Government of the District of
Columbia
Office of the Inspector General
Cash Verification of the Metropolitan Police Department’s Main
Imprest Fund, IF-FA-39
E. Barrett Prettyman, Jr., Inspector General
OIG Report No. 9820-16
November 13, 1998
1. INTRODUCTION AND PURPOSE
II. BACKGROUND
III. SCOPE AND METHODOLOGY
IV. SUMMARY AND CONCLUSION
V. FINDINGS AND RECOMMENDATIONS
Finance and Budget Division
Prior Audit Recommendations Not
Implemented
Recommendations
Inadequate Documentation From An Element's
Commander Or Director
Recommendations
PD 152 Sub-vouchers
Not Canceled After Reimbursement
Recommendation
FBD Confidential
Fund-Account Book Not Maintained
Recommendation
MPD Imprest Fund Losses Not
Reported To The OIG
Recommendation
Criminal Investigations
Division-Homicide Unit
Cash Count Of CID-Homicide's
Confidential Fund
Inadequate Records Documenting
Fund Activity
Recommendation
Inadequate
Training Of Confidential Imprest Fund Custodians
Recommendations
Fourth District
Cash Count Of The Confidential Fund
Recommendation
Transactions Not Recorded In A
Timely Manner
Recommendations
Inadequate Controls Over The
Payment Process
Recommendations
Non-Compliance With Approval
Requirements
Recommendation
General Comments
Attachment
The District of Columbia (D.C.) Office of the Inspector General (OIG) has conducted an
unannounced cash verification and audit on selected departments (hereafter called
elements) of the D.C. Metropolitan Police Department (MPD) regarding the impress funds
assigned from the MPD's Main Cash Advance Fund (MPD impress fund). The MPD impress fund,
which is accounted for as impress fund IF-FA 39, is authorized at $125,000 and is
administered by the MPD's Finance and Budget Division.
The purpose of the cash verification was to determine whether MPD impress funds
assigned to the elements were maintained in accordance with the provisions of Mayor's
Memorandum 82-29, Imprest Fund Procedures, D.C. Municipal Regulations (DCMR), Title 27,
Section 1815. Imprest Funds, and MPD General Order 304.5 Confidential Fund Procedures.
Specifically, the audit was to determine whether the funds were expended for intended
purposes, the expenditures were adequately approved and documented, and controls are in
place and operating effectively to safeguard the funds.
Back to top of page
The mission of the MPD is to provide law enforcement and other police services to
people living, working, and visiting in D.C.; and to improve the quality of life in the
city. The MPD is a community-oriented police organization that works with individual
neighborhoods in identifying resources available to solve crime and maintain order while
assisting with the resolution of problems affecting the community's quality of life.
To accomplish this mission, the MPD was provided a $ 100,000 impress fund for use in
the prevention and detection of crime. In March 1997, the MPD requested and received an
increase in the fund to $125,000. The MPD used the impress fund to establish fourteen
confidential and impress funds at the various elements within the MPD for varying amounts.
The commanders/ directors of an element are required to sign cash advance sub-vouchers for
the amount of MPD impress funds allocated to their respective elements. An officer from
each element is designated by the Commander/Director to perform the duties of the
confidential or impress fund custodian. The confidential funds are used by the elements to
pay informants (special employees) and witnesses, and to fund undercover operations for
the prevention and detection of crime.
The MPD's Finance and Budget Division (FBD) is responsible for the proper distribution
of and accounting for the $ 125,000 MPD impress fund. The FBD maintains $38,100 of the
fund to reimburse the various elements' confidential and impress fund expenditures. The
FBD submits its reimbursement requests to the District's Deputy Chief Financial Officer
(CFO), Office of Financial Operations and Systems (OFOS) for funding.
In addition to the $38,100 fund, the FBD also maintains an additional $25,000 which was
previously maintained by the Criminal Investigation Division (CID)-Backup Fund custodian.
These additional monies were returned to the FBD custodian by the Federal Bureau of
Investigations (FBI) after it seized the $25,000 for evidence upon the arrest of the
CID-Backup fund custodian The funds were transferred to the FBD custodian on May 22. 1998.
The CID-Backup Fund was used to reimburse the various elements' confidential funds when
the FBD office was closed.
