The internal controls over the equipment inventory systems in the U.S. House
of Representatives (House) can be improved to provide greater assurance that the
House's assets are identified, accounted for, secured, and valued uniformly on a
House-wide basis. The House has not implemented adequate controls to ensure that
its system of inventories is in accordance with sound management principles.
Specifically, (1) equipment is inventoried in numerous systems which are
inconsistent with each other and contain incomplete information; (2) certain
policies and procedures necessary to ensure a reliable inventory system either
are not implemented or are not consistently applied; (3) inventory records are
not timely reviewed and updated; (4) the integrity and reliability of management
controls for the computer-based Office Equipment System are inadequate; (5)
segregation of duties is not always implemented; and (6) physical security is
inadequate to safeguard certain assets. We have also addressed an additional
matter in our report that, while not as critical as the findings themselves,
warrants management's attention and action to correct. As a result, the House's
ability to identify and account for all its assets and to provide effective,
timely, and accurate input to the financial statements used by management is
diminished.
RECOMMENDATIONS
We recommend that the Chief Administrative Officer (CAO) develop a proposal,
for approval by the Committee on House Oversight (CHO), to implement an
inventory tracking process for equipment which contains all information
necessary to adequately identify and account for all assets House-wide. We also
recommend that the CAO submit a proposal to the CHO for approval to develop
House-wide, written policies and procedures which ensure the accountability of
all assets. We also recommend that the CAO periodically review and adjust the
inventory records where appropriate; limit access authority to supervisory
transactions to authorized personnel only; implement effective segregation of
duties; and ensure that assets are properly secured at all times.
MANAGEMENT RESPONSE
On May 28, 1997, the Acting CAO concurred with the 6 findings and all
21 recommendations (see Appendix). According to the response, the Acting CAO is
implementing, or plans to implement, a variety of corrective actions to improve
the accountability and uniformity of equipment inventory systems. Some examples
of current and planned actions include:
(1) proposing a policy, for approval by the CHO, that all purchases of
equipment and furniture go through one of the following entities, Office Systems
Management (OSM), Furniture Resource Center (FRC), or House Information
Resources (HIR), to ensure that all assets of the House are accounted for in one
of these inventory systems (purchases outside these inventory systems would not
be honored by the Office of Finance); (2) submitting a proposal to the CHO to
determine the requirements and cost-benefits of consolidating the inventories of
the House; (3) proposing a policy, for approval by the CHO, to conduct
inventories of equipment owned by the House to reconcile the assets to the
inventory on a timely basis, investigating and adjusting any differences as
appropriate; (4) proposing a policy, for approval by the CHO, which provides for
the establishment of depreciation rates and capitalization thresholds and
authorization to write-off obsolete or lost assets; (5) ensuring that policies
and procedures are clearly disseminated and consistently and uniformly applied
by House management; (6) reviewing and resolving the "not billed/not paid"
report and using it to supplement the accounts payable tracking system; (7)
proposing a policy to address the discrepancies between payments and purchase
order amounts, and addressing the validity of current OSM procedures used to
process vendor invoices; (8) having OSM work with HIR personnel to address
security issues and instituting a policy requiring documentation of changes made
by HIR, including appropriate testing; (9) performing independent reconciliation
of OSM physical inventories; and (10) ensuring that assets are secured at all
times.
OFFICE OF INSPECTOR GENERAL COMMENTS
The CAO's current and planned actions on all of the findings are responsive
to the issues we identified and, when fully implemented, should satisfy the
intent of the recommendations.
I. INTRODUCTION
Background
Office Systems Management (OSM) is the entity primarily responsible for the
purchase and subsequent tracking of office equipment and computers (herein known
collectively as equipment) for the U.S. House of Representatives (House). OSM is
also responsible for purchasing and tracking District office furnishings.
Furniture Resource Center (FRC) purchases and accounts for the furnishings of
Members' Washington, D.C. offices as well as of other House entities, such as
the Page School. For further discussion about FRC's inventory responsibilities,
see the Office of Inspector General's report entitled, Internal Controls Over
House Furnishings Need Improvement, 96-CAO-08, dated September 10,
1996. House Information Resources (HIR), the House's internal computing and
telecommunications facility, purchases computers and telecommunications
equipment for its own use, in addition to purchasing telecommunications
equipment for the House, and maintains its own computer and telecommunications
equipment inventory.
One of OSM's duties is to process equipment requests from Members,
Committees, and House offices. OSM purchases the equipment through its operating
or program budget and then charges the requester's account for the amount of the
purchase. Typically, OSM offers two types of payment plans for equipment
purchases, the one time acquisition plan and the three-year plan. With the
latter plan, OSM charges the account each month for 1/36th of the total purchase
price. The account under either plan is also charged monthly for any associated
maintenance.
Management officials in the Office of the Chief Administrative Officer (CAO)
stated that the House has three main inventory systems, OSM, HIR, and FRC but is
aware that other House entities do purchase and track equipment unique to their
operations themselves. For instance, the Attending Physician, House Recording
Studio (HRS), and Photography Studio purchase hospital beds, microphones, and
cameras, respectively, from their own funding instead of having OSM make these
purchases. However, these entities purchase personal computers, fax machines,
and other general equipment through OSM.
In total, we have identified nine House entities which perform some type of
purchasing function and maintain, in whole or in part, their own inventory
listings. In addition, some may have their equipment listed in OSM or elsewhere.
Besides OSM, HIR, FRC, Attending Physician, HRS, and the Photography Studio, the
other entities are: Sergeant at Arms (SAA), Office of Supply Services, and
Office of the Clerk.
Objective, Scope, And Methodology
Our objective was to evaluate the effectiveness of internal controls over
OSM's equipment inventory system. During the survey phase, we identified other
entities, as noted above, which procured items without going through OSM,
therefore, we included these entities on a limited basis in our audit. We
identified and evaluated the internal control structure of OSM through
(1) interviews with personnel in OSM, HIR, Office of Finance, Attending
Physician, HRS, Photography Studio, Page School, and SAA; (2) reviews of
pertinent policies and procedures; (3) observations of operations; (4) reviews
of management reports; and (5) an evaluation of the flow of transactions. Our
audit was limited to OSM's various locations, and to HIR, the Office of Finance,
Attending Physician, HRS, Photography Studio, Page School, and SAA and covers
Calendar Year 1995. We also conducted physical inventories of the
telecommunications equipment assigned to two House offices and the House-owned,
used pagers. In addition, we identified and reviewed subsequent events related
to accounts payable, records updating, and bulk inventory. The audit was
conducted in accordance with Government Auditing Standards issued by the
Comptroller General of the United States and included such tests as we
considered necessary under the circumstances.
According to a June 30, 1995 organization chart, published by the Office of
the CAO, Office Systems Management's (OSM) name was changed to Property Asset
Management (PAM). However, PAM's current Assistant Chief informed us that PAM
was renamed OSM effective October 1, 1996. To avoid any confusion associated
with having to footnote or explain why we use PAM instead of OSM and vice versa,
we will use the reference OSM consistently throughout this report. In addition,
for purposes of this report, the term House office includes Leadership and other
House organizations, unless otherwise noted.
Internal Controls
We reviewed internal controls related to the operation of the House's
inventory system. We found numerous internal control weaknesses which are
discussed below in Section II, "Findings and Recommendations."
Prior Audit Coverage
- Audit of Financial Statements for the 15-Month Period Ended December 31,
1994 (Report No. 95-HOC-22, dated July 18, 1995). This audit reviewed the
internal control structure of the House for the 15-months ended December 31,
1994, and made recommendations for its improvement in several areas, including
accountability of equipment.
- Audit of Financial Statements for the Year Ended December 31, 1995
(Report No. 96-HOC-05, dated July 30, 1996). This audit assessed the status of
those recommendations and determined that only a few had been implemented and
that the majority were still pending action by the House.
- House Office Systems Management-Fiscal Year Ended 9/30/93 and Three
Months Ended 9/30/92 (GAO/AIMD-95-78, dated March 30, 1995). The General
Accounting Office (GAO) audited OSM's Statements of Cash Receipts and
Disbursements for fiscal year 1993 and the three months ended September 30, 1992
and found that the statements were reliable in all material respects and that
internal controls in effect on September 30, 1993, reasonably ensured that
losses, noncompliance with laws or regulations, or misstatements affecting the
financial statements would be prevented or detected and there was no material
noncompliance with laws and regulations. GAO reported that OSM corrected the
internal control weakness identified in its previous report (House Office
Systems Management-Three Months Ended 9/30/92 and Fiscal Years Ended 6/30/92 and
6/30/91, GAO/AIMD-94-18 dated January 14, 1994). In that report, GAO
noted that OSM did not have procedures to prevent or detect all unauthorized
changes to its automated data files. GAO did not make any recommendations in
the March 30, 1995 audit report.
II. FINDINGS AND
RECOMMENDATIONS
Finding A: Numerous Inventory Systems Exist Which Are
Inconsistent
With Each Other And Contain Incomplete Information
No centralized equipment inventory control system exists to acquire, receive,
record, value, and account for all equipment purchased and leased by and for the
House. Instead, numerous systems exist, some of which
are inconsistent with each other and do not contain the same type of
information, such as cost or depreciation. Because of the decentralized nature
of House inventory management, we do not know if we have identified all existing
House inventory systems or whether all House assets are recorded in a system.
