District I
Audit Finding Resolution Summary
Region I
East Central Missouri Solid Waste Management District
Date of Final Audit Report: April 22, 1999
For The Fiscal Years: 1992 - 1997
Date of Final Resolution: May 9, 2000
This document is a summary of the actual findings and resolutions
determined by this audit. The document is posted here for informational
purposes only and not all data from the audit is included here.
A complete copy of the audit material may be requested under Section
610, Revised Statutes of Missouri and can be obtained by contacting
the Solid Waste Management Program (SWMP) at 573-751-5401.
Audit Finding and Recommendation:
Interest Income Not Reported. Interest income was earned by the
district in their checking account. The district did not report
their interest income and the program did not deduct the interest
income from outlays. Total interest earnings for fiscal years 1992
1997 amounted to $9,587. The Department of Natural Resources
(DNR) General Terms and Conditions (GTC) II.C. states, "Program
income shall be deducted from outlays which may be both federal
and nonfederal, unless the DNR, as negotiated with the recipient,
or federal awarding agency specifies an alternative method in the
agreement." The auditor recommended the program reduce future
payments to the district for the interest earned for fiscal years
1992-1997 ($9,587) or that the district obtain permission from the
program to use this interest income for administration of the program.
District Response:
The district is in receipt of correspondence that states the
SWMP has determined that it is acceptable for districts to use accrued
interest income for approved activities.
Final Resolution:
The DNR considers Finding 1 resolved as the district provided
to the SWMP on March 2, 1999, a copy of a Dec.13, 1999, letter from
the SWMP to all twenty districts giving permission to use and instructions
as to how to use accrued interest income to comply with GTC, II.C.
A copy of the minutes from the Feb. 8, 2000, districts executive
board meeting in which this issue was discussed was also provided.
All documentation will be retained in the districts permanent
file.
Audit Finding and Recommendation:
Composition of the Executive Board. The districts
executive board is comprised of five voting members and one non-voting
member. RSMo, Section 260.315.4.(2) states that the council shall
select seven persons to serve on the executive board. East Central
Missouri Solid Waste Management District (SWMD) believes that the
by-laws of the district were intended to demonstrate that an alternative
management structure had been formulated and compliance to state
regulations achieved. They cite DNRs Model Plan Guidelines
for Comprehensive Solid Waste Management, Chapter 3, under the
heading Alternative Management Structure, "The district can
determine the number of members to serve on the executive board,
as well as their terms of office and the manner of selection and
replacement for the members." However, East Central Missouri
SWMD does acknowledge that they have not obtained from each local
political subdivision member a letter approving the Alternative
Management Structure. The auditor recommended that the by-laws,
Alternative Management Structure, and approval letter from each
participating local political subdivision member be submitted to
DNR to demonstrate compliance with RSMo, Section 260.315.
District Response:
The districts by-laws, which were revised and adopted
June 1996 show that an alternative management structure has been
formed and is in compliance with RSMo, Section 260.315. This issue
is being re-affirmed by a resolution letter from each participating
political subdivision.
Final Resolution:
The DNR considers Finding 2 resolved as the district provided
a copy of its by-laws showing that the district adopted an alternative
management structure as required by Section 260.300(3) RSMo. The
district has also decided to re-affirm this structure by current
resolution. A copy of the resolutions forwarded to pertinent entities
was provided to the SWMP on March 22, 2000. The district has indicated
that the signed copies will be forwarded to the SWMP upon their
receipt, which are due to the district on April 15, 2000. This documentation
was received on April 28, 2000. All documentation will be retained
in the districts permanent file.
Audit Finding and Resolution:
MBE/WBE Utilization. The districts current
practices do not include a formal policy to encourage utilization
of minority, women, and small disadvantaged businesses when procuring
goods and services. Additionally, DNR has no record of the district
submitting Form 334, "MBE/WBE Utilization Report." The
DNRs GTC, II.W. and RSMo, Section 260.320.4 require the district
establish policies which encourage the utilization of such disadvantaged
enterprises. The auditor recommended the district procurement policies
be amended to include the GTC provisions relating to the encouragement
of utilizing disadvanteged enterprises. Appropriate documentation
should be maintained in the file supporting submission of Form 334
"MBE/WBE Utilization Report" to the DNR.
District Response:
The administering agency does have a MBE/WBE utilization policy
in place. The executive board has also adopted this policy and the
districts by-laws will be amended by a vote of the full Council
at their next meeting. Form 334 will be filed with quarterly reports.
Final Resolution:
The DNR considers Finding 3 resolved. The district provided
to the SWMP on March 1, 2000, a copy of the administering agencys
policy, the districts amendment to its by-laws and a copy
of the executive board meeting minutes in which this issue was discussed
and approved in compliance with GTC, II.W. The district provided
a copy of the administering agencys policy on March 22, 2000.
All documentation will be retained in the districts permanent
file.
Audit Finding and Recommendation:
Evaluation Criteria Not Followed. The district has a policy
to review and rank district grant proposals that is lacking components
of the criteria set by the DNR. 10 CSR 80-9.050(2)(c)3 states that
the executive board shall evaluate each proposal that is determined
to be eligible and complete according to the criteria required by
the DNR. The board will also develop a District Targeted Materials
List to be used as one of the evaluation criteria. The auditor recommended
the district adopt the DNRs evaluation criteria to be used
in ranking future proposals.
District Response:
Evaluation criteria was revised to comply with 10 CSR 80-9.050(2)(C)3
and approved by the districts executive board.
Final Resolution:
The DNR considers Finding 4 resolved. The district provided to the SWMP
on March 1, 2000, a copy of evaluation criteria that was a part of its Fiscal
Year 2000 (FY00) grant cycle and executive board meeting minutes in which
this issue was discussed and approved in compliance with 10 CSR 80-9.050(2)(C)3.
All documentation will be retained in the districts permanent file.
Audit Finding and Recommendation:
Quarterly Reports Not Filed District Grants. The auditor noted
that quarterly reports for district grant 94103 were not submitted to DNR
as required. 10 CSR 80-9.050(3)(B) states that "The district shall submit
to the department at the end of each fiscal year quarter, a report
"
The recipient had not submitted a report to the district. The auditor recommended
that the district hold payment to the project recipient until all reporting
requirements are met.
District Response:
A copy of page 3 of the application for financial assistance for FY00
is attached. This information will be stated in the subgrantees Financial
Assistance Agreements as well.
Final Resolution:
The DNR considers Finding 5 resolved. The district provided
to the SWMP on March 22, 2000, a copy of criteria from its application
packet to potential applicants that outlines the districts
policy on reimbursements, quarterly/final reporting, and 15 percent
withholding. The SWMP does not elect to take further action regarding
previous late quarterly reports as this situation is no longer occurring
and SWMP believes the district understands and intends to comply
with this requirement in the future. All documentation will be retained
in the districts permanent file.