The FBD custodian accounts for the $125,000 by including cash on hand, the
disbursements issued to replenish the various element fund expenditures, and the cash
advance sub-voucher receipts supporting the amount of funds issued to the elements.
Records at the OFOS list the FBD Accounting Officer and one alternate cashier as the
individuals responsible for the $125,000 MPD impress fund.
Mayor's Memorandum 82-29, dated May 18, 1982, provides the basic guidelines for the
establishment, use, reimbursement, safeguarding, and auditing of the impress funds.
Section III of the Memorandum requires that use of the impress fund shall be restricted to
the purpose for which it was established. The authority to modify or to abolish all
impress funds is vested with the Mayor, who has delegated this authority to the OFOS. The
OFOS is also responsible for approving and assigning identification numbers to impress
funds.
MPD's General Order Series 304.5 provides the basic guidelines for the establishment of
procedures for controlling and disbursing funds allocated to the Confidential Fund. Part I
of the Order outlines the responsibilities and procedures for special assignment
personnel, and Part II outlines the responsibilities and procedures for supervisory and
command personnel.
Back to top of page
Audit procedures employed during the cash verification included performing unannounced
cash counts of the FBD, CID-Homicide Division. the Fourth District, and records maintained
to account for the respective fund balances and the MPD impress fund balance of $ 125,000.
We examined fund expenditures for adequate support, and for proper approval and compliance
with MPD General Order 304.5 and impress fund regulations. We reviewed internal controls
over the safeguarding of MPD impress funds and examined prior audit and inspection reports
to determine if prior issues were resolved. We held discussions with the MPD and FBD
officials and other employees who currently handle the confidential funds and the FBD
impress fund. In addition, we examined related MPD impress fund records maintained at the
OFOS.
The cash verifications were conducted on March 11 (CID), March 17 (Fourth District),
and April 6 (FBD), 1998. Records related to the CID-Homicide and FBD funds were examined
for the period October 1, 1995 through December 31. 1997, and from October 1, 1996 through
September 30, 1997 for the Fourth District fund.
With respect to the CID-Homicide confidential fund of $1,000, we were unable to verify
that all expenditures and reimbursements to the fund were adequately recorded and
accounted for by the fund's former custodian. The PD Forms 128 (PD 128 control sheets)
used to record all expenses and reimbursements were not available for our examination.
The audit was conducted in accordance with Generally Accepted Government Auditing
standards.
Back to top of page
Our cash verification disclosed that control and accountability over the impress funds
were inadequate. We noted that documentation acknowledging the receipt and responsibility
for thirteen (13) sub-funds, totaling $61,900, was not updated. As a result, we could not
determine who was responsible for each of the thirteen sub-funds, and the amount in each.
The FBD safe also contained $8,453.06 of an unidentified fund that was previously
reported on in the OIG audit report, OIG No. 9512-07 dated February 8, 1995. The prior IG
report recommended that the Chief of Police deposit the unidentified funds to the General
Fund if the funds were no longer needed. This recommendation was not implemented.
In addition to the cash count, our audit of the FBD records revealed that the FBD:
- did not cancel either the original PD 152 sub-vouchers prior to submitting the items for
reimbursement and did not return the duplicate copy to the element's custodian when paid;
- stopped recording MPD impress fund activity to the Confidential Fund-Account Book; and
- did not report impress fund losses to the OIG.
Our cash count and analysis of the CID-Homicide safe contents indicated that the
confidential fund's $1,000 was, for the most part, accounted for. There was an expenditure
of $100 that was not documented as issued from the fund, and there was an outstanding
advance for $120. Further, our discussions with the current CID-Homicide custodian
indicated that training, MPD policies and procedures, and impress fund regulations
regarding the control and maintenance of the confidential fund were not provided.
Because of the unavailability of documents, we were unable to verify that all
expenditures and reimbursements were accounted for and properly recorded. The PD
128-control sheets were missing for most of the audit period that we reviewed. This lack
of documentation prevented us from determining if the former CID-Homicide custodian
properly recorded expenditures for advances issued and recorded reimbursements from the
FBD to replenish the confidential fund.
