District N

Audit Finding Resolution Summary
Regin N Solid Waste Management District
Date of Final Audit Report: Feb. 21, 1996
For The Fiscal Years: 1993, 1994 and 1995
Date of Final Resolution: July 12, 1996

Note.gif (986 bytes) 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 at 573-751-5401.

Review of Accounting and Internal Control

1.  Audit Finding and Recommendation:
Inadequate Accounting Systems and Procedures. The district does not have an effective system of internal controls over accounting functions.

  1. District checks currently require only one signature, allowing no other person an active role in the administration or review of the district’s financial matters.
  2. There is no review of the treasurer’s bank statement reconciliations.
  3. A review of the bank statements revealed that check number 1642 in the amount of $20 was dated May 19, 1995, and at the time of field work had yet to clear the bank.
  4. District receipts are not deposited promptly.
  5. The District Coordinator and Secretary are not bonded.
  6. The petty cash fund was not administered correctly. The petty cash fund should be reconciled each time it is replenished. This reconciliation should be performed by someone other than the person in control of the fund.
  7. Checks were written without documentation.
  8. Travel advances were given without documentation.
  9. On several occasions, district bills were paid twice. The district does not currently have a mechanism in place to prevent duplicate payments from occurring.

The auditor recommended the district establish a system of internal controls including an adequate segregation of accounting duties and that the district require dual signatures on all district checks.

District Response: 1(A), 1(B), 1(D)
The district stated that it had established a comprehensive system of internal controls at the November 1995 Executive Board meeting. The meeting minutes from that board meeting contain verification of the changes made on internal controls. The following controls have been in place since November 28, 1995.

A. District checks currently require two signatures, the Executive Board Treasurer and one additional board member; the Executive Chairperson can sign for either one, but not both at the same time. Bills and invoices are received in the office by the District Secretary. Bills and invoices are then paid in the accounting software by the District Coordinator and checks generated. The District Coordinator reviews all checks against bills and invoices. The District Secretary then takes the checks and corresponding documentation to the Treasurer for review and signature. Once the Treasurer has signed, the District Secretary then takes the checks to the authorized Board Member or to the Chairperson who then reviews and adds the second signature to the check(s). After two signatures have been obtained, the District Secretary brings the signed checks back to the office to be mailed.

B. Bank statement reconciliations are performed by the District Secretary, reviewed by the District Coordinator, approved by the Treasurer, and reviewed and approved by the Executive Board on a monthly basis. Disbursement orders are generated on a monthly basis. Each disbursement order contains a printout of the check register, all account information, the reconciled bank statement, any canceled checks, deposit slips, and account transactions during that month. Also, the disbursement order contains the documentation for each bill and invoice paid that month, plus the payroll information on each employee paid that month. The disbursement order is reviewed and approved by the Treasurer and then presented to the Executive Board for review and approval at the monthly board meeting. It was noted by the district that disbursement orders had always been handled this way by the district.

D. District deposits are logged in the office the day they are received by the District Coordinator and marked "For Deposit Only" by the District Secretary and then taken for deposit by the Treasurer.

In addition to the above controls, the district has retained a CPA to audit the district on an annual basis and provide accounting support during the year.

Final Resolution:
The Department of Natural Resources (DNR) considers this matter resolved. DNR’s Division of Administrative Support (DAS) acknowledged that the above procedure was acceptable.

District Response: 1(C)
C.  The district stated that the Treasurer performed periodic reconciliations and presented all documentation to the Executive Board for review and approval. The district also responded that check number 1642, outstanding since May 19, 1995, was first highlighted during the bank reconciliation in August 1995. Notice was given to the recipient of the outstanding check. The district communicated to the recipient the need to account for the check. The individual looked for the check and did not locate it, so the check was voided on February 1, 1996. A replacement check was not and will not be cut.

Final Resolution:
The DNR considers this matter resolved with the understanding that the district follow the auditor’s recommendation that "a proper bank reconciliation highlights checks which are outstanding for two consecutive bank statement cycles."

District Response: 1(E)
E.  The district stated it is currently in the process of bonding the positions of Chairperson, Board Member, and Treasurer, along with the District Coordinator, and District Secretary. The application for bonding of the above positions and personnel was submitted on May 2, 1996. The district anticipates that bonding of these positions and employees will be in effect by July 1, 1996.

