The following report was obtained through a Freedom of Information request from Hartford's Auditors.
This report proves the old adage, you get what you pay for and seems to show that Government operations should not be handed out as political favors, rather than relying on experience in the appropriate fields.
I won't rehash the entire report, but essentially the audit uncovered an alleged pattern and practice of embezzlement of cash funds from the City of Hartford Vital Records Division
Theft of City funds is probably as old as the City of Hartford itself, but unfortunately the safeguards that should be in place to prevent these thefts, are not.
It seems all to often we see these thefts go unchecked, whether it is tens of thousands of dollars from Students Activity accounts at the Board of Education or now a supervisor in the Town Clerks office skimming cash receipts from vital records by allegedly voiding cash transactions and pocketing the cash..
It also appears, as detailed in the report, the employee knew that auditors were on her heels of tracking her criminal deeds and the employee let herself into City Hall on a Saturday morning to destroy the records that showed her thefts.
The dollar of the thefts is undetermined, essentially because the records have been destroyed by the employee in question, but it is estimated these thefts may have gone on for upwards of two decades.
I hate to say it, but only in Hartford can an employee steal like this, undetected, as they build their pension at the taxpayers expense with little or no fear of detection or criminal prosecution. An employee that had basic management skills should have been on top of this, especially after numerous warnings from auditors. This is what happens when people with no management experience are put in jobs because of their political connections and who they know, not what they know.
The Hartford City Clerk is a political appointment made by the Hartford City Council with no testing process or standardized requirements to manage the Department.
It is also interesting to note that probably one of the most qualified persons who applied for the Town Clerk's position, Eric Lusa. and was passed over. was the person who eventually noticed the suspicious activity and requested City auditors tor "take a deep dive" and investigate the Vital Records operations. Good job Eric for paying attention and speaking up.
THE AUDITOR'S REPORT IS BELOW:
I. EXECUTIVE SUMMARY
At the request of the Town and City Clerk we completed a follow up audit in July 2021 to specific issues related to transactions recorded by the Vital Records Unit (VRU) supervisor into the City financial system, Munis in 2019, 2020 and 2021. The purpose of the audit was to evaluate and test the accuracy and propriety of transactions processed by the VRU supervisor and other employees as necessary. The following includes only exceptions noted. The results of our examination were reviewed with N. McGregor, Town and City Clerk and shared with Corporation Counsel.
The VRU supervisor has been employed by the City for the past 34 years, 17 of those in the VRU of the Town Clerk’s office. We found that there was a complete lack of good internal controls and segregation of duties related to the supervisor’s recording of transactions and preparation of the daily batch balancing and cash deposit process. The supervisor could process daily transactions including MUNIS transaction reversals, collect cash, record sales, reconcile daily work batches and prepare the daily deposit alone with no witness, and then sent to the City treasurer’s office. There was no process to periodically review the supervisor’s work. There were no security cameras in the VRU. The lack of adequate internal controls and appropriate segregation of duties with access to cash, creates an environment extremely susceptible to the misappropriation of funds. During the beginning of our follow up audit in March 2021 we had concerns that the accounting records that we needed to examine may be tampered with or destroyed. We requested that the Town Clerk have the VRU supervisor put on administrative leave during the duration of the audit in order to preserve the accounting records. Just prior to the VRU supervisor being put on administrative leave on April 28, 2021, the VRU supervisor contacted Iron Mountain Enterprise Information Management Company to shred accounting records for the VRU. The VRU supervisor did this without the knowledge of the Town and City Clerk. We found, with the assistance of the Town Clerk that 2019, part of our investigative period of transactions, and many prior years accounting records were picked up for shredding by Iron Mountain in bins filled by the VRU supervisor on the Saturday before being put on administrative leave. These actions were in direct violation of the State of Connecticut document retention mandates and request for document destruction permission processes mandated by the State. Because most of the 2019 accounting documents were destroyed, we could not fully audit 2019 transactions. During our audit we found that the supervisor’s daily recording of transactions was not in accordance with established VRU procedures followed by the other VRU employees. Although the VRU operating procedures were apparently known by the VRU employees, the procedures were not documented in writing. Of the 92 transactions processed by the supervisor that we had accounting records available for examination, over half were not processed in accordance with established operating procedures. Critical fields in the MUNIS system were either vacant, incomplete, false all of which made it extremely difficult to follow and determine the legitimacy of the transactions. The evidential matter available to us was not sufficient to determine the complete extent of possible improper transaction recordings.