The cash count of the Fourth District confidential fund revealed a $5,030 balance with
an unexplained $30 overage. Our audit of transactions noted that the confidential fund
custodian did not timely record transactions to the PD 128-control sheet and, therefore,
did not know the balance in the account at any given time. We determined that controls
over the approval, issuance and recording of advances and expenditures for payments were
inadequate and did not comply with MPD General Order 304.5.
We have provided recommendations for the Chief of Police to take the proper actions to
address these conditions.
Back to top of page
Our audit disclosed that an unidentified sum of $8,453.06, which was previously
reported in an OIG audit, still remained idle in the FBD safe. The FBD custodian informed
us that the unidentified funds were not deposited due to an ongoing investigation by the
MPD's Office of Professional Responsibility (previously Internal Affairs) for possible
wrongdoing. He also stated that FBD officials wanted to wait until after the results of
the MPD investigation before removing the funds from the safe. As a result, the
unidentified funds have remained idle for over three years.
The $8,453.06 unidentified fund was previously reported by the OIG in its report, OIG
No. 9512-07, dated February 8, 1995. In that report, it was noted that the funds were from
a special $20,000 fund established in 1976 by a miscellaneous voucher to fund a special
narcotics investigation. However, there was no determination regarding the source of the
fund, the purpose of the fund, or what the funds were expended for. In the prior report,
the OIG recommended that "...the Chief of Police take administrative action to:
- determine the source, purpose and original amount of the $8,453.06 in unidentified
funds;
- ensure that the total amount of unidentified funds is accounted for and take appropriate
action if there are funds unaccounted for; and,
- deposit the unidentified fund to the District's General Fund if the purpose for which
the funds were to be used no longer exists...."
To date, we have not been informed in regard to the current status or results of the
MPD investigation.
We recommended that the Chief of Police take the following necessary action.
- Deposit immediately the $8,453.06 to the District's General Fund.
- Provide our Office with the results or the status of the investigation regarding the
$8,453.06 unidentified funds.
Agency Response:
The agency concurred with the finding and recommendations. (See
attachment).
- The funds were deposited in the District's General Fund on October 22, 1998.
- As soon as the agent concludes the investigation, the OIG will be informed of the
outcome
Back to top of page.
Our audit of the FBD documents disclosed that the FBD custodian did not have signed
statements from the elements' current commanders or directors acknowledging their receipt
and responsibility for $61,900 of the $125,000 impress fund. The FBD custodian noted that
he did not maintain updated cash advance receipts from each element's commander or
director because his Office is not notified when changes occur in commanders, directors,
or the delegated custodian. Without obtaining a signed cash advance sub-voucher from the
current commander or director of an element, acknowledging his/her receipt and
responsibility for the funds, the FBD custodian, the impress custodian of record, is
technically liable for any fund shortages of the $125,000 impress fund. MPD General Order
304.5, Part II, A. provides: "All cash advances shall be recorded by obtaining a
receipt signed by the element commander or director."
The FBD custodian only had cash advance sub-vouchers that were initially issued as far
back as March 1990 to account for the $61,900 of funds assigned to the various elements of
the MPD. The individuals who signed the cash advance sub-vouchers were not the persons
currently authorized to sign and issue confidential funds for the elements.
We recommended that the Chief of Police take the following necessary measures.
- Have the current commanders and directors comply with General Order 304.5 and sign cash
advance receipt vouchers acknowledging receipt of the funds and responsibility for the
internal control of the funds assigned.
- Require that the commanders and directors notify the FBD regarding changes in the
delegated fund custodian of their elements.
- Ensure that cash advance receipt vouchers for the commanders and directors are updated
when changes occur at an element and are forwarded to the FBD custodian to account for the
total MPD impress fund.
- Require a reconciliation of the elements' fund when a commander, director, or the
designated custodian changes, holding the commander or director and the delegated
custodian responsible for any fund shortages.
Agency Response:
The agency concurred with the finding and recommendations. (See
attachment.)
The agency has developed a training course for managing the Confidential Fund. A draft
copy of the training outline is included in the attachment.