Final Resolution:
The DNR considers this matter resolved with the understanding that a copy of the bonding documentation is submitted to the Solid Waste Management Program (SWMP). The documentation was received on June 24, 1996.

District Response: 1(F)
F.  The district stated that the petty cash fund is being administered in accordance with General Accounting Principles. Each time the fund is replenished it is brought back to its authorized amount of $75.00. All receipts for expenditures are totaled by the District Secretary and a disbursement record created for review. The District Coordinator reviews the record and submits it for payment as an invoice. A check is then generated as payment for the invoice. The check requires the same review and signatures as any check. The signed check is then cashed and the money placed in a locked box in the office for use by the staff for minor district expenses. The District Coordinator is responsible for distribution of funds from petty cash. The reimbursement check then becomes part of that month’s Disbursement Order. The petty cash fund has always been reconciled before replenishment.

Final Resolution:
The DNR considers this matter resolved per DNR’s DAS acknowledgment that the above procedure was acceptable and assuming that the procedures outlined will be followed in the future.

District Response: 1(G), 1(H)
G. The district stated that it is its policy that all checks must have documentation as to the expenditure and that they are reasonable and are being used to support district operations.

H. The district stated that its policy is that all travel advances have proper documentation prior to approval. It is also policy that all travel advances be reconciled after the conclusion of the travel. The reconciliation takes place on the employee expense report.

Final Resolution:
The DNR considers this matter resolved with the understanding that the district provides to the SWMP a description of procedures it follows to insure adequate source documentation for expenditure of district funds, and a description of the procedures the district follows for travel advances and final reconciliation. This documentation was received on June 24, 1996.

District Response: 1(I)
I. 
The district stated that it has put in place a mechanism to prevent bills from being paid twice. This mechanism is in accordance with General Accounting Principals. These controls have been in place since November 1995.

Final Resolution:
The DNR considers this matter resolved with the understanding that the district submits a description of the procedures it follows to prevent bills from being paid twice. This documentation was received on June 24, 1996.

2.  Audit Finding and Recommendation:
Improper payment reimbursed. An error on the District Secretary’s W-2 resulted in an overpayment of tax refund from the IRS to the District Secretary totaling $1,054. When this error was realized, the District Secretary had to obtain a loan to repay the IRS for the overpayment. The District Secretary incurred $162.84 in interest and loan fees to acquire this loan. The district in turn used grant funds to reimburse the District Secretary for these costs. Grant fund should not be used to correct district errors, and thus are disallowed. The auditor recommended the program recover $162.84 from the district for this disallowed reimbursement.

District Response:
The district believes that the expenditure of $162.84 to the Secretary of the district for reimbursement of expenses resulting from an error in the employee's W-2 on the part of the district's Treasurer should be an allowed expense under the Administration Grant for the district. The district would like DNR to reconsider this expenditure as being an allowed expense.

Final Resolution:
The DNR will consider the matter of $162.84 in questioned costs resolved with the understanding that the SWMP will seek a legal opinion regarding whether this cost is eligible under the state grant program. A legal opinion from the Attorney General’s Office deemed the costs ineligible. The district was notified and the district recovered the funds via their risk insurance and a check for $162.84 was deposited to the district’s account on June 12, 1997.

Review of District Grants

1.  Audit Findings and Recommendations:
No formal evaluation completed. 10 CSR 80-9.050 (2)(C)3 lists 17 criteria which are to be used to evaluate district grant proposals. These required evaluation criteria have not been used to evaluate proposals. An evaluation sheet has been created for the 1996 district grant cycle.

The auditor recommended the district complete a formal written evaluation sheet including the required 17 criteria for each district grant proposal.

District Response:
The district stated that it has instituted an evaluation of all grant applications starting with the 1996 grant cycle.

Final Resolution:
The DNR considers this matter resolved with the understanding that the district provides the SWMP a copy of its evaluation criteria. The DNR will accept this as evidence of the district’s intent to complete evaluations and ranking for all future district grant applications. This documentation was received on June 24, 1996.

2.  Audit Findings and Recommendations:
Incomplete proposals accepted. 10 CSR 80-9.050(2)(B) lists the elements which are required for each proposal. Proposals have been approved which did not contain the proper elements. The auditor recommended the district require proposals to contain the information required in CSR 80-9.050(2)(B).

