Finding Text
District Credit Cards Repeat Finding: This finding was first reported in 2022 (Finding 2022-002). See Section IV: Prior Year Findings for management’s status update. Criteria: A sound system of internal control over financial reporting includes a formalized credit card use agreement, which specifies authorized purchases, transactional limits (individually or in the aggregate), policies for providing transactional support and general ledger coding instruction and supervisory review. Condition: During 2023, the District provided and authorized the use of District credit cards to certain employees. The absence of a formalized credit card use policy left the maintenance of authorized users, operational validity if purchases, criteria for properly documented receipts and cost reimbursement to the discretion of the credit card users. Audit procures additionally identified instances in which sales tax was paid on purchases despite the District’s tax-exempt status, one transaction lacking adequate supporting documentation and fuel credit cards maintained within District vehicles rather than assigned to specific employees or administered through a documented checkout process. Cause: The District had not fully established or formally adopted comprehensive policies and procedures governing credit card usage and monitoring controls. Additionally, the prior year audit report containing recommendations related to this matter was not issued until January 29, 2025, subsequent to the 2023 reporting period; therefore, management did not have the opportunity during the year under audit to implement corrective actions related to this finding. Effect: During 2023, one credit card transaction totaling $42.94 was identified as personal in nature and was subsequently reimbursed to the District. Audit procedures also identified transactions in which sales tax totaling $74.14 was paid on otherwise exempt purchases and one transaction for which adequate documentation was not maintained. Inadequate controls over credit card activity increase the risk of unauthorized, unsupported or personal expenditures not being identified timely. Recommendation: We recommend the establishment and adoption of a formal credit card use and review policy. This policy should include clear guidelines for approved uses of credit cards, transactional limits, required documentation, supervisory review and approval procedures, reimbursement requirements, tax-exempt purchasing procedures and accountability controls over fuel credit cards. Views of Responsible Officials and Planned Corrective Action: Management acknowledges the need to strengthen internal controls surrounding the use of District credit cards. In 2024, the District implemented a requirement for the Harbor Master to review all credit card transactions prior to fulfillment of the combined credit card bill. Management is currently evaluating the form and function of a formalized credit card use agreement and related monitoring procedures.