Back to top of page
The PD 152 sub-vouchers submitted by the various elements to the FBD for reimbursement
were not canceled in accordance with MPD General Order 304.5 when the FBD custodian
prepared the items for reimbursement from the OFOS. Our discussions with the FBD custodian
indicated that this was not done because the custodian and other FBD officials were not
aware of this requirement. Failure to cancel PD 152 sub-vouchers could result in an
original PD 152 sub-voucher being resubmitted for reimbursement, either in error or
intentionally.
MPD General Order 304.5, Part I, E. 2. b. provides: "...After PD Form 152 has
been included on a voucher for reimbursement, the word "REIMBURSED " shall be
stamped in large letters across its face.... "
The PD 152 sub-vouchers are used by the various MPD elements to document the
expenditures from the confidential fund without divulging confidential information. The
confidential fund custodians submit their PD 152 sub-vouchers to the FBD custodian for
reimbursement to the fund. We examined approximately 175 reimbursement vouchers and 575 PD
152 sub-vouchers submitted by all elements to determine if the FBD followed documented
procedures. None of the sub-vouchers issued during the audit period was marked as
canceled. In addition, we also found that the FBD custodian did not cancel the duplicate
PD 152 sub-vouchers that were returned to the element upon payment. Although not a
requirement of General Order 304.5, basic accounting controls would recommend that the
receipt, submitted for reimbursement, be "canceled" with some form of validation
to prevent its reuse.
We recommended that the Chief of Police take the necessary measures to ensure that an
FBD official, other than the FBD custodian, cancel all PD Form 152 sub-vouchers submitted
for reimbursement in accordance with General Order 304.5.
Agency Response:
The agency concurred with the finding and recommendation. (See
attachment.)
All PD 152s will be canceled immediately after reimbursement, effective November 3,
1998.
Back to top of page
Our audit disclosed that the FBD custodian did not maintain the Confidential
Fund-Account Book (Account Book) as required by General Order 304.5 noted below. The FBD
custodian noted that he stopped recording to the Account Book due to staff shortages and
prioritizing responsibilities. Although the Account Book was maintained through April 30,
1997, the FBD custodian noted that it was not kept current. Failure to adhere to
established policies and procedures weakens the control functions for which the policies
and procedures were established.
General Order 304.5, Part I, E. 1 .a.provides: "A Confidential Fund-Account
Book shall be maintained in the Office of Finance and Management consisting of three
sections. The first section (Obligation) shall be a list of PD Form 152s in numerical
sequence.... The second section ...shall show the exact amount of PD Form 152s paid....
The third section...shall be a list of reimbursement vouchers in numerical sequence giving
the date of the voucher, control number of PD Form 152s covered total amount of the
voucher, and balance of appropriation "
We recommended that the Chief of Police take the necessary measures to ensure that the
FBD maintains the Confidential Fund-Account Book in accordance with the requirements of
General Order 304.5.
Agency Response:
The agency concurred with the finding and recommendation. (See
attachment.)
The Confidential Fund-Account Book was re-established on October 1, 1998.
Back to top of page
The FBD did not report MPD impress fund losses to the OIG in accordance with required
regulations. Failure to notify the OIG of any fund shortage within twenty-four hours
violates Mayor's Memorandum 82-29, "Impress Fund Procedures," and impairs the
audit trail with the passage of time. The FBD custodian noted that he was unaware of the
requirement to notify the OIG of any fund losses. He stated that any missing funds from an
element are reported to the Chief of Police's office for action. Consequently, we could
not determine when the shortage occurred because the FBD did not follow the established
procedures for handling fund shortage.
Section XII of Mayor's Memorandum 82-29 provides: "...ln the event of loss,
theft, or occurrence of an unexplained shortage to the Imprest Fund, a report citing the
appropriate circumstance, must be filed with the Office of the Inspector General (OIG) as
well as the Metropolitan Police Department (MPD). Where applicable. the MPD should
be called immediately while the report to the OIG should be filed within 24 hours of the
occurrence...."
During examination of the FBD reimbursement requests and PD 152 sub-vouchers, we noted
that a $5,000 reimbursement was issued to the Sixth District. The reimbursement
documentation noted that it was to replenish the confidential fund back to a $5,000 fund.
Documentation further noted that the element experienced a theft of the initial $5.000
confidential fund and a special fund for $1,000 was issued to the Sixth District for use.