District Response:
The district stated that the evaluation process instituted with the 1996 District Grant Applications will ensure that all information as required by the District Grant Rule is included in each grant application.

Final Resolution:
The DNR considers this matter resolved with the understanding that the district provides the SWMP a copy of its criteria for ensuring that each application is complete. This documentation was received on June 24, 1996.

3.  Audit Findings and Recommendations:
No financial assistance agreements. 10 CSR 80-9.050(5)(B)2.B states "Before awarded funds are distributed to an applicant, the applicant shall…Enter into a financial assistance agreement issued by the district which is consistent with the department’s terms and conditions." No Financial Assistance Agreement (FAA) was completed between the district and the DNR for three of their 1993 district grants.

The auditor recommended the district complete a FAA with the DNR for each district grant and that the district complete a FAA with each district grant subrecipient.

Final Resolution:
The DNR considers this matter resolved for Fiscal Year 1993 District Grant projects as FAAs were not provided to districts for that grant cycle. The district understands that beginning with the Fiscal Year 1994 District Grant cycle, FAAs are required between the district and the DNR as well as between the district and its subgrantees.

4.  Audit Findings and Recommendations:
District grants not administered on reimbursement basis. According to the DNR’s General Terms and Conditions II.A, "The recipient will be reimbursed for all allowable expenses incurred in performing the scope of services. The recipient shall report project expenses and submit standard invoices, attached to the agreement, for payment." The district grants have not been adminstered on a reimbursement basis. The district has given the subrecipient 85 percent of the grant amount before any expenditures were incurred and documented. The district plans to administer the 1996 grants on a totally reimbursement basis. The auditor recommended the district administer all district grants on a reimbursement basis.

District Response:
The district stated that beginning with the 1996 District Grant cycle, it is the district's policy to administer grant funds on a reimbursement basis. This information was conveyed to all potential grantees at two workshops conducted prior to the formal District Grant call in November 1995. This information on grant administration was also written into the application package that was sent to prospective grantees.

Final Resolution:
The DNR will consider this matter resolved with the understanding that the district provides to the SWMP a copy of the Fiscal Year 1996 application package provided to subgrantees to ensure that grants are administered on a reimbursement basis only. The district will also provide a list of all outstanding district grants from prior years, as well as certification in quarterly reports that all funding spent by subgrantees has been documented appropriately as eligible for grant funds. This documentation was received on June 24, 1996.

5.  Audit Finding and Recommendation:
Quarterly reports not submitted on time. Quarterly reports have not been submitted by the district to the program in a timely manner. The auditor recommended the district submit quarterly reports each fiscal quarter for each district grant in progress.

Final Resolution:
The DNR will consider this matter resolved with the understanding that the district will submit future Quarterly Status Reports (QSR) in a timely manner. For now, the timetable for QSRs will be established by the SWMP based upon the DNR Director’s signature date on the grant agreement. Districts shall not receive funding until all QSRs are up to date.

6.  Audit Finding and Recommendation:
No notices of solicitation of bids. To ensure each area an equitable opportunity to receive grant funds the district is required by 10 CSR 80-9.050(2)(A)2 to request project proposals by written notification to governing officials and by published notices in area newspaper. The district is also required by 10 CSR 80-9.050(3)(A)4 to submit to the department a copy of such notices. For the 1993 grant cycle, no copies were submitted to the program documenting solicitation in area newspapers. The auditor recommended the district submit to the SWMP documentation of notices of solicitation of bids for each grant cycle.

District Response:
The district stated that it has always been its policy to require written notification of request for proposals to the governing officials of each county and to area newspapers for each grant cycle. In the 1993 grant cycle, notifications were made to the city and county officials and to the local newspapers.

Final Resolution:
The DNR considers this matter resolved with the understanding that the district provides the SWMP with copies of area newspaper solicitations for Fiscal Year 1993 or a signed, notarized affidavit stating that such notices were published. The notarized affadavit was received on June 24, 1996. 

7.  Audit Finding and Recommendation:
Contingency funds approved in proposal. The District Board approved the proposal for project number 93023 including $667.20 in contingency funds. Contingency funds are specifically prohibited by 10 CSR 80-9.050(1)(E)2.E which states, "The following costs are considered ineligible for district grant funding…Contingency funds." The auditor recommended the district recover $667.20 for disallowed contingency funds.