Separate inventory systems exist in some cases because of the specialized nature
of the equipment. Some entities did not value their inventories because they did
not consider cost to be a relevant factor in inventory accountability. Inventory
systems that collectively do not reflect the sum total of all assets under House
control, that are not consistent with each other, and do not provide complete
information, may improperly indicate a lack of assets, misstate the financial
statements, and lessen accountability of the assets.
Discussion
OSM managers stated that OSM served as the House's central purchasing office
for equipment and district office furnishings. Although they were aware of two
other inventory systems of the House, HIR and FRC, they indicated they were not
aware that other systems, such as the one maintained by the Attending Physician,
existed "outside" of these systems. However, subsequent discussions with CAO
management during our March 12, 1997 exit conference indicated they consider
OSM, FRC, and HIR the only bona fide inventory systems of the House.
Nonetheless, they did acknowledge that, based on information developed in our
audit, these three systems do not contain all assets owned by the House.
FRC's principal responsibility is to furnish the Washington, D.C. offices,
however, it also acts as a conduit for purchasing
non-furniture items for Members, Committees, and House offices, such as
subscriptions for a Member and a public address system for the Page School. FRC
management said they purchased these items, even though they were not furniture,
at the request of the Member and House office. The latter items are not included
in FRC's inventory system, according to FRC personnel, because the expenditures
are not made through its program budget. Rather, they are purchased with the
Member's or House office's funds. These items may or may not be tracked by OSM;
it depends on whether OSM is notified about them. In contrast, OSM includes
items it purchases for Members and other House offices in its inventory system.
These purchases are made from OSM's program budget and then charged back to the
Member, Committee, or House office.
In the past, OSM has been able to track inventory because it processed
purchases on behalf of Members, Committees, and House offices. OSM entered the
purchase information into its inventory system and assigned a control number to
each item. The Members' Congressional Handbook, the regulations governing
the Member's Representational Allowance issued by the Committee on House
Oversight (CHO), effective September 1, 1995, states that Members must contact
OSM before purchasing any equipment. These regulations gave OSM a means for
capturing and entering new purchases into its inventory system, thus providing
accountability. The regulations in the Committees' Congressional
Handbook, also issued by the CHO and effective on June 1,
1996, indicate that Committees should not purchase equipment without consulting
OSM and should refer to the User's Guide to Purchasing Equipment, Software,
and Related Services. With the termination of the Approved Equipment List, Members,
Committees, and House offices may purchase equipment themselves--from any
source. However, unless they notify OSM about these purchases, the information
may not be entered into OSM's inventory system.
Inventory system problems
OSM conducts an annual inventory count of the equipment that it has purchased
for each Member, Committee, and House office. During the audit period, the CAO
distributed inventory listings of equipment to
Members, Committees, and House offices and asked for confirmation as to their
accuracy. Items which were purchased "outside" OSM (e.g., equipment purchased
through FRC or items purchased under different funding sources) will not be
included in these listings unless OSM has been notified about these items and
subsequently entered them into the inventory system. Based on interviews with
House personnel, we understand offices do not always inform OSM that the
listings exclude certain items. Therefore, all listings may not contain a
complete inventory count nor would OSM necessarily know this.
Other inventory systems contribute to the problem
Besides the inventory systems maintained by OSM, FRC, and HIR, other House
offices have their own systems. Personnel we interviewed at HRS, the
Communications and Client Services Groups within HIR, the Page School and the
Attending Physician, indicate that these groups maintain their own systems and
do not always report their assets to OSM.
HRS has certain equipment that was not included in OSM's inventory system.
Because HRS had not purchased this equipment through OSM, it initially was not
tracked by OSM. Instead, certain production equipment, such as televisions and
audio equipment, were recorded in a separate customized computer system residing
on HIR's mainframe. Until September 30, 1995, HRS had statutory authority to
purchase production equipment from its revolving fund. Consequently, it did not
have to submit equipment procurement requests through OSM. (Pursuant to the
Legislative Branch Appropriations Act for Fiscal Year 1996, Public Law 104-53,
funds for HRS "shall be available only to the extent provided in the
appropriation Acts" effective October 1, 1995.) According to HRS personnel, as
of November 1, 1995, HRS stopped using its revolving fund and began purchasing
all studio production, House floor coverage production, and administrative
office equipment through OSM; therefore, these items are now tracked by OSM.
(Based on our review of the HRS detailed inventory equipment listing dated May
1996, we did not see any equipment with a purchase date of October 1, 1995
through October 31, 1995.)
- HIR telecommunications inventory system
We also identified a fragmented, telecommunications equipment inventory
information system within HIR. HIR's Communications Group is responsible for the
House's Washington, D.C. telephone and network infrastructure while the Client
Services Group provides the phone system and service to both Washington, D.C.
and district offices. This information is recorded in several different
inventory systems or databases maintained by different subgroups within HIR. For
example, the Communications Group's Network Configuration Management subgroup
maintains several different inventories for the network infrastructure. The four
network configuration managers within this subgroup maintain their own inventory
databases, which are all designed differently. Each of these systems was
generally designed for a specific use, but contain useful data that can be
utilized for inventory purposes. However, these systems do not contain all the
necessary information required in a typical inventory system. Nevertheless, the
Group has the capability to track network equipment through its current network
management system (NMS) but these capabilities have not
yet been utilized. That is, through configuring all equipment connected to the
House network, the NMS (i.e., NetView for Advanced Interactive Executive (AIX)) can detect the location and type of equipment
attached to the network. Therefore, it is our view that the Group should explore
the possibility of consolidating the various databases maintained by HIR's
subgroups and integrating the consolidated database with the House NMS.
In contrast, Communications Group's Management of Network
Income, Expense, and Services (MONIES) System
tracks telecommunications voice equipment and lines for the House and district
offices and provides the overall telecommunications utilization and service
expense information for generating the monthly charge-backs to Members and other
House offices. However, the inventory does not contain all voice equipment, such
as the PBX switch equipment, located at the Longworth Building. Presently, the
switch information is contained in the PBX telephone system. According to HIR,
they were not aware of a need to maintain an all-inclusive voice
telecommunications inventory for decision-making or asset valuation purposes,
but can easily add the switch information to the MONIES System. Therefore, we
believe that HIR should centralize all voice telecommunications equipment and
lines in the MONIES System by adding equipment, such as PBX switch equipment,
currently not in the MONIES System.
The Page School maintains its own internal listing of equipment, only some of
which is included in OSM's inventory. The Attending Physician purchases medical
equipment "outside" of OSM. Based on discussions with SAA personnel, SAA's
computers and office equipment are recorded in OSM's inventory system. However,
before the House discontinued the Approved Equipment List, SAA ordered equipment
not on this list through FRC. Since then, SAA personnel indicated they place all
orders for equipment, such as radios and communications equipment, through
OSM.
Telecommunications inventory system information
In late July 1996, we conducted limited tests of the accuracy of the
telecommunications equipment, lines, and voice mail links used for charging
expenses back to Member, Committee, and other House offices and concluded that
opportunities exist for improving HIR's voice telecommunications inventory
system information. We obtained the CAO's July 1996 telecommunications equipment
and services list generated from HIR's MONIES System, which was sent to Member
and other House offices for review and verification. We then performed physical
inventories of telecommunications equipment, lines, and software at two House
offices (i.e., the office suites of the CHO and the Office of Inspector General
(OIG)). The results of our physical inventory were compared to the CAO's list to
determine the accuracy of the information in the MONIES system, in which charge
backs are based. In the CHO offices, we found that HIR was billing the CHO for
18 voice/data lines, which we could not locate. On the other hand, the CHO was
using three voice lines and eight voice mail boxes, which were not recorded in
the inventory system and, therefore, were not charged to the office. In the
OIG's offices, we found that HIR was billing the OIG for fourteen telephone
lines, three voice mail boxes, one soft line, two 36-button digital sets, and
eight 10-button analog sets, which we could not locate. However, we did identify
one telephone line, two voice mail boxes, one analog speaker phone, and twenty
two 10-button analog sets that were in use and needed to be added to the
inventory.
We discussed these discrepancies with the HIR Telecommunications (a subgroup
within the Client Services Group) manager and found reasonable explanations for
some of these discrepancies. From HIR management, we learned that the three
voice lines and eight voice mail boxes, which were not recorded in the inventory
system and were not charged to the CHO, may have been listed and billed to the
individual Member offices instead of the CHO. HIR indicated that billing a
Member office, instead of a Committee, is not an uncommon practice. They further
surmised that some of the other discrepancies may have been attributed to the
OIG's major office move in early June 1996. HIR further stated that some of the
telephone line numbers we could not locate were data lines that, in fact,
existed in the OIG offices, but were not in the room locations indicated on the
inventory list. HIR was able to provide us the locations of the data lines by
using the jack location numbers identified on the office floor plan. Each data
line in House offices are marked only with a jack location number. This makes it
difficult for office personnel to locate a data line without the jack
number--especially when the room numbers are incorrect. Had the inventory list
also listed the jack location numbers, the offices could have been able to match
the telephone number with the jack location. According to the Telecommunications
manager, the jack location information was removed from the inventory list
because users found this information confusing. However, the fact remains that
while some of these discrepancies could be explained, others could not because
some records had not been kept beyond the retention period and, therefore, were
not readily available at the time of our inquiry. This raises doubt as to
the accuracy and reliability of the inventory information. In addition, a
Member's account may be charged when, in fact, the Committee's account should be
charged. Although the Telecommunications manager admitted that the inventory
information in the MONIES System may not be accurate, she maintained that
discrepancies of this volume in any one office do not normally occur.
In conclusion, the House's verification and certification process is
ineffective for ensuring the accuracy, completeness, and reliability of the
MONIES System inventory information. Consequently, the inventory information in
MONIES may be considered unreliable because of admitted inaccuracies.
Furthermore, since this information is used to charge telecommunications
expenses and services back to Member and other House offices, charge backs to
these offices may also be erroneous.
Inconsistent information
The inventory systems we identified do not contain the same, basic
information such as cost, depreciation, acquisition value, or equipment location
that one would expect to find in an inventory system. For example, OSM's system
values its inventory while HIR's system does not record the cost of an asset or
its subsequent depreciation. Under generally accepted accounting principles
(GAAP), an asset is depreciated in order to allocate its cost to the periods in
which services are received from the asset. Failure to depreciate assets may
impact the financial statements, depending on materiality. Consequently, those inventory systems which do not depreciate
assets make it difficult for management to prepare financial statements
according to GAAP. (For further discussion on depreciation refer to
Finding B.) The HIR inventory system also does not utilize its ability to track
equipment by location. FRC's system may, but does not always, record the cost of
an asset such as raw materials and it does not include any additional value
derived from processing the item. The usefulness of an inventory system is only
as good as the information it provides. From an internal controls perspective,
safeguarding assets, and assuring accountability is essential. Providing room
locations, control and serial numbers, and equipment descriptions enables
management to readily track and identify assets.
The disjointed nature of the inventory systems and the inconsistent reporting
and updating of information perpetuate incomplete, inconsistent, and inaccurate
records. Consequently, management cannot be assured that it has accurate and
meaningful information for decision-making purposes. Furthermore, the House
cannot be assured that equipment and services are sufficiently protected from
waste, theft, unauthorized use, and mismanagement. Allowing information to exist
in multiple inventory systems increases the likelihood that information is
inconsistently recorded, incomplete, and inaccurate. Best practices recognize
the use of a centralized inventory system within an organization to avoid
duplication of information (and the errors associated with duplicate entries)
and inconsistencies, and reduce multiple system maintenance support. This
approach allows one individual or group to be responsible for the timely
updating and maintenance of the inventory system and its contents. However,
because entities are unique, there may be circumstances where more than one
inventory system is necessary. The House should identify and review all its
systems--both formal and informal--and determine the optimum number of systems
it needs to track and control its assets.
Recommendation:
We recommend that the Chief Administrative Officer develop a proposal, for
approval by the Committee on House Oversight, to:
1. Implement an inventory tracking process for House equipment which contains
all information necessary to:
(a) prepare financial statements in accordance with GAAP.
(b) adequately identify and account for all assets on a House-wide basis.
2. Appoint a qualified project manager to oversee and report on the progress
of the consolidation effort described below.
3. Comply with recommendation one above by implementing an SDLC approach to
maximize inventory consolidation by:
(a) identifying all inventory systems (the systems discussed in this report
may not be all-inclusive);
(b) conducting a modified requirements analysis of those inventory systems
at the data element level to identify any changes needed to optimize
compatibility with one another;
(c) determining which inventory systems can be readily consolidated; that
would serve as temporary subsidiary feeder systems; and those, if any, that must
stand-alone; reviewing available off-the-shelf software and/or contacting other
government entities to determine availability of consolidated inventory systems.
4. Periodically evaluate inventory consolidation efforts to determine if, and
at what point, optimum consolidation has been achieved.
Management Response
The Acting CAO agreed with the recommendations in this finding. Specifically,
he agreed to implement an inventory tracking system for House equipment that
contains sufficient information to satisfy GAAP requirements and adequately
identify and account for all assets on a House-wide basis. He also agreed to
propose a policy to the CHO to require that all purchases of equipment and
furniture go through one of the three appropriate inventory systems (OSM, HIR,
and FRC). Purchases outside these inventories would not be honored by the Office
of Finance. The Acting CAO will also develop and submit a proposal to the CHO to
identify all assets of the House and place such information in one of the three
inventories as appropriate. These proposals will be submitted by August 31, 1997
and will include a request for adequate staffing and resources to accomplish
them. The Acting CAO also indicated a project manager needed to oversee this
inventory effort will be appointed within 30 days after the CHO approves the
proposal cited above. In addition, the Acting CAO will submit a proposal to the
CHO to determine the requirements and cost-benefits of consolidating the
inventories of the House. This proposal will include a request to compare the
costs-benefits of this endeavor with other priorities of the House. This
proposal will also be submitted by August 31, 1997. A timetable for evaluating
consolidation efforts to determine optimum consolidation will be included in the
above proposals.
Office of Inspector General Comments
The CAO's planned actions are responsive to the issues we identified and,
when fully implemented, should fully satisfy the intent of the recommendations.
Finding B: Formal Policies And Procedures Do Not Exist Or Are Not
Followed Consistently
The House does not have, or does not consistently enforce, policies and
procedures necessary to ensure an adequate, accountable inventory record across
the various inventory systems that currently exist. House managers we spoke to
did not specifically state why certain policies and procedures have not been
formulated although they explained that time constraints and inadequate staffing
have contributed to the lack of enforcement of certain established policies.
(However, it should be noted that at the time of our audit no requests for
additional staffing had been made to the CHO.) Formal policies and
procedures help clearly communicate detailed guidance for handling
specific transactions and the importance of this guidance. Without them,
processes may be handled inconsistently or improperly. Without consistent
application of established policies and procedures, overall compliance by House
entities may diminish and operational efficiency may suffer.
Discussion
The Executive Branch has issued numerous directives in the form of Federal
guidance aimed at improving Federal financial management, including internal
controls. Although the House is not required to adhere to Executive Branch
directives, its intent to modernize and integrate its financial management
system would benefit from adherence to generally accepted management practices
as expressed, for example, in circulars issued by Office of Management and
Budget (OMB). OMB Circular No. A-123, entitled Management Accountability and
Control (revised June 21, 1995), provides guidance on improving the
accountability and effectiveness of Federal programs and operations by
establishing, assessing, correcting, and reporting on controls by management. An
organization's internal control structure consists of management's policies,
procedures, and commitment to reasonably prevent material errors and
irregularities from occurring or going undetected. In addition, internal
controls are the overall plan of an organization and the methods employed to:
(1) safeguard assets; (2) ensure the reliability of accounting data; (3) promote
efficient operations; and (4) ensure compliance with established policies.
Although some House inventory systems have implemented certain internal
controls, no formal, documented House-wide policy has been
developed or implemented requiring that: (1) detailed property and equipment
records be checked periodically by physical inventory by personnel knowledgeable
about such equipment; (2) differences between the records and physical counts be
reconciled and the records be adjusted to reflect the differences; (3)
supporting documentation, including proper authorization of transactions, be
maintained; (4) assets be depreciated; (5) policies for the write-off of
obsolete and missing equipment be established; (6) regulations prescribing the
freezing of accounts be uniformly enforced; (7) transactions be approved by the
proper party; and (8) receipts be timely deposited.
Formal policies and procedures not developed
- Periodic House-wide physical inventory
OSM performs an annual spring inventory of House equipment via
"tearsheets"--a listing of equipment assigned to each office. However, it does
not conduct a physical inventory of the Member's Washington, D.C. office unless
the Member moves to another office location, leaves the House, or requests help
with confirming the accuracy of the inventory list. In addition, OSM directs the
General Services Administration (GSA) to perform physical inventories of
District offices. The Member is ultimately responsible for the accuracy of his
or her inventory listing, and confirms it by signing the listing and returning
it to OSM, with any discrepancies noted. According to the Member's
Congressional Handbook, Members are personally liable for missing, damaged,
or stolen equipment assigned to their office equipment account and, in the event
an item has been identified as missing, damaged, or stolen must notify the CAO,
in writing, of the circumstances. However, during the audit period, the
House had no policy in place requiring a periodic physical inventory of its
equipment by persons knowledgeable about such equipment. Good business practices
mandate conducting a periodic physical inventory by appropriate personnel to
ensure that the records accurately reflect the assets on hand. In addition,
differences between the records and physical counts should be reconciled
on a timely basis and the records adjusted to reflect the differences. An
inaccurate count of assets may misstate the financial statements or affect House
operations. For example, if a Member requests a piece of used equipment from
House inventory (House inventory contains items available for reissue) and OSM
does not have an accurate record of such items, OSM may incorrectly deny the
request because it does not know what is available or OSM may purchase new
equipment for a Member unnecessarily.
Pursuant to the Member's Congressional Handbook, OSM sends out
"tearsheets" each spring to all offices, requesting they verify the accuracy of
the listing. OSM management informed us that they question returned tearsheets
which are not "marked-up" because they believe some offices merely sign off the
tearsheet without performing a physical inventory. However, if a questioned
office indicates they did a physical inventory, OSM does not independently
confirm this. Regardless of who is ultimately responsible for the equipment,
failure to conduct a complete physical inventory undermines the effectiveness of
this control. Furthermore, the tearsheets may include items such as the internal
parts of a computer, e.g., the motherboard, memory chips, controller cards, etc.
Unless office personnel are familiar with these items, it may be difficult for
them to determine whether the listed component part is correct. Discussions with
OSM personnel indicate that maintenance vendors (or employees) may exchange or
remove equipment parts that are inventoried, such as internal parts, keyboards,
monitors, etc., without OSM receiving proper documentation to adjust the
inventory records. (Typically, OSM discovers this when the computer is returned
to the House due to obsolescence or a Member relocates or leaves office.)
However, the office staff should have been aware of alterations done to their
equipment because vendors should not have keys to access Members offices;
therefore, office staff should have been present and the change reported to OSM.
HIR also issues an inventory tearsheet for verification with the monthly
invoices that are sent to Members, Committees, and House offices. As we delved
further into the voice telecommunications inventory validation procedures at the
House, we found the process to be ineffective for assuring the accuracy and
completeness of voice telecommunications equipment and lines. Annually, a
system-wide inventory is conducted to verify both the voice and data equipment.
As part of this annual process, HIR sends out an inventory printout to each
Member, Committee, and other House office for verification and certification.
HIR informed us that because the Member is ultimately responsible for the
accuracy of his or her equipment inventory, the Member's office should be
responsible for performing the inventory. However, HIR has always offered their
assistance with the inventory. Nevertheless, according to HIR, they only
received a few requests for assistance from offices. When a Member leaves the
House, HIR is responsible for conducting a physical inventory and preparing the
office for the new incoming Member and staff.
As with OSM, the annual verification process is not always reliable because
HIR relies on Member, Committee, and other House office staff for verification
of inventory, yet these individuals often are not technically trained to the
level that is needed to differentiate one type of equipment from another. They
also may not be familiar with the types of test to employ to locate a voice or
data line. Further, they may not have the time to physically verify counts,
therefore, they are performing spot checks or no checks at all and returning the
inventory as accurate, if at all. In fact, the Telecommunications manager
estimated the response rate to the 1996 physical inventory request to be about
30 percent. This adversely affects the accuracy of inventory reconciliation. HIR
agreed the responsibility for conducting physical inventories of voice
telecommunications equipment and lines should be assigned to HIR.
Further, as of October 1996, not all spring 1995 tearsheets had been returned
to OSM. (According to a letter written by the CAO and dated June 2, 1995,
the tearsheets should have been returned within 30 days of receipt of the
letter.) In addition, OSM staff are still reconciling tearsheet differences to
their records. This significant time lag weakens the accuracy of the inventory
and lessens the ability of recovering assets which may be lost or
misappropriated. OSM management noted that the process is so
time-consuming because each component part is listed on the tearsheet,
regardless of cost and must be accounted for. For example, a computer processing
unit may have five component parts. These are tracked separately by OSM and must
be reconciled to OSM's records if a Member or organization notes discrepancies
in the tearsheet. In addition, only two staff are assigned to do 1,500-1,600
reconciliations in addition to their other duties, such as office moves. It is
not practicable to rely on two staff to reconcile the tearsheets on a timely
basis. From an internal control standpoint, assets must be adequately
safeguarded. However, a reasonable dollar threshold should be established to
avoid the expense and free up staff resources required to track items of nominal
value. Items should also be inventoried by operable unit, not component part as
this would expedite the reconciliation process.
- Reconciliation of physical counts to records
There is no uniform House-wide policy requiring a reconciliation of the
inventory physical count to the records. Although some offices do reconcile
their assets to their records, it is not on a timely basis, as illustrated in
the OSM example above. However, OSM cannot do timely reconciliations if they do
not receive all the necessary information, i.e., the tearsheets, within the
prescribed deadline. House organizations, such as HRS, reconcile their recorded
production assets with the physical equipment at least once a year. However,
this reconciliation process is done by the staff when they have time, i.e., it
is not done on a scheduled basis. Management said that they do try to update the
records when they have available time. A routine, timely, independent
reconciliation process helps assure that (1) assets are adequately safeguarded
because missing items would be identified and the cause of these losses could be
corrected; (2) inventory records are accurate; and (3) management's policies and
procedures are being followed.
- Supporting documentation is not maintained by the appropriate office
During the audit period, OSM's Correspondence division, which processes
equipment requests from Members and other House offices, did not retain signed,
approved copies of purchase orders. Instead, it submitted the approved purchase
orders to the vendors. Failure to keep proper supporting documentation may
result in unsubstantiated claims if a dispute arises between the vendor and a
Member, Committee, or House office. In addition, signed copies would prove
invaluable in those instances where purchase orders are lost in transit.
To ensure that the House receives and is billed for only authorized goods,
the Accounts Payable division compares the installation and issue tickets (i.e.,
receiving reports) and the vendor's invoice with the purchase order. Because the
division's copy of the purchase order does not show the authorizing signatures,
Accounts Payable cannot confirm that the equipment on the purchase order was
properly authorized. According to OSM management, the Office of
Procurement and Purchasing maintains an authorized copy of the purchase
order. However, to improve this control, Accounts Payable should receive a copy
of the signed purchase order from Correspondence, where it is generated. In
addition, the authorizing officials should review the supporting documents when
signing the voucher, and Accounts Payable should keep a copy of the signed
voucher for its files to show that the disbursement to the vendor is authorized.
The Office of Finance keeps a copy of the signed voucher, according to OSM
management; however, we believe Accounts Payable should maintain a copy for its
records.
Furthermore, since the voucher numbers are consecutively assigned by the
computer, Accounts Payable should periodically account for all voucher numbers
to ensure that they have been forwarded to the Office of Finance for payment.
Finally, to improve controls ensuring that transactions are properly
supported and authorized, policies should be clearly stated in writing and
systemically communicated to appropriate parties.
- Depreciation of equipment
We were unable to identify any established, uniform, House-wide policy
governing the depreciation of equipment. In addition, not all entities we
reviewed depreciated their equipment, and of those that did, management was
unsure, in certain instances, how the depreciation policy had been developed. To
comply with GAAP for financial statement purposes, entities must depreciate
their assets. In addition, one objective of an entity's internal controls is to
ensure the reliability of accounting data. This includes consistency of
accounting information within an organization. According to CAO personnel, the
House has adopted a depreciation policy; however, during the audit period, based
on our discussions with the various personnel who maintained inventory systems,
we were unable to identify any specific, uniform policy. Further, a review of
the notes to the financial statements for the 15-month period ended December 31,
1994 and for the year ended December 31, 1995, indicates that, "Accumulated
depreciation and depreciation expense have been estimated based on available
records." If a systematic depreciation policy had been in effect, an estimate of
depreciation expense based on available records would not have been required.
The depreciation expense should have been readily available from the inventory
systems. CAO personnel informed us that the contractor who compiled the
numbers for the House's 1995 financial statement audit had created a database
which provided the depreciation expense.
Because separate inventory systems still exist, the House should ensure that
any depreciation policy it adopts is implemented on a House-wide basis and is
disseminated to the entities maintaining inventory systems. The House
should refer to standard industry practices to determine the depreciation rates
for each asset class.
- Write-off of obsolete or missing equipment
According to OSM management, there is no formal policy prescribing when and
how to write off obsolete or missing equipment from inventory accounts. For
example, the Accounts Payable supervisor informed us that approximately 75
broken pagers intended for disposal through GSA have been missing since 1991.
However, seventy-five pagers represent an immaterial amount relative to the
House's overall assets and illustrates the point that there should be a
threshold for writing off missing or obsolete equipment. (For further discussion
of adjusting the inventory records see Finding C.) In addition, when an item is
reported as missing by a Member, Committee, or other House office, we were told
it is entered into a "missing items" account and is never transferred to a
"deletions" account. Unless OSM plans to actively pursue these missing
items, a policy should be established to review this account for unusual items
or activity and purge it periodically. Further, a policy should be developed
authorizing OSM management to write-off equipment below a certain threshold
amount. This would save time on following-up and reporting on items with a
nominal value.
- Timely deposit of surplus sales receipts
During our review of surplus sales, we noted that OSM remitted checks
untimely to the Finance Office. The sale of surplus goods was handled by the
Accounts Payable division until the sales were ended in 1995. The staff manned
the surplus sales room, answered questions, prepared the necessary paperwork for
the sale of the goods, and forwarded the receipts to the Finance Office. We
noted that between February and April 1995 Accounts Payable received 14 checks
and money orders totaling $1,425.00 which were not remitted to Finance until May
1995. Prudent management practices dictate timely deposits of checks to avoid
their misappropriation or loss. The current Assistant Chief is aware of this
situation and agreed that ideally, monies should be deposited timely. Because
the surplus sales program has been terminated according to the CAO's
Administrative Counsel, we have no recommendation to make; however, if it is
revived, a policy should be developed concerning timely deposits.
- Maintaining accountability
We were informed that OSM depreciates items it purchases in bulk, such as
pagers, televisions, and video cassette recorders only when they are assigned to
an office. To prevent the inventory system from depreciating these items, OSM
does not assign control/serial numbers to them until they are issued. However,
failure to assign control/serial numbers makes it more difficult to account for
these items when they are temporarily loaned out (bulk items may be loaned to an
office for a day or two without charge). Asset Management personnel informed us
that bulk purchases ended subsequent to our audit period and bulk inventory will
be excessed to GSA, therefore, we have not made any recommendations with regard
to bulk purchases.
Inconsistent or ineffective application of established policies and
procedures
If a tearsheet is not returned on a timely basis, OSM is supposed to freeze
the account, which means that it will not process any requests to purchase,
transfer, or remove equipment. In June 1995, the CAO sent out a letter
requesting Members to verify their inventories within 30 days of the date of the
letter, or their account would be suspended. OSM management generally allows 90
days (because Member activity is slower in the summer) before they suspend the
accounts. However, personnel indicated to us that there is no computerized flag
to prevent OSM staff from processing a request once an account is suspended.
Instead, staff are notified by electronic mail about the delinquent offices and
are supposed to stop processing transactions until the tearsheets are submitted.
To assess whether this is an effective means of control, we obtained a list of
accounts frozen since September 1995. We tested six accounts and determined that
purchase requests had been processed for each account during the period the
accounts were supposed to be frozen.
- OSM management also informed us that during the last Congressional
changeover various outgoing Committee tearsheets contained discrepancies between
the assets on hand and the recorded amount. According to OSM, the outgoing
chairpersons (who are ultimately responsible) refused to sign the tearsheets,
refuting their accuracy. The incoming chairpersons would not take responsibility
for these missing items. Consequently, OSM has not been able to account for all
items listed in the tearsheets. Since the changeover, OSM has been reconciling
the unsigned tearsheets to its inventory records and, as of October 1996, has
accounted for approximately 25 percent of the items. Instead of assigning these
items to the "missing" computerized inventory account and requesting the
chairperson reimburse the House, which is the normal procedure, OSM continues to
keep these items in the Committees' account or else has transferred them to a
"holding" account, because it does not know whom to hold responsible. OSM
management explained they did not want to designate these items as missing until
they were positive they could not be found. Typically, the responsible party is
held personally liable for a missing item and can appeal OSM's decision within
30 days to the CHO. In this particular instance, the policy regarding missing
items has not been enforced because no one has been held responsible almost two
years after the items were determined to be "missing." Furthermore, OSM has
expended its limited resources investigating these discrepancies. According to
the CAO's Administrative Counsel, the CHO is aware of the problems resulting
from the changeover
Additional matters
Bulk items have been purchased by OSM for use as "loaners," generally for a
period of a day or two; however, as of September 26, 1996, we identified a total
of ten televisions and three video cassette recorders loaned out between
December 1994 and February 1996 which have neither been returned nor been
charged to the requesters' accounts. During a review of the bulk orders account,
we discovered a Member and two House entities have borrowed items from the bulk
orders account without being charged by OSM. As a result, five televisions and a
video cassette recorder have been on loan, free of charge, for almost two years.
Asset Management personnel explained they previously felt they had to honor a
Member's request for a loaner even if the period extended for more than a few
days; however, they now obtain approval from OSM's current Assistant Chief.
Recommendations:
We recommend that the Chief Administrative Officer develop a proposal, for
approval by the Committee on House Oversight, to:
1. Establish House-wide written policies and procedures in accordance with
prudent business practices which ensure the accountability of all assets,
including:
(a) Conducting a timely physical inventory by technically qualified
personnel; notifying the responsible Member, Committee, or other House office of
missing, damaged, or stolen equipment; and inventorying items by operable unit;
(b) Reconciling the assets to the inventory records on a timely basis
and adjusting and investigating any differences where appropriate;
(c)
Requiring supporting documentation and proper authorization of transactions by
appropriate personnel;
(d) Establishing depreciation rates and
capitalization thresholds; and
(e) Identifying property to be written
off due to obsolescence or loss and authorizing appropriate personnel to
periodically write off the property.
2. Ensure that established policies and procedures are clearly disseminated,
and consistently and uniformly applied by House management.
Management Response
The Acting CAO concurred with the recommendations in this finding.
Specifically, he agreed to submit a proposal to the CHO by August 31, 1997, to
conduct inventories of House-owned equipment and to reconcile the assets to the
inventory and to adjust and investigate any differences as appropriate. The
proposal will include approval of additional staffing to accomplish the
additional workload. He also noted that in January 1997, OSM implemented a
policy of conducting physical inventories of Member
offices on at least a biannual basis. In
addition, the Acting CAO indicated that OSM's Correspondence division began
keeping copies of signed purchase orders in June 1996 and began to provide
copies to the Accounts Payable division in March 1997. Also in March 1997, the
Accounts Payable division began keeping copies of signed vouchers and will
ensure vouchers are timely forwarded to the Office of Finance. The Acting CAO
also agreed to submit a proposed capitalization policy to the CHO for approval
by June 30, 1997. The Acting CAO will review the inventory systems in HIR and
FRC and determine the best method for including a depreciation component in them
by June 30, 1997. The Acting CAO will also present a proposal to the CHO by July
30, 1997 for authorization to write off obsolete or lost assets.
Office of Inspector General Comments
The CAO's current and planned actions are responsive to the issues we
identified and, when fully implemented, should fully satisfy the intent of the
recommendations.
Finding C: Computerized Accounting Records Are Not Updated On A Timely
Basis
To Ensure Accuracy And Accountability Of Assets
Computerized accounting records are not always adjusted to reflect changes to
the equipment inventory accounts. OSM management agreed that these records
should be adjusted to accurately reflect the assets of the House but said time
constraints have limited their ability, or they do not have the authorization,
to do so. Failure to timely adjust these records may incorrectly state the
inventory on hand.
Discussion
House inventory, surplus sales, and GSA accounts
OSM is comprised of three divisions: Correspondence, Accounts Payable, and
Asset Management. Correspondence processes equipment transaction requests from
Members and other House offices; Accounts Payable pays the vendors; and Asset
Management removes, transfers, and verifies the installation of, and affixes
uniquely numbered control stickers on, equipment. At a Member's,
Committee's, and other House office's request, Asset Management removes unwanted
equipment from the office. Before any action is taken, the Correspondence
division must receive a signed equipment removal request. Once the request is
received, the Correspondence division generates a removal receipt and
forwards it to the Asset Management division. When the equipment is removed from
an office, the removal receipt is supposed to be signed by a responsible party
of that office. The supervisor of Asset Management examines the removed
equipment and, based on its condition and age, decides whether it should go into
House inventory, be sold as surplus, or sent to GSA for disposal. The supervisor
writes the decision on the removal receipt for data entry and tracking purposes.
Personnel in Asset Management enter this information into OSM's computerized
inventory system.
During the audit period, equipment which was not in use typically was handled
by OSM in one of four ways. It was (1) maintained in the House inventory account
awaiting reissue to a Member or office; (2) maintained in the surplus sales
account to be sold to Members and staff; (3) maintained in the GSA account to be
disposed of through GSA; or (4) traded to a vendor for credit or like equipment.
Surplus sales were managed by the Accounts Payable division of OSM but were
ended during the audit period. OSM management indicated that surplus sales
should not be resumed because the procedure is not cost beneficial and also
gives preferential treatment to Members and House staff. OSM management does not
know the last time a complete physical inventory of its storerooms was taken or
reconciled to recorded inventory. OSM attempted one in 1994 but stopped before
it was completed because the change in Congress necessitated reassigning staff
to help with office moves. OSM has not performed one since that time. Because
management did not know the last time a complete physical count of these
inventories has been done or been reconciled to OSM's records, we decided to
test the procedures applicable to House inventory, surplus sales, and GSA
items. To determine if items were being properly accounted for, we
analyzed the following computerized listings of inventory accounts: (1) the
surplus sales pending, approved, and sold accounts; (2) the GSA pending and
deletions accounts; and (3) House inventory account.
Surplus sales and GSA
During the period surplus sales were being held, the Asset Management
supervisor prepared a list of surplus sales items and their recommended sales
prices for approval by the CHA (now the CHO). Prior to approval, these items
were entered into the computerized account designated as "surplus sales
pending." Once the items were approved for sale by the CHO, they were recorded
as "surplus sales approved." (For further discussion on the approval process see
Finding B). When they were sold, the items were transferred to the "surplus sold
account." Although surplus sales were ended in 1995, we noted that there were
still items listed in both the pending and approved accounts as of August 23,
1996. OSM personnel explained that any items in the surplus sales approved
account which were on display in the salesroom and had not been sold after 90
days were sent to GSA. Consequently, we would expect to see these items excessed
to GSA. However, OSM management noted that as of April 1996, there were
approximately 300 items approved for sale as surplus which were still on hand
and were now obsolete. These items may not have been displayed in the salesroom
because of space constraints, and thus were not sold or shipped to GSA. Because
we were unable to determine which items had been displayed for sale but not
sold, we could not test the 90-day rule. Ideally, these items should have been
removed from the surplus sales approved account, entered into the GSA account,
and subsequently deleted when shipped to GSA. In addition, the items listed as
surplus sales pending should have been transferred to the approved account to be
sold, or else shipped to GSA prior to August 23, 1996. According to the CAO's
Administrative Counsel, the CHO decided to terminate the surplus sales program
in 1995. Therefore, we believe any existing items may have become obsolete by
now and their book values and the resultant recommended sales prices should have
decreased during this time period.
House inventory and GSA
OSM management indicated that the House inventory account still listed items
that had already been shipped to GSA and, therefore, were no longer considered
to be House property. Management explained that they tried to clear the
storerooms of obsolete items during spring 1995. In doing so, they made several
shipments to GSA but did not update the inventory records to reflect this.
(According to OSM personnel, a former Associate Administrator told them not to
update the records.) In addition, the manifest accompanying the GSA shipment
only listed the primary control number. For example, if a computer was shipped
to GSA with several internal parts--each part labeled with a unique control
number--the internal parts were not listed on the manifest. The computerized
account listing generated by the House, however, tracks the equipment by the
unique control number. Consequently, the inventory listing has not been adjusted
to reflect all items shipped to GSA during this time. Although OSM management
explained that this was an unusual occurrence, not their prescribed practice,
the inventory records should be adjusted to reflect the disposal of equipment.
Pager records
The Accounts Payable division maintains custody of and the accounting records
for House-owned pagers, including used pagers. Used pagers are recorded in the
House inventory account. To determine whether recorded used pagers were still in
House custody, we obtained a listing of pagers in the House inventory account.
The account reported 401 pagers. Our physical observation of the amount of used
pagers stored in Accounts Payable showed that the computer records included a
number of pagers no longer in their custody. To determine the extent of this
discrepancy, we performed a physical count of all used pagers in the division's
custody and determined that 127 pagers were missing. (We performed this count in
the presence of OSM personnel who could not explain the discrepancy or what
happened to the missing pagers.) Consequently, the pager records in OSM's
computer system are not reliable.
Unpaid items to vendors needs to be reviewed
The House has equipment on its books dating back to at least March 1985 for
which it has not been billed and/or not made payment. The "not billed/not paid"
report, which is produced by HIR, reported more than $7 million in unpaid
purchase orders from March 3, 1985 through June 28, 1996. According to CAO and
OSM officials, the House does not consider equipment as owned by
the House (although the item may be physically present and, in some cases, in
use) unless (1) an installation ticket signed by the requesting office has been
submitted to OSM, (2) a signed issue ticket has also been submitted, and (3) an
invoice has been presented and paid.
During our review of the "not billed/not paid" report, we inquired as to why
there were outstanding, unpaid purchase orders dating as far back as March 1985.
We were told by OSM management that they believed the Office of Finance had told
them they were prohibited from paying the older, outstanding purchase orders.
The CAO's Administrative Counsel indicated that purchase orders may be
outstanding because of a dispute, i.e., the ordered equipment was not
functioning properly, or because the vendor failed to invoice the House. The
existence of a questionable, multimillion dollar amount representing unpaid
purchase orders should concern OSM management. In an exit conference with OIG
staff, OSM and CAO officials agreed to use the "not billed/not paid" report as a
supplement to OSM's accounts payable tracking system.
HIR generates a list of "not billed/not paid" purchase orders which,
according to OSM management, is sent to them only at OSM's request. The list
indicates the status of an item, e.g., whether it has been received or partially
paid for, although OSM management explained that the report was intended to
provide OSM with information on outstanding items and not intended as a
receiving report. HIR produces this information based on input from OSM's
computerized inventory system. If a vendor fails to notify OSM that it has
provided the requested item to a Member, OSM will not pay the vendor.
(Typically, a vendor completes an installation ticket upon delivering the
equipment to a Member's office, has the installation ticket signed, and then
forwards it to OSM. This notifies OSM that the goods have been received and are
ready to be inspected by Asset Management. Asset Management receives an issue
receipt from the Accounts Payable division and compares the information on the
issue receipt with the physical equipment in the office, places an inventory
control label on the equipment, and obtains the Member's, or designated staff's,
signature on the receipt.) If a vendor fails to invoice OSM directly, even if
OSM's Asset Management division has physically confirmed that the equipment was
received by the Member, OSM does not consider it "officially received" and will
not pay.
The "not billed/not paid" report might also include equipment which has never
been received or which was ordered by a Member or office, who subsequently
canceled the order, without notifying OSM. The Accounts Payable division does
not have policies and procedures to ensure that vendor invoices are received or
are paid timely when the equipment has been delivered. According to OSM, the
vendor is responsible for submitting a signed installation ticket indicating
that the equipment has been delivered and installed and for submitting an
invoice for payment. We were told that the staff tries to review open
items when they have time but this is neither consistent or necessarily timely.
The supervisor of OSM's Accounts Payable division said certain vendors were
known to have poor billing practices but was not aware of any pattern
advantageous or disadvantageous to a particular Member. We selected 20 "not
billed/not paid" purchase orders (i.e., accounts payable) from the list based on
age, dollar amount, and vendor. Although the list does not contain the name of
the requesting office, it does include the purchase order number and this
enabled us to extract the name from the computer. From this, we determined that
there did not appear to be a pattern of failing to pay for a particular
requester's equipment. In addition, numerous vendors are represented in the
accounts payable listing and this appears to indicate that nonpayment by OSM is
random, and not targeted towards a specific vendor.
According to the "not billed/not paid" report, equipment listed on one
purchase order dated April 17, 1992, had not been received. However, the
supporting documentation included a signed installation ticket. OSM's procedures
require stamping a copy of the purchase order "installed" if a signed
installation ticket has been returned by the vendor to OSM. In this case, the
purchase order was not stamped. We also noted that the supporting documentation
did not include an issue receipt. Upon further review of the supporting
documentation, we learned that OSM personnel had contacted the vendor in
February 1993. The vendor replied that it had no record of shipping the
equipment and, therefore, could not invoice the House. According to the
documentation provided, this item was purchased under the one time payment plan
which means OSM should have charged the requester once the purchase order was
generated. OSM itself has not been charged and has not paid for this equipment
totaling $7,515.00.
Of the 20 "not billed/not paid" purchase orders tested, the report indicated
that equipment had been received in seven instances. We also noted three
purchase orders marked "payment pending," although they already had been paid
according to the computerized records. We were told this was probably a keying
error. In addition, the amount paid for two items exceeded the purchase order
amount. We initially had been told by OSM management that Accounts Payable pays
only the purchase order amount (or invoice amount if lower) even if a vendor's
invoice shows a larger amount due. We asked the Accounts Payable supervisor
about these apparent discrepancies and were informed that the differences were
probably due to the installation fees. She said the computer does allow a
payment exceeding the purchase order amount. She also noted that the new Federal
Financial System (FFS) allows a 20 percent override but anything higher requires
an amended purchase order. She said the purchasing office is normally not
charged the difference but believes this may have changed with FFS.
This supervisor further stated it is the vendors' responsibility to bill the
House timely, not the House's responsibility. She said a vendor occasionally
will ask about an invoice that the Accounts Payable division never received.
Sometimes the original invoice was sent to the office that received the
equipment and the office never forwarded it to the Accounts Payable division.
She also said, which the Office of Finance confirmed, that Finance would not pay
for equipment unless the invoice came from OSM's Accounts Payable division.
However, we noted that a Member was able to purchase computer-related equipment
through FRC, thereby weakening this control. She said OSM does not have time to
research all open purchase orders, and they only represent a small percentage of
the total processed.
When a Member purchases an item under the one time payment plan, his or her
account is charged at the time a purchase order is generated. However, OSM does
not pay the vendor until the vendor submits the installation ticket and invoice.
Therefore, Members have been charged for items for which OSM has not paid
because the vendors have not submitted the ticket and invoice. We were
also told that if a vendor submits an invoice which is less than the purchase
order amount, OSM still charges the Member, Committee, or House office the
purchase order amount. According to OSM management, this procedure enables OSM
to have funds available in case the vendor eventually requests the correct
amount. Unless OSM believes that vendors who invoiced the House for an amount
less than the purchase order amount will be submitting an invoice for the
difference at a later date, OSM should adjust obligations for differences
between obligations previously recorded and actual outlays to liquidate those
obligations.
OSM also frequently absorbs certain costs, e.g., Members are charged 100
percent of the vendor's maintenance fee for new equipment but only 55 percent of
the vendor's maintenance fee for reissued (used) equipment. OSM absorbs the
remaining 45 percent.
The "not billed/not paid" report contains other information which is
inaccurate and obsolete. For example, the report indicated that five of the
twenty purchase orders we tested, dated March 5, 1992, had not been filled,
i.e., equipment had not been installed. However, we obtained a copy of a letter
dated January 11, 1995, written by a Committee chairperson, indicating that the
equipment had been received at least two years earlier, but no installation
ticket had been signed. Therefore, OSM had no record that the equipment was
received. (According to the explanation we were given regarding the House's
official position on recognizing assets, this equipment was never officially
received and is not a House asset.) Although OSM has indicated that this report
was intended to provide information on open purchase orders and was not intended
for use as a receiving report, the information provided can be inaccurate. This
discrepancy should have been noted when the annual inventory tearsheets were
circulated in 1993 and 1994, and further illustrates the need for periodically
conducting physical inventories and timely reviews of open purchase orders.
In discussions with the OSM manager at a March 12, 1997 exit conference, we
were told that the "not billed/not paid" report was not designed to be a
management tool and that we should not have placed so much reliance upon it.
However, regardless of what it was intended for, it is our view that the
information in the "not billed/not paid" report (a report that has been prepared
and in use for at least the past four years) could prove very useful in
monitoring the status of unpaid vouchers and the assets they represent but only
after the outstanding items have been addressed and resolved.
Recommendations:
We recommend that the Chief Administrative Officer:
1. Periodically review and adjust the inventory records where appropriate, or
establish a suspense account and periodically review the account to ensure that
only authorized items are being transferred in.
2. Determine what is needed to resolve the "not billed/not paid" report and
use it as a management tool to identify and investigate reasons for outstanding,
unpaid purchase orders and the status of the assets they represent.
3. Review purchase orders which were recorded at greater than the actual
amount paid. Determine whether vendors who invoiced the House for an amount less
than the purchase order amount will be submitting an invoice for the difference
at a later date. If they are not, adjust the obligations for the differences
between the obligations previously recorded and actual outlays to liquidate
these obligations and adjust the requester's account accordingly.
4. Review accounts payable periodically to determine
whether they are being timely paid.
5. Evaluate the validity of current OSM procedures used to process vendor
invoices whose amounts differ from the original purchase order amounts.
Management Response
The Acting CAO agreed with the recommendations in this finding and cited the
following corrective actions to be taken. OSM created a suspense account for
inventory reconciliation purposes in March 1996 and will continue to use it when
investigating and reconciling assets to inventory records. OSM is now reviewing
the "not billed/not paid" report in order to resolve the payment status of
purchase orders. OSM currently uses the accounts payable tracking system to
determine timely payment of accounts payable, and will supplement this system
with the "not billed/not paid" report. In addition, OSM agreed to routinely
review the "not billed/not paid" report and provide periodic status reports
beginning on August 31, 1997. With regard to purchase orders recorded at greater
than the actual amount paid, OSM officials indicated they will submit a proposal
to the CHO to develop a procedure whereby payments of a certain dollar threshold
(to be determined at a later date with an explanation and/or supporting
rationale) will automatically be credited to the House account charged. Any
differences between the invoice amount and the established threshold will be
reviewed and resolved. In addition, the procedures used to process vendor
invoices that differ from the original purchase amounts will be reviewed and
modified accordingly. The Acting CAO also stated that OSM uses the accounts
payable tracking system (since May of 1996) to review outstanding payables and
provide summary information in the CAO's indicators report.
Office of Inspector General Comments
The CAO's current and planned actions are responsive to the issues we
identified and, when fully implemented, should fully satisfy the intent of the
recommendations.
Finding D: The Integrity And Reliability Of Management Controls For
Office Systems Management's Inventory System Are Inadequate
Management controls surrounding OSM's Office Equipment Systems (OES)
application system have not been adequately established to prevent unauthorized
activity. In an automated environment, best practices require the establishment
of general controls that ensure the protection and integrity of resident
software systems, as well as the establishment of application controls to ensure
the reliability of the data that is maintained by each application system. Our
audit determined that (1) approximately 48 percent of OSM personnel have been
granted supervisory level authority within the system, which allows access to
some of the restricted OES inventory transactions; (2) current practice allows
the supporting HIR programmer to modify the OES system without written
authorization; and (3) personnel no longer employed by OSM still have
supervisory access to the OES system. These weaknesses occurred, in part,
because there is no comprehensive set of standards and procedures defining the
general and application controls that can be expected to be contained within a
well managed computer environment. As a result, management can place no
assurance that erroneous or fraudulent transactions have not occurred in, or
been entered into, the OES system.
Discussion
The equipment inventory system is updated by entering an individual
transaction or by selecting a function from a menu through the Customer
Information Control System (CICS) communication system. During the audit period,
the OES system was still an active member of, and accessed through, the
Financial Management System.
Excessive number of OSM personnel have unnecessary system level
access
There are a total of 42 personnel within the OSM division. Almost half of
this group (20 of 42) have OES system privileges that allow them to access
"supervisory" transactions, even though only three are supervisors. This
privilege level allows access to OES transactions J010 (Control Record Utility)
and J020 (Terminal Printer Maintenance). These "supervisory" transactions have
been established to control access to transactions that management has
identified as requiring restricted access--said access being accomplished via
password control. The J010 "supervisory" transaction provides the means for
establishing a password for selected inventory transactions, thereby limiting
access to only those authorized users who have been given the corresponding
password. The J010 transaction itself does not provide this password change
capability. However, additional functionality was built into this transaction.
When it is called up, a password and transaction prompt are activated at the
bottom of the screen. This gives users who can access J010 the ability to select
a protected transaction and then change its password before entering the
selected transaction screen. The J020 "supervisory" transaction defines and
links application screen address locations to authorized users via their
Resource Identification Code (RIC), thereby giving the false impression of
limiting access to inventory transactions to pre-approved individuals.
Granting access to these transactions to a majority of the staff, i.e.,
anyone with access level "1" or higher, is self-defeating and undermines the
reliability of the online activities within the OES system. As an example, one
of the restricted transactions, J130, is used to make authorized changes to the
vendor name and address file/table. Allowing unauthorized personnel the
opportunity to access the J010 transaction, which in turn allows them to change
passwords to restricted transactions, e.g., the vendor transaction (J131),
exposes the system to fraud, waste and abuse, or simple human error. Subsequent
to our January 29, 1997 exit conference with OSM personnel, the Assistant Chief
informed us that all but two OSM personnel with access level "1" have been
changed to level "0," a level that cannot access J010 and J020, and that she has
limited assess level "2" to only two individuals. This action is laudable and
should provide a higher level of protection but more work needs to be done. For
example, as a result of our review and test of employee access levels, we
identified one employee who had two RICs with different access levels. This
particular situation stymied our test efforts because in addition to having two
active RICs (which is a security exposure), this employee was still carried in
the system under an inactive RIC. Given this information, we believe a
comprehensive review of all users is needed to identify and remove inactive RICs
as a cleanup measure if nothing else, and more importantly, determine if access
levels for individuals are accurate for every mainframe application (i.e.,
terminal ID) they can access. In addition, OSM can eliminate the exposure that
currently exists when the password and transaction prompts are activated with
the J010 transaction screen by requesting HIR to move these prompts to a
separate transaction screen and require verification of the current password
(which is not required now) before allowing a password change.
HIR programmer can modify the OES system without written
authorization
As part of the System Development Life Cycle process, an information system
will continue to evolve over its lifetime as user and site requirements change.
As the term 'change' implies, this process will transform the existing
production program(s) to reflect those requirements. Best practices require that
management develop a methodology regulating the change process in a manner that
ensures only authorized, tested, and documented changes are made to the system.
These fundamental concepts offer management a level of assurance regarding the
integrity of the application system in that all changes that have been made have
been authorized and are correct. However, the current authorization process
employed by OSM management, allows changes to the inventory system by verbal
request, thus bypassing this practice. As an example, the current process
governing the adding of personnel to the inventory security table that is
maintained by the HIR supporting programmer can be authorized by a telephone
request.
Personnel no longer employed by OSM still have access
We noted that ten personnel terminated from OSM were still defined as having
access to the inventory system. Of these ten, one has supervisory level
authority. Best practices require the immediate removal of access to an
automated system, once an employee's authorization is withdrawn either as a
result of a transfer or termination of employment. Access controls within the
OES system are based exclusively on the authentication of the on-line requester
through the input of an identification code and password. If an unauthorized
user gains knowledge of these still active access codes, then the system will
not only be unable to prevent access, but also be unable to produce an accurate
audit trail. As a compensating control, management must develop detective
controls that continuously monitor and report on sensitive transaction activity
such as the supervisory transactions. These two management initiatives relating
to preventative and detective controls should offer a adequate short term
solution. Since we already made recommendations in a previous audit report to
address the issue of terminated employee access for which HIR security has
initiated implementation, we are not making any additional recommendations at
this time.
Recommendations:
We recommend that the Chief Administrative Officer:
1. Develop procedures that limit access authority to J010 and J020
transactions to authorized personnel only.
2. Develop monitoring procedures that require continuous review of
password-protected transactions and require follow-up and documented review of
activity against such transactions.
3. Re-design the J010 transaction screen so that a separate path is required
to access the password function and transaction prompt function. Modify the
password prompt to require confirmation of the current password before allowing
a password change.
4. Review and update employee information via transaction J020 on a periodic
basis and verify employee access levels for each RIC and mainframe application
screen they can access.
5. Require HIR personnel be restricted from making changes to the inventory
production system without appropriate testing and authorized documentation from
designated OSM management.
Management Response
The Acting CAO agreed with the recommendations in this finding. Specifically,
he stated that OSM is working with HIR personnel to address concerns raised in
all of the recommendations of this finding. In addition, OSM will institute a
policy that requires documentation of changes made by HIR personnel, including
appropriate testing. Both of these actions will be completed by June 30, 1997.
Office of Inspector General Comments
The CAO's current and planned actions are responsive to the issues we
identified in this finding and, when fully implemented, should fully satisfy the
intent of the recommendations.
Finding E: Segregation Of Duties Is Not Always Implemented
During a review of OSM's operations, we identified several areas where
segregation of duties has not been implemented. One of the objectives of
achieving an effective internal control structure is to establish a logical plan
of organization with clear lines of authority and responsibility and segregation
of the operating, recording, and custodial functions among divisions or
individuals. Failure to segregate key duties and responsibilities increases the
possibility of assets being misappropriated and also reduces timely detection of
such misappropriation.
- The Office of Finance mails most checks directly to the vendor which helps
prevent the check from being misappropriated. Segregating the custody of the
asset from accounting is an effective control technique. However, the Accounts
Payable division can complete a check attachment form which instructs the Office
of Finance to return a check to the Accounts Payable division so that the vendor
can pick the check up from them. This procedure weakens the control technique as
there is no assurance that the check is adequately safeguarded during this
process or that the person receiving the check currently works for the vendor.
Therefore, the Office of Finance should mail all checks to the payee or the
vendor should receive them directly from the Office of Finance.
- Staff in the Asset Management division of OSM have both custody of the asset
and recordkeeping duties for the GSA and House inventory equipment. In addition,
before surplus sales were ended in 1995, Asset Management was responsible
for processing and entering the inventory transactions for the "pending surplus
sales" account. Therefore, key duties of entering and processing these
transactions were not adequately segregated among individuals. The segregation
of these duties is critical because there is no independent reconciliation of
physical items to the recorded assets. One compensating control is if the
equipment removed from the Member's office is not deleted from the Member's
account, the Member may still be charged for the equipment or maintenance and
notify OSM of the discrepancy. Another control would be if an independent
reconciliation of physical items to the recorded assets was performed.
- The Accounts Payable division was responsible for surplus sales until the
sales were ended in 1995. Staff collected proceeds and entered the sale into
OSM's computer system. Because Accounts Payable had both custody of the assets
and recorded the sale in the computer, key duties of entering data and
processing transactions were not adequately segregated among divisions. Based on
conversations with OSM management, we understand surplus sales have been
terminated, therefore, we have no recommendation to make with respect to this
issue.
Recommendations:
We recommend that the Chief Administrative Officer:
1. Assign an independent staff member to perform a reconciliation of physical
inventories of equipment in OSM's custody such as House inventory, surplus
sales, and GSA.
2. Require that the Office of Finance mail all checks to the payee or the
vendor receive checks directly from the Office of Finance.
Management Response
The Acting CAO agreed with the two recommendations in this finding. He
indicated that a nonOSM employee will perform a reconciliation of physical
inventories in OSM's custody, including House inventory, surplus sales, and GSA,
and that all such inventory reconciliations will be done within the two-year
cycle of a Congress. A policy statement to that effect will be issued no later
than July 31, 1997. The process began on January 3, 1997 and the non-OSM
employee will begin the physical inventory on October 1, 1997. With
regard to the disposition and handling of checks to vendors, the Acting CAO
indicated that there may be legitimate needs for the CAO to receive and sign for
checks, such as when a dispute is involved. However, the Acting CAO agreed that
at no time will checks to vendors be returned to OSM personnel. Again, a policy
directive covering this change in procedures will be in place by July 31,
1997.
Office of Inspector General Comments
The CAO's current and planned actions are responsive to the issues we
identified in this finding and, when fully implemented, should fully satisfy the
intent of the recommendations.
Finding F: Physical Security Is Not Adequate To Safeguard Certain
Assets
During tours of Asset Management's facilities, we noted unattended equipment
in corridors, open storerooms, and unlocked storage cabinets. In addition,
pagers in the Accounts Payable division were not kept in a locking file cabinet
because the staff did not think they needed additional security precautions.
Failure to properly secure assets may result in their misappropriation. Further,
because the physical inventory of these items is not consistently reconciled to
the records, it may take years before any theft or loss is detected.
Asset Management
On several occasions, subsequent to the audit period, we noted photocopiers
and computer processing units left unattended in the corridors outside the Asset
Management section. We also were able to open filing cabinets containing
keyboards. One compensating control is that photocopiers are large, heavy
objects and may be difficult to remove from the building without notice.
However, the computer equipment and keyboards are portable and could be
concealed and removed from the building without detection. We also noticed the
storeroom where House inventory is kept was open on occasion and portable
equipment, such as keyboards, were located on shelves near the entrance and
staff were not visibly present.
In addition, Asset Management personnel informed us that Member offices
occasionally leave equipment in the hallways which the Building Superintendent
finds and subsequently instructs Asset Management to retrieve. Asset Management
will put the equipment in House inventory only to discover that the office did
not want it removed and merely had placed it in the hallway for convenience.
Asset Management should not be asked to remove equipment, and should not remove
equipment, unless they have written authorization from the requester.
Accounts Payable
During the audit period, the Accounts Payable division did not store pagers
assigned to House inventory in a locking cabinet. We suggested the division
purchase and use a padlock on the pager storage cabinet to adequately safeguard
the assets. The division subsequently purchased and affixed a lock to the
cabinet. Further precautions should not be necessary because the book values are
minimal, a small quantity would be necessary for replacement as they are
currently storing more used pagers than are necessary for House operations, and
the pagers are of limited use outside the House.
Besides the missing, broken pagers discussed in Finding B, we also determined
that an additional three pagers cannot be located by the Accounts Payable
division. As noted above, the pagers are of limited value; however, from an
internal controls perspective, safeguarding assets is a primary objective.
Additionally, maintaining accurate accounting information also is critical;
therefore, the records should be adjusted to reflect the actual pagers on hand.
Storeroom access
Besides OSM staff, we were told other personnel, such as the Superintendent's
staff, have access to OSM's equipment storerooms. When we asked who specifically
in the Superintendent's office, or anyone else for that matter, had access to
these rooms, we were told they didn't know. According to OSM management, the
current Assistant Chief has keys to all storerooms and other OSM personnel have
access to particular rooms where they work. Access to the rooms should be
restricted only to those who work in the rooms, or oversee the operation, such
as the Assistant Chief. A roster should be kept of the individuals who have keys
and should be reviewed on a periodic basis for changes in personnel and duties.
Because OSM has not conducted a complete physical inventory or reconciled its
records to these assets, items could be removed by unauthorized personnel with
little risk of detection. Therefore, any personnel outside of OSM should notify
OSM in writing when they need access to the storerooms and where practicable
should be accompanied by Asset Management staff.
Computer hard drives
According to Asset Management staff, computer hard drives are reformatted when the equipment is reassigned to other
offices within the House, but not when the equipment is excessed to GSA. OSM
officials explained that they do not have the resources it would require to
erase or reformat hard drives in all equipment sent to GSA. Outdated but usable
computer equipment is excessed to GSA where it may be offered to other Federal
agencies who can use it or it may be sold at auction to the general public.
Therefore, House files and software programs may still be on the computer(s).
The latter situation may violate site licensing agreements; whereas the former
may incur breaches of confidentiality if retained files contain sensitive
information which should not be released. Best practices would require all hard
drives be reformatted or that a cleaning method (e.g., bulk erasure) be
implemented to protect sensitive information and comply with applicable
licensing agreements.
Recommendations:
We recommend that the Chief Administrative Officer:
1. Ensure that assets are secured at all times.
2. Determine whether used pagers should be excessed to GSA.
3. Develop and implement procedures to bulk erase or reformat hard drives in
all computers excessed to GSA.
Management Response
The Acting CAO agreed with all recommendations in this finding. He stated
that OSM is currently taking measures to ensure that all assets are secured at
all times and will take necessary steps to evaluate and address any weaknesses
to current practices. An initial security evaluation will be completed by August
31, 1997. With regard to used pagers, OSM is currently disposing of obsolete and
irreparable pagers to GSA and will continue to do so. Finally, the Acting CAO
will submit a proposal to the CHO by July 30, 1997 to develop and implement
procedures to bulk erase or reformat hard drives in all computers sent to GSA,
including required additional staffing and resources to accomplish this
additional workload. Until this proposal is approved and implemented, the CAO
will not dispose of any hard drive that has not been erased or reformatted.
Office of Inspector General Comments
The CAO's current and planned actions are responsive to the issues we
identified in this finding and, when fully implemented, should fully satisfy the
intent of the recommendations.
III. OTHER MATTERS
During our audit, the following matter came to our attention and, while this
issue is not as critical as the findings contained herein, we feel it warrants
management's attention and corrective action.
Based on the computer access provided to them, Accounts
Payable personnel can change a vendor's address when they are preparing a
voucher. The vendor's address for the voucher is obtained from the computer's
purchase order record and may need to be changed if the vendor requests that
purchase orders and remittances be mailed to two different addresses. However,
to prevent misappropriation of funds, we suggest vendor address changes be
carefully reviewed by an independent staff member (e.g., in-house personnel that
are not functionally responsible for that area) and said review be documented to
ensure that checks are not mailed to inappropriate addresses. According to OSM
management, this procedure is reviewed by another party; however, this review
should be documented, e.g., a sign-off, in order to strengthen the
controls.
Management Response
The Acting CAO agreed with us on this issue and indicated
that, in addition to a third party review, OSM officials stated that "checkers"
began initialing OSM's copies of the vouchers in 1994 to verify that all
information, including the 'remit to address,' was correct . However, beginning
in February 1997, the Finance copy of the voucher carried the checker's
initials.
Office of Inspector General Comments
The CAO's corrective action is responsive to the issue we identified in this
section.
EXHIBIT
U.S. House of Representatives House