We were unable to obtain the results or the current status of the investigation regarding
the loss of funds.
We recommended that the Chief of Police take the necessary measures to ensure that all
impress and/or confidential fund shortages or losses of funds are reported to the OIG in
accordance with Section XII of Mayor's Memorandum 82-29 "Impress Fund
Procedures."
Agency Response:
The agency concurred with the finding and recommendation. (See
attachment.)
Losses will be reported to the OIG as soon as the Office of the CFO knows of such
losses through its own the reviews and audits.
Back to top of page
Our cash count on March 1 1, 1998 of the CID-Homicide confidential fund indicated that
the $1,000 confidential fund was accounted for. Although the initial cash count indicated
a fund overage of $2,600, further analysis of the safe documents disclosed that funds in
the amount of $2,600 were previously reimbursed. Also, there was an expenditure of $100
that was not documented as issued from the fund, and there was an outstanding advance for
$120.
We were unable to determine why the documents for previously reimbursed items remained
in the CID-Homicide safe. In our opinion, this occurred because the former custodian of
the CID-Homicide confidential fund did not keep the PD 128-control sheets current. The PD
128-control sheets were unavailable for examination. The following lists the payment dates
and Chief of Police assigned control voucher numbers (COP voucher numbers) of items in the
safe reported as unreimbursed but were reimbursed:
| Date Prepared |
Date Paid |
COP Voucher Number |
PD 152* |
PD 127* |
| 07/13/97 |
07/17/97 |
233 |
970.00 |
|
| 97/13/97 |
07/17/97 |
234 |
740.00 |
|
| 09/05/97 |
09/09/97 |
276 |
590.00 |
|
| 09/05/97 |
10/09/97 |
002 |
|
100.00 |
| 09/05/97 |
10/09/97 |
002 |
|
200.00 |
| Total |
$2,300.00 |
$300.00 |
* These are forms submitted by investigators and the reimbursement payments from the
FBD.
We disclosed this problem to the new custodian and gave verbal instructions as to how
the documents should be filed given that they had already been reimbursed.
Back to top of page
Our audit noted that the records accounting for activity of the CID-Homicide fund were
not adequately maintained. We found that the PD 128-control sheets used to list the PD 127
expenditures submitted by its investigators and the reimbursement payments from the FBD
were not available for 17 of the 27 months that we examined. The current fund custodian
and other CID officials stated that the records presented were the only records that were
maintained in the safe when the current custodian took over in November 1997. Attempts to
locate the records were unsuccessful. The failure of the fund custodians to maintain
records adequately precludes an efficient reconciliation of the fund and eliminates the
audit trail that would aid in detection of errors.
MPD General Order 304.5, Part I, C. 5. b. (2) provides "...Part 2 shall contain
a separate PD 128 Log for each fiscal seal year. The PD 128 Log for the current fiscal
seal year may be kept in a three- ring note book. The PD 128 Log shall be balanced at the
end of each month...."
Recommendation
We recommended that the Chief of Police take the following necessary measures.
- Reconcile periodically and examine all confidential and impress funds issued to the
various elements to ensure that the funds are accounted for.
- Ensure that proper records are maintained in accordance with General Order 304.5.
Agency Response:
The agency concurred with the finding and recommendations. (See
attachment.)
The Office of the CFO will conduct periodic reviews to reconcile documents and cash.
and to ensure that proper records are maintained in compliance with General Order 304.5.
This requirement is now a part of the workload of the general accounting staff in the
Office of the CFO, MPD.
Back to top of page
During our cash count and examination, the current CID-Homicide custodian noted that
she was unaware of the procedures governing the confidential fund. The custodian stated
that training was not provided. Also, she was not provided a copy of the MPD General Order
304.5, Confidential Fund Procedures, or of Mayor's Memorandum 82-29, Imprest Fund
Procedures, for guidance. Assigning confidential funds to a custodian without providing
the basic policies and procedures for operating the fund may create confusion in
administering the fund, which ultimately could result in errors.
Recommendations
We recommended that the Chief of Police take the following necessary measures.
- Ensure that all confidential and impress fund custodians are adequately trained and are
provided copies of the Mayor's Memorandum 82-29 and MPD General Order 304.5 regulations.