District Response:
The district stated that the $667.20 in questioned costs is from the 1993 District Grant called Paving The Way. This grant had included in its budget a contingency fund for the above amount. The grant was revised to include a new budget for expenditure of the funds. At that time the $667.20 was eliminated as a budget item and included with the funds used for construction of the glass crushing facility. A quarterly report updating this grant is under development and will be submitted to SWMP upon completion.

Final Resolution:
The DNR considers this matter resolved with the understanding that the SWMP receives a quarterly report updating the grant and a cover letter stipulating that the district will not allow "contingency" costs in any budget category in the future. The documentation was received on June 24, 1996.

8.  Audit Finding and Recommendation:
No written permission for changes to budget. The DNR’s General Terms and Conditions section IIG requires prior written approval to transfer funds from a direct cost budget category. 10 CSR 80-9.050(3)(B) requires quarterly reports to contain details of progress, problems, budget adjustments, and other information necessary for proper evaluation of the progress of the project.

The District Board moved funds from the equipment to incentives category without getting written permission from the DNR or including this information in the quarterly reports. Verbal permission was requested. At that time the district was verbally advised to resubmit an amended grant application for approval. This application has not been submitted.

The grant application for project 93023 also contained errors. Funds were incorrectly listed as match funds. The district coordinator stated that these funds were in the wrong place and that there were no matching funds for this project.

The project deadline for project 95077 was extended from June 30, 1996, to October 31, 1996. Neither this extension nor the problems leading to this extension were included in the quarterly report submitted to the SWMP.

The auditor recommended the district submit an amended application outlining all budget changes and that the district obtain prior written approval for all future budget category transfers. It was also recommended that the district include all required information in quarterly reports submitted to the SWMP.

District Response:
The district stated that quarterly reports are being written to address this finding. The district also commits to obtaining SWMP written approval prior to any future budget category transfers.

Final Resolution:
The DNR considers this matter resolved with the understanding that the SWMP receives the quarterly reports. In addition, the district shall request written approval for all future budget category transfers of 10 percent or greater. The district shall identify budget changes and grant extensions in quarterly reports. The quarterly reports were submitted on June 24, 1996.

9.  Audit Finding and Recommendation:
Proper documentation not required. Proper documentation was not required from the subgrantee for projects 93022, 93023, and 95075. Project 93022 received incomplete documentation from the subgrantees. Invoices have been submitted as proof of payment. To assure payment has been made, the subgrantee should be required to submit canceled checks that support the invoice. The auditor recommended the district require adequate documentation from subgrantees. If proper documentation is not provided by the district, the questioned project should be disallowed and the district should remit back to the program the sum of $12,560.62.

District Response:
The district stated that it will provide any additional documentation for projects that can be obtained from the subgrantees for these projects. The district will submit this additional documentation or an explanation as to why the documentation is not available.

Final Resolution:
The DNR considers the matter of $12,560.62 in questioned costs resolved with the understanding that the district submits to the SWMP additional documentation that adequately support expenditure of funds for projects questioned. In the future, the district shall include language in the subgrantee FAA specifying the documentation required for reimbursement, and shall provide to the SWMP written procedures for insuring future documentation is sufficient before paying subgrantee expenses. This documentation was received on June 24, 1996.

10.  Audit Finding and Recommendation:
Agreement not followed. In project 93022 the district has an agreement with the City of Aurora. This agreement stated that the recycling center funded by this project would remain open at least four (4) hours a week. The sign on the site lists that the center is open only three (3) hours each month. District funds should be used for projects which are beneficial to the district’s goals. Three hours a month is well short of the required time the center is to be open and does not allow adequate accessibility for beneficial use of the recycling center. The auditor recommended the district require the City of Aurora recycling station to be open for the number of hours described in their agreement.

District Response:
The district stated that the City of Aurora’s recycling center project was complete and that all funding had been expended on the project. The district acknowledged that the hours posted on the center were less than what the agreement stated. However, the center is still operating and the district views this as a continued benefit to the district. The district stated that it would send a letter to the City of Aurora encouraging the city to increase hours of operation.

Final Resolution:
The DNR considers this matter resolved with the understanding that a copy of the letter to the City of Aurora be submitted to SWMP. The district shall also submit to SWMP a final report on this project. The letter and report were received on June 24, 1996.