The Vital Records Unit (VRU) of the Town and City Clerk’s (TCC) Office (reports to City Council) is responsible for providing the public with copies of vital records such as birth certificates, marriage licenses, death certificates, burial and cremation permits, disinterment services and notary services. VRU charges its customers Connecticut State mandated fees ranging from $2 to $50 depending on the type of document. A portion ($16) of each marriage certificate is remitted to the state of Connecticut’s Department of Public Health. A majority of the transactions are processed over the counter in the VRU office in City Hall with customers paying with cash and with credit cards. Customers also request documents by mail, facsimile or through the Internet. These transactions are paid by money order or credit card. VRU also bills and collects revenue generated from fees assessed to other cities and towns for document services provided. VRU uses the Cash Receipt module of the MUNIS Financial Management System (MUNIS) to process and account for cash, checks, money orders and credit card receipts.
On July 23, 2020, we issued our audit report #2017 covering the Revenue Accounts and Operations of the Vital Records Unit of the Town and City Clerk’s Office. We reported in this report and also in a similar report issued in 2015 the following:
· During the period from July 1, 2019, to February 14, 2020, we noted 355 reversal of cash receipt transactions totaling $16,910 that were processed in MUNIS by VRU. There is no indication that these transactions are being monitored, reviewed, and approved by supervisory personnel. In addition, all VRU employees that receive, and process payments are also able to process reversals.
· There is no indication that VRU supervisory personnel review the daily cash receipt transactions and summaries to verify that all activity has been properly accounted for throughout the process and recorded in MUNIS as required. This includes reconciling transactions recorded in MUNIS to applications and other supporting documentation.
The Town Clerk responded that “I was appointed as Town and City Clerk on March 9, 2020. This is an area I have not had a chance to look into because of COVID 19, but do recognize there needs documentation, and verification of reversal transactions by a supervisor. We will work on the comments detailed above and will act to follow-up on and address each of the related recommendations as noted and will work with the Internal Audit Department to develop such directives”. In March 2021, the assistant Town Clerk asked the Chief Auditor if the internal audit department could take a deep dive into MUNIS reversal transactions because he had suspicions of improper accounting entries and possibly misappropriation of City funds perpetrated by the Vital Records supervisor. We met with the Town Clerk and the Assistant Town Clerk and agreed to perform audit work related to management’s concerns.
The scope of our audit included various reviews and tests of transactions recorded by the VRU supervisor and others primarily during the fiscal year ended June 30, 2020, and 2021. We performed tests and reviews of daily cash receipts, bank deposits and related accounting, recording and balancing processes and reviews and tests of credit and voided transactions.
II. AUDIT RESULTS
City VRU Records Destroyed During the Investigation
During the beginning of our audit, we had concerns that the 2019 and current accounting records that we needed to examine may be destroyed. We requested that the Town Clerk put the VRU supervisor on administrative leave in order to preserve the accounting records. Before the supervisor was put on administrative leave, she contacted Iron Mountain Enterprise information management company to shred City VRU accounting records without the knowledge of the Town Clerk. We found, with the assistance of the Town Clerk, that most of the 2019 VRU manual accounting record, part of our investigative period, and many prior years accounting records were picked up by Iron Mountain, their secured bins filled by the supervisor, for destruction without the express permission of the Town Clerk or the State of Connecticut. The act of having municipal records destroyed prior to the state’s mandated retention period and during an audit/investigation was in direct violation of the State of Connecticut document retention mandates. Practically all of 2019 manual accounting records/daily work batches were destroyed during our audit that started in March of 2021. The following is an excerpt from the State Document retention mandates https://atlas.ct.gov/Portal/pages/index.jsp, record series title – Cash Receipts, Disbursement ledgers, Journals, Books, etc. Minimum retention period is Fiscal Year End plus three years.
Inadequate Segregation of the Supervisor’s Duties
We found that the internal controls and segregation of duties related to the VRU supervisor’s recording of transactions and preparation of the dialing batch balancing and cash deposit process were inadequate. The VRU supervisor could process daily transactions including the reversal of sale transactions in MUNIS, collect cash, record sale transactions in MUNIS, reconcile daily work batches and prepare the daily deposit with no witness prior to sending it to the City treasurer’s office. There was no process to periodically review the VRU supervisor’s work, as mentioned below, and there were no security cameras in the VRU. The lack of adequate internal controls, management oversite and appropriate segregation of duties, including access to cash, creates an environment susceptible to the misappropriation of funds and inappropriate accounting entries.