- Ensure that the required cash advance sub-voucher is prepared and signed when there is a
change in an element's commander/director, and that the fund is reconciled when a change
in fund custodian occurs. The outgoing custodian is responsible for any shortages noted in
the fund on transition of the fund custodian.
Agency Response:
The agency concurred with the finding and recornrnendations. (See
attachment.)
- The Office of the CFO has developed a training curriculum to certify all custodians.
Part of the training package includes distributing Mayor's Memorandum 82-29 and General
Order 304.5.
- The CFO has established new procedures to audit and reconcile the impress funds when a
change in fund custodian occurs, holding the outgoing custodian responsible for shortages.
Back to top of page
The cash count of the Fourth District confidential fund set up as $5,000 disclosed a
total of $5,030. This included both cash and sub-vouchers, making a $30 unexplained
overage in the fund. The current fund custodian noted that the overage was in the fund
when he took over the account on January 21, 1998, although the PD 128-control sheet
disclosed that the fund balance was $5,002.
The OIG recommended that the Chief of Police instruct the Fourth District confidential
fund custodian to submit the $30 overage to the FBD custodian for deposit in the
District's General Fund.
Agency Response:
The overage of $30.00 was deposited in the General Fund on November 3, 1998.
Back to top of page
Confidential fund transactions were not recorded to the PD 128-control sheet in a
timely manner. The PD 128-control sheet was, last updated in January 1998 and therefore
was not available for examination for transactions after January 1998. The fund custodian
noted that he did not maintain the monthly summary sheet due to his excessive workload.
However, our review of the monthly summary sheets for Fiscal Year 1997 indicated
approximately 200 transactions, about 17 transactions per month.
A current PD 128-control sheet provides the daily balance of the confidential fund. It
lists the daily expense and reimbursement transactions of the confidential fund and
summarizes the monthly totals. It is similar to a check book register for a checking
account and is a useful reconciliation tool. Failure to maintain an up-to-date PD
128-control sheet allows for errors to go undetected.
MPD General Order 304.5 Part I, C. 2. a., provides, "...the official in charge
of the Confidential Fund shall, on a daily basis, enter the member's expenditures on PD
Form 129 and on PD Form 128 (Monthly Summary of Expenditures and Reimbursements). " Part
I, C. 4. c. provides: "The official in charge of the Confidential Fund shall enter
the amount of the reimbursement on the PD Form 128 and place the cash in the safe. "
The OIG recommended that the Chief of Police take the following necessary action.
- Institute a monthly reconciliation and review process to ascertain that all confidential
fund custodians are complying with the requirements of MPD General Order 304.5 with
respect to recording expenditures and reimbursements daily to the PD 128-control sheet.
- Ensure that the officers' qualifications are taken into consideration before designation
as custodians so as to make certain that the officers can perform their assigned
responsibilities while maintaining the funds as required.
Agency Response:
The agency concurred with the findings and recommendations. (See
attachment.)
- The CFO has been charged with the responsibility to conduct monthly reconciliations and
a review process to ensure that all confidential fund custodians are complying with the
MPD General Order 304.5 with respect to recording expenditures and reimbursements daily to
the PD 128 control sheet.
- The Officers' qualifications and workload will be taken into consideration when
commanders/directors recommend custodians to the Chief of Police. Maintaining and
administering the impress fund will be a high priority for all custodians.
Back to top of page
We noted that controls over transactions involving Special Employees (S.E.s) were not
implemented to ensure compliance with MPD General Order 304.5. We noted that S.E.
identification numbers were not always recorded on the PD 153 Form, which is signed by the
S.E. upon receiving payment, and which is used to support the expenditure of advanced
confidential funds. Also, there were no controls in place to ensure advance approval of
payment to S.E.s when the amount exceeded $100. Failure to implement adequate controls
could easily result in abuse and misuse of the confidential funds.
We examined approximately 153 payments (approximately $16,140) made to S.E.s during the
audit period. About 85% of the payments (approximately $13,225) did not indicate the S.E.
number on the PD Form 153, which was signed by the S.E. Also, there were 45 payments
(approximately $9,818) made in excess of $ 100 that were made without advance approval.
MPD General Order 304.5 Part II, TRACKING VICE INVESTIGATIONS, Confidential Funds
(revised July 9, 1987) provides: "Directives must be set forth And policies
emphasized to supplement the contents of this General Order at the element levels. The
following procedures will facilitate accountability of confidential funds at the various
element levels:
"... 6. In every instance that a Special Employee (SE) receives
advanced MPDC Funds whether for the purchase of evidence and/or for information and
assistance provided the Special Employee must sign a completed PD 153, Receipt for
Expended Advanced MPD Funds. Every PD 153 must be reviewed and signed by a sergeant and a
Vice Lieutenant or Branch Commander of the respective branch prior [to; the submission for
processing Special Employees shall be documented within element vice files and have
assigned a S.E. number prior to their receipt of any Confidential Funds. The Special
Employee Number shall be noted on the PD 153 along with the Investigation File Number.
"
"Any payment to a Special Employee for information and/or
assistance provided which exceeds $100.00, shall require advance approval by the Vice
Lieutenant, or Branch Commander, or Watch Commander."
We recommended that the Chief of Police take action to ensure the
following:
- MPD officials supervise and inspect the maintenance of the confidential funds on a
regular basis and in a timely manner. There should be a training/educational process to
instruct the custodians about the established procedures and to guide them in their
performance of those procedures.
- Appropriate action is taken to establish guidelines for all elements with confidential
funds to ensure compliance with established approval requirements.
Agency Response:
The agency concurred with the findings and recommendations. (See
attachment.)
- The CFO will conduct regular reconciliations and reviews of the confidential fund and
report findings to the immediate supervisor through the chain of command. The CFO has
developed a training curriculum to certify all custodians. Additional reviews and audits
will be conducted to ensure that procedures will be followed as outlined in General Order
304.5.
- The Executive Assistant Chief will establish guidelines to ensure that the proper
approval Process is followed for payments made to Special Employees.
Back to top of page
Our audit noted that expenditures exceeding $300 did not have the
required review and level of approval when submitted for reimbursement. PD Form 127
Confidential Expenditure Sheet (PD 127 expenditure), used to support expenditures for the
cash advance, does not provide a specific place for the required level of approval for
expenditures exceeding $300. Also, the commander did not establish procedures to ensure
that MPD General Order 304.5 was followed. Failure to ensure compliance with established
approval requirements could result in improper payment of confidential funds.
MPD General Order 304.5, Confidential Funds (revised July 9, 1987)
provides:
"...2. Disbursements to personnel or expenditures exceeding
$300.00 for any one (1) transaction must be approved by the vice lieutenant or, in his
absence. the watch commander.
We recommended that the Chief of Police take appropriate action to
revise the layout of forms PD 127, Confidential Expenditure Sheet, and PD 153, Receipt for
Expended Advanced MPD Funds, to provide for indication of review and approval in
accordance with MPD General Order 304.5.
Agency Response:
The agency concurred with the finding and recommendation. (See attachment.)
The commanders/directors will attend the custodians training to provide
updates on the approval process.
Back to top of page
PD 127, 152 and 153 Forms Should Be Pre-Numbered
The MPD should have the PD forms 127, 152, and 153 (used to document
and account for individual confidential fund receipts, expenditures, and reimbursements)
pre-numbered to facilitate control and accountability. Because a normal receipt or invoice
does not support confidential fund expenditures, the use of a pre-numbered voucher will
provide added information and an audit trail for tracing expenditures to supporting
documentation.
Validate Reimbursement Documents To Prevent Reuse
There are currently no procedures in place for destroying or mutilating
the reimbursement documents supporting the PD 152-reimbursement request submitted to the
FBD unit to replenish the confidential fund. Because the supporting documentation is not
submitted with the reimbursement request to the FBD custodian, the unit commander or
director should validate the supporting documents when approving the PD 152 sub-voucher
for reimbursement. With the use of pre-numbered PD 152 sub-vouchers. the commander or
director could validate the supporting documents (PD 127s and PD 153s) simply by noting on
the forms. "Reimbursed by PD 152 No. xxxxx dated xxlxx/xx."
Agency Response:
The agency concurred with our comments. (See
attachment.)
MPD will investigate prenumbering the PD-127 and 152 forms. |