11.  Audit Finding and Recommendation:
Bins incorrectly marked. In project 93022 used bins were donated to the district. These bins contain signs that indicate proceeds from the bin are donated to the United Way. Since proceeds are not donated to the United Way, the bins should not be labeled as such. The auditor recommended the district cover or remove the signs indicating proceeds are donated to the United Way.

District Response:
The district stated that it would send a letter to each Drop Off Center funded under project 93022 that has an incorrectly marked bin. The letter will advise the project to mark out or paint over the wording "the proceeds from the bin are donated to the United Way." A visit to each Drop-off Center will be made by district personnel to ensure that the wording has been removed. A future quarterly report will update and/or close out this Finding.

Final Resolution:
The DNR considers this matter resolved with the understanding that the SWMP receives a copy of the letters to the Drop-Off Centers as well as a quarterly report that describes the action taken by the subgrantees. This documentation was received on June 24, 1996.

12.  Audit Finding and Recommendation:
Project started before start date. 10 CSR 80-9.050(1)(E)2.B lists costs incurred before the project start date as ineligible costs. A feasibility study for the City of Branson was performed by a subcontractor. The contract between Branson and the subcontractor was signed on February 14, 1995. The project was approved by the district in the February 21, 1995, board meeting. This project was in process when the application was submitted to the district and thus should not have been funded. The auditor recommended the district not approve district grant projects which are already in progress.

District Response:
The district stated that it intends not to fund any future projects that have either started work or expended funds prior to district approval. It is now part of the District Grant Application package and the District Grant Workshop that no work or expenditure of funds is to commence without a "Notification to Start" from the district.

Final Resolution:
The DNR considers this matter resolved with the understanding that the district submits to SWMP a copy of its District Grant Application package highlighting the area indicating that no work or expenditure of funds is to commence without a "Notification to Start" from the district. The district shall also provide to the SWMP and the subgrantee a request to amend the questioned project allowing the prior costs incurred. Documentation was received on June 24, 1996.

13.  Audit Finding and Recommendation:
Conflict of interest. Project number 95075 was a feasibility study for a composting facility in Branson, Missouri. The project manager is the director of the City of Branson Health Department. The project manager is also a district board member who voted on the approval of the project. This constitutes a conflict of interest compromising the integrity of the voting process and is not allowed per 10 CSR 80-9.050(1)(C)4. The total amount of the grant, $12,199 should be disallowed because of the conflict of interest. The auditor recommended the district remit $12,199 to the SWMP.

District Response:
The district stated that its current policy for board members that have submitted District Grant applications is to have the board member leave the meeting while any discussion and/or vote is being taken by the board on that application. In this way no appearance of a conflict of interest is present. In addressing the apparent conflict of interest with project 95075, the board minutes for that meeting indicated that the board member was present at the meeting. However, the board member is willing to submit an affidavit that she did not vote on approval of her own application at this meeting.

Final Resolution:
The DNR will consider the matter of $12,199.00 in questioned costs resolved with the understanding that the district will provide the SWMP a signed and notarized affidavit from the affected board member stating that she did not vote on the project. The district shall also provide the SWMP with a copy of their policy requiring affected board members to leave the room when their projects are being discussed/voted on. Future meeting minutes should also specify that this actually occurs when there is a potential conflict of interest. Documentation was received on June 24, 1996.

14.  Audit Finding and Recommendation:
Incorrect allocation. Project 95074 was a district plan implementation project which was considered a district-wide grant. This project was for $45,485 which was 62.4 percent of the total district grant allocation for the Fiscal Year 1995 grant cycle. 10 CSR 80-9.050(1)(D)2 only allows "Up to 60 percent of the grant money available to a district may be allocated for district-wide projects and at least 40 percent shall be allocated for projects of cities and counties within the district. The auditor recommended the district allocate at least 40 percent of district grant funds each year to projects of cities and counties within the district.

District Response:
The district stated that it was aware that the allocation of grant funds for the 1995 grant cycle was 60 percent for the district portion and 40 percent for the city/county portion. The district used the allocation plus the rollover amount from previous years to calculate the percentages for the 1995 cycle. Using the total amount available for the 1995 District Grant year, the percentages are less than the 60 percent and 40 percent required by law. The auditor used the total received by the district on the 1995 Award Letter to calculate the percentages. According to the district, this gives an inaccurate percentage and does not take into account the amount that was available but not asked for in the district's account with DNR.