Town Clerk Management Oversight
We could not find any evidence that there was any documented management oversight of the VRU supervisor’s work during the past two Town Clerk’s terms. Such management oversite would include periodic documented reviews of the VRU supervisors work in light of a lack of segregation of duties including access to cash transaction recording in MUNIS and solely performing the daily deposit and work batch reconciliations. No management action, to our knowledge, was taken to correct issues reported in our 2015 audit report covering the VRU operations, specifically the issue related to reversals of recorded transactions in MUNIS.
Procedures and Controls
Procedures for the collection, processing, recording, deposit and balancing of cash receipts; and fee billing and collection processes were not adequately documented in writing. Documenting procedures and controls for key processes in narrative form in writing is a basis for good internal controls and provides management with a baseline for evaluating day-to-day activities and employee performance. We recommend that TCC management document procedures, process flows and related key controls for the areas noted above in writing. Ideally, these procedures and process flows should be documented using automated tools such as Microsoft Word or Excel so that they can be easily updated as necessary with any required changes. Key controls and the individuals/positions responsible for them should be noted where appropriate in the documentation. Although the procedures are not documented in writing, each VRU staff member is required to follow their supervisor’s verbal training in those areas. The VRU staff was apparently trained on the proper recording of transactions in MUNIS. at the start of each VRU staff employment and they are expected to follow those procedures as follows:
1. Each customer’s application, for Marriage Licenses, Burial Permits, and Death and Birth Certificates must be separately recorded in MUNIS
2. All cash receipts should be recorded immediately by the cashier in MUNIS
3. All checks, cash, money order, and credit cards should be recorded in MUNIS with the correct amount, check/money order and credit cards numbers
4. At the end of each day, all applications for Marriage Licenses, Burial Permits, Death and Birth Certificates, check images, visa receipts and MUINS payment proof reports must be attached to each VRU staff batch package
5. All customer transactions must be properly identified in MUNIS
6. In the “Paid by” field, in the MUNIS cash receipt module, the name of the customer must be recorded
7. The payment method should be recorded and properly identified with a check or credit card number
As noted in the details that follow the VRU supervisor’s processing of transactions in many instances are not in accordance with the procedures that the staff was trained on when processing like or similar transactions. The results listed below resulted from our audit work which include an examination of 205 MUNIS transaction reversals recorded between July 2019 and April 2021 related to the VRU supervisor’s daily work batches:
1. In several instances, 159 out of the 205 reversal transactions were not properly identified and were in violation of most of, if not all the seven establish internal processes, procedures and controls listed above specifically as it relates to transaction recordings of Death Certificates. We identified more than 69 of the 205 reversal transactions, where the reversed sale was paid by check, the field in MUNIS identifying the payer was not properly posted. Instead of the name of the customer, as required, the “paid by” field said either “deaths” or “Customer”. By not posting the customer’s name accurately it would be extremely difficult to identify the actual customer and make it easier to mask a misappropriation of funds.
2. In the “paid by’’ section labeled Deaths, we found several different funeral homes made payments for Death Certificates that were recorded on one receipt instead of separate receipts for each funeral home as required, payments by check were recorded in MUNIS with no check number or an invalid check number. As a result, we could not trace these transactions to the daily bank deposit. It appears that these types of transactions were recorded in MUNIS to replace actual cash receipts that may not have been included in the daily deposit.
3. In the “paid by” section labeled Customers, we found several different funeral homes check payments that were recorded for sales other than death certificates such as birth certificates and plastic covers, thing funeral homes do not purchase from the VRU. We contacted the related funeral homes, and we were informed that they did not request any birth certificates or covers from the City of Hartford and that they only purchase copies of death certificates. We also found credit card payments that were improperly recorded as sales of death certificates. These transactions could have the appearance of being made to replace unrecorded cash payments not included in the daily bank deposit.
4. A reversed check payment made for death certificates, with no other replacing entry in MUNIS, was deposited in the City of Hartford bank account. On March 2, 2021, the VRU supervisor processed a check totaling $105 for five death certificates and one burial permit. The transaction was recorded in MUNIS, and the customer received five certified death certificates and one burial permit. On March 3, 2021, the VRU supervisor reversed $105 check payment that was previously recorded on March 2, 2021. Later that afternoon, on March 3, 2021, the VRU supervisor prepared the daily batches, March 2, 2021, for deposit, which also included the $105 reversed/unrecorded check payment, in the City bank account. It appears that the deposit of the check related to the reversal of the sