To the editor:
As a CPA who has been practicing in the field of audit for over 20 years, I find the lack of accountability on the part of ISD 200 concerning in regards to the Josh McLay issue. Internal controls include the processes involved in submitting, reviewing, approving and disbursing expense reimbursements. It clearly appears certain individuals did not perform their duties according to their job descriptions, as publicly posted on the ISD 200 website.
Once all receipts were properly submitted to the athletic department, they are submitted to the district office for approval. Due to reorganization within the district finance office, the names of the positions have changed but the job description and responsibilities remain the same.
1. Accounts Payable/AR Clerk or Accountant - "review purchase orders ... prior to payment, communicates any inappropriate expenditures or non compliance to Accounting Supervisor."
2. Finance Supervisor or Accounting Supervisor - "Monitors financial activity (e.g. purchase orders, vouchers, timesheets and business leave requests) for accuracy, appropriateness, correct coding, budget compliance and proper authorization."
Once a coach submits receipts for approval and payment, it appears it goes through approximately five people, with the final two approvals within the finance department being responsible for compliance. Numerous people in all levels of this chain of command have not accurately done their job as these expenses were approved and reimbursed for seven or more years. This indicates a weakness within the internal controls approval process.
Superintendent Tim Collins indicated on a KDWA broadcast that the district office relies on the approval of the athletic director/department heads and the chain of command stops there. According to district job descriptions, the chain of command does not stop until it reaches the finance/accounting supervisor. Is the district office unaware of the responsibility they have on the approval of expenditures and compliance?
Donations to Fund 11:
Under the Appropriate Expenditures Policy guideline located on the ISD 200 website it indicates on page 2 in bold, "Donation or Grant monies may be expended for the purposes authorized in the donation or grant."
Collins stated on KDWA, "that dollars donated to Fund 11 need to be expensed according to the law" and indicated donors were not contacted as part of the investigation. However, the law also allows donors to restrict their donations for specific purposes and dollars need to be spent according to donor guidelines. Documentation on donor's intent was not included in the publicly available information. Without provided documentation and without contacting donors, how can the superintendent and school board determine that the funds were not spent according to donor's intent?
Fund 11 expenses:
We have all heard about the 2011 email "where Mr. McLay was told football tickets are for entertainment are not an acceptable expenditure" as stated at the school board meeting posted to Facebook and responses on air with KDWA. This email reply is actually only one sentence long. "The travel expenses (gas, van and hotel) are ok but entertainment expenses are not."
The question Mr. McLay asked to receive this response ended with "Please let me know what I can do so I don't make a mistake."
The response he received was one sentence. I would expect more guidance from the accounting/finance supervisor in regards to that entertainment expenses are never OK and even a quick overview of what Fund 11 can be used for or where to find the information. There seems to be an overreliance on four words "entertainment expenses are not" which is supposed to "educate" him on how the funds can be used. The rest of the email has conveniently been omitted from any narrative.
As McLay stated in his 2011 email, he did not want to make a mistake. However, as it turns out he is being accused of making a mistake. As did many district employees all the way up the chain of command ending with who had access to the funds to reimburse McLay. For the lowest level in the transaction to be the only district employee seeing consequences is concerning. The district needs to take accountability for the mistakes and lack of controls over approvals and compliance at all levels in this transaction.
A "top-down" approach in reviewing the existing internal controls should be performed to see who dropped the ball in many different areas to allow this to happen. How can we as taxpayers feel confident that ISD 200 has proper controls in place to prevent this from happening on a much grander scale?
The superintendent and school board went public with this issue two weeks ago, yet the investigation report is still not available. We all want what is best for the students and residents of this community. However, I do not believe we have the answer yet. I encourage residents to continue to ask the school board the tough questions on all issues within the district. I want Hastings to be a great place for my children to grow up.