Final Resolution:
The DNR considers this matter resolved because the district has a defensible method of calculating compliance with these percentages and because the discrepancy, if calculated as the auditor advised, is very small. However, the department will re-evaluate appropriate methods for calculating compliance with the specifics and will provide additional guidance to all districts on this issue.

Review of Administration

1.  Audit Finding and Recommendation:
Interest income not reported. Interest income was earned by the district in their savings account. The district did not report their interest income and the program did not deduct the interest income from outlays as required by the DNR’s General Terms and Conditions II.C. The amount of interest income earned for Fiscal Years (FY) 1993, 1994, and 1995 totaled $7,566.16. The auditor recommended the program reduce FY96 payments to the district by $7,566.16 for interest earned in FY93, FY94, and FY95 or the district obtain permission from the program to use this interest income. It was also recommended that the district obtain permission from the program to use future interest income earned by the district.

Final Resolution:
The district was not required to take any actions. The SWMP has made changes to the Special Terms and Conditions to allow districts to utilize income generated from interest earned on district grant agreement funds. The expenditure of income earned from such interest must comply with 10 CSR 80-9.050 Solid Waste Management Fund (SWMF) – District Grants. Interest earned from grant monies may be used to fund costs as long as they are reimbursable under the provisions established in the SWMF – District Grants rule and directly benefit the district grant program.

2.  Audit Finding and Recommendation:
Inadequate documentation to support match. The district used donated board member hours as match for the administrative grants in FY94 and FY95. Projected hours were used to calculate this match. Actual hours were never documented and submitted to prove the match. Because adequate documentation was not submitted for either of these years, the total grant amount $20,000 each year should be disallowed. The auditor recommended the district provide the appropriate documentation for the match funds or remit $40,000 to the SWMP for administrative grant funds which were not adequately matched.

District Response:
The district stated that it will review the Administrative Grants for FY94 and FY95 and submit revised documentation changing the projected hours used to calculate board members donated time to actual hours. The district agrees to use actual hours and either the actual dollar per hour value or an average of the board members dollar per hour value, in the case where the board member does not work or is retired, to calculate future Administrative Grant match.

Final Resolution:
The DNR considers the matter of $40,000 in questioned costs resolved with the understanding that the district provides to the SWMP documentation for all hours designated as match to prove the entire match amount. Attached to the documentation should be the names of individuals donating their time, along with actual hours donated and the rate of hourly pay. The documentation should be signed by all affected board members. If the actual amount is less than previously agreed to, the district will forfeit a proportionate amount in future awards. The documentation was received on June 24, 1996.

3.  Audit Finding and Recommendation:
No approval for district publications. The district did not submit a draft copy of a brochure for approval by the DNR as required by the DNR’s General Terms and Conditions. This should be done for each publication to ensure the DNR has proper oversight of publications from the district. The auditor recommended the district submit draft copies of all publications to the DNR for approval prior to publication.

District Response:
No response required.

Final Resolution:
The Special Terms and Conditions of the grant amended the General Terms and Conditions to allow the district to approve draft copies of publications used in the subgrants.

4.  Audit Finding and Recommendation:
Inadequate monitoring of district inventory. The district has no formal policy regarding equipment control. An inventory of equipment purchased with grant funds has never been performed. An inventory list should be maintained and a physical inventory should be taken every two years. Since there are no property records and no inventory taken, there is no assurance that property purchased with district funds is being used to support program activity. The auditor recommended the district maintain a list of all inventory purchased with grant funds and that the district complete a physical inventory every two years.

District Response:
The district stated that the auditors never asked for a copy of the District Inventory of Equipment. The district indicated that all equipment purchased by the district for use by district personnel is logged and tagged by the District Secretary. The only piece of equipment purchased by district funds outside of the office is a chipper for the City of Lockwood. This item will be added to the District Inventory of Equipment. The district stated that it will develop an inventory control procedure incorporating current regulations regarding proper control and disposition of equipment and to conduct an inventory of equipment every two years.

Final Resolution:
The DNR will consider the matter of the district creating and maintaining equipment management procedures and inventory for all equipment purchased with district grant funds resolved, with the understanding that the district provides a copy of its physical inventory of all equipment purchased after the FY93 funding cycle. The district provided the documentation on June 24, 1996.