlook for reporting to members appears good, based on current plans - the hope is that most of the -ated data PERA and TRA both have a June 30 fiscal year-end this is the measurement date you will utilize for your presentation in your June 30 financial statements twelve months subsequent to that date Other Deferred Inflows/Outflows will include: differences between expected and actual economic experience and investment earnings, changes in assumptions and changes in employer proportion and difference between contributions and proportionate share of pension expense Required Supplementary Information will be two separate schedules Schedule of Changes in Net Pension Liability and Related Ratios & Schedule of Contributions - 10-year presentation for each with notes GASB 71 clarifies that in the year of implementation you must determine the deferred outflows associated with pension contributions made subsequent to the measurement date even if it is not practical to determine the other deferred inflows and outflows 21 CITY OF ALBERTVILLE EMERGING ISSUES December 31, 2014 ACCOUNTING STANDARD UPDATE ACCOUNTING FOR PENSIONS (CONTINUED) PERA and TRA Plan: Perform annual actuarial valuations to determine funded status and liabilities Require plan actuary to calculate collective amount of items requiring deferred treatment proportionate share Communicate results to the local governments Provide RSI and suggested footnotes Local Impacts: Your liability on your government-wide statements. As of December 31, 2014, PERA has estimated the liability for your city to be $ 756,297, based on the total unfunded liability as of their June 30, 2014 year end. Expenditures will continue to be tracked in the fund statements for your statutory contributions, but a reconciling item will be needed to adjust these contributions with your government-wide expenses which will be represented by the change in the net pension liability As a result, your financial statements/financial position will be immediately impacted by funding shortfalls at the pension plan Additional RSI presenting 10 years of information regarding net pension liability, required & actual contributions and related ratios Adds more extensive note disclosures, including sensitivity analysis of investment return assumption Requires employer to track annual balances of deferred outflows of resources and inflows of resources. Must describe signification assumptions and other inputs used to measure total pension liability. UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS The Office of Management and Budget (OMB) issued grant reform rules on December 23, 2013. This uniform grant guidance streamlines Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. Effective Dates Federal agencies must implement the requirements to be effective by December 26, 2014. Non-federal entities will need to implement the new Administrative Requirements and Cost Principles for all new Federal Awards made after December 26, 2014. Audit Requirements are effective for fiscal years beginning on or after December 26, 2014. 22 CITY OF ALBERTVILLE EMERGING ISSUES December 31, 2014 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS (CONTINUED) Objective of OMB Grant Reform This reform streamlines the language from eight existing OMB Circulars into one consolidated set of guidance, in the code of Federal regulations, known as the The objective of the grant reform is to reduce administrative burden for non-federal entities receiving Federal Awards while reducing the risk of waste, fraud and abuse by: 1. Eliminating duplicative and conflicting guidance 2. Focusing on performance over compliance for accountability 3. Encouraging efficient use of information technology and shared services 4. Providing for consistent and transparent treatment of costs 5. Limiting allowable costs to make the best use of federal resources 6. Setting standard processes using data definitions 7. Encouraging non-federal entities to have family friendly policies 8. Strengthening oversight 9. Targeting audit requirements on risk of waste, fraud and abuse This grant reform complements targeted efforts by OMB and a number of Federal agencies to reform overall approaches to grant-making by implementing innovative, outcome-focused grant making decisions and processes in collaboration with their non-federal partners. Administrative Requirements Subpart A-D of Federal Register Following are some of the notable items in the updated Administrative Requirements. Must is defined as required Should is defined as best practice or recommended approach The term is no longer used and was replaced with the term (Section 200.23) Personally Identifiable Information (PII) and Protected Personally Identifiable Information (PPII) are defined (Sections 200.79 and 200.82) Fixed amount awards focused on meeting performance milestones (Section 200.201) Emphasis on performance goals and performance reporting (Section 200.301) Defined that computers are considered supplies, not equipment (Section 200.940) Flexibility in electronic documentation retention, with associated internal controls (Section 200.335) Internal Controls (Section 200.303) Internal controls should comply with: the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Federal statutes, regulations and terms and conditions of the Federal award Internal controls must: Evaluate and monitor compliance Take prompt action for noncompliance Take reasonable measures to safeguard PPII and other sensitive information 23 CITY OF ALBERTVILLE EMERGING ISSUES December 31, 2014 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS (CONTINUED) Procurement Standards (Sections 200.317 through 200.326) Guidelines provide five different procurement methods Micro-purchases Small purchases Sealed bids Competitive proposals Noncompetitive proposals Entities must have a documented procurement policy, written standards of conduct covering organizational conflicts of interest and must maintain oversight to ensure that contractors perform in accordance with the terms, conditions and specifications of their contracts or purchase orders. Subrecipient Monitoring (Sections 200.330 through 200.332 and 200.521) The pass-through entity must clearly identify the agreements as a subaward and must provide up to 13 different award identification pieces of information within the contract. There are also other required disclosures described for all requirements imposed by the pass-through entity on the subrecipient, indirect cost rate, allowing access to records, etc. An evaluation of each subrecipients risk of noncompliance is also required. Cost Principles Subpart E of Federal Register Following are some of the notable items in the updated Cost Principles. Indirect/Direct Costs (Sections 200.413-200.414) Salaries of administrative or clerical staff could be directly charged to a federal program if they meet certain conditions. Any non-federal entity that has never negotiated an indirect cost rate may elect to charge a de minimis rate of 10% of modified total direct costs which may be used indefinitely Federally negotiated indirect cost rates must be accepted by all federal awarding agencies (usually). Any non-federal entity that has a federally negotiated indirect cost rate may apply for a one- time extension of a current negotiated indirect cost rates for a period of up to four years. Time and Effort Reporting (Section 200.430) Charges to Federal Awards must be based on records that accurately reflect the work performed. Records are to be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated There is flexibility in process used to meet those standards Personnel activity reports not specifically required Maintained budget estimates may be used for interim accounting purposes, provided that, the non-federal system of internal controls includes processes to review after-the- fact interim charges made to a Federal Award based on budget estimates to ensure adjustments are made so final amounts to Federal Awards are proper. 24 CITY OF ALBERTVILLE EMERGING ISSUES December 31, 2014 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS (CONTINUED) Audit Requirements Subpart F of Federal Register Following are some of the notable items in the updated Audit Requirements. Single Audit threshold raised from $ 500,000 in Federal Awards per year to $ 750,000 in Federal awards per year Major program determination changes include: Type A/B program threshold is a sliding scale with a minimum of $ 750,000 Percentage of coverage rule changes to 40% (50% currently) for non-low risk auditees and 20% (25% currently) for low risk auditees Updated criteria for a low-risk auditee Going concern is incorporated Cognizant/oversight agency can no longer waive exception Reporting for questioned costs threshold raised from $ 10,000 to $ 25,000 Other Items of Interest List of items requiring prior written approval (Section 200.407) Advertising and public relations clarified, include program outreach (Section 200.421) Conference spending clarified (Section 200.432) Employee costs eliminated (Section 200.437) Example of Strategy to Implement OMB Grant Reform Changes 1. Understand grant reform changes 2. Assign an internal expert who will be responsible for leading effort (time, resources and availability) 3. Establish a team and include those in program, financial and budget sides of federal grant management 4. Develop a plan and concentrate on areas of most significance first 5. Obtain approval from management and those charged with governance as it relates to policy changes 6. Attain/Provide training on new requirements and new entity specific policies and procedures 7. Monitor plan and focus on areas of most significant change Additional Resources on OMB Grant Reform OMB Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniform- administrative-requirements-cost-principles-and-audit-requirements-for-federal-awards) COFAR FAQS (https://cfo.gov/wp-content/uploads/2013/01/2-C.F.R.-200-FAQs-2-12-2014.pdf) (https://cfo.gov/wp-content/uploads/2014/08/2014-08-29-Frequently-Asked- Questions.pdf) OMB Policy Statements (http://www.whitehouse.gov/OMB/grants_docs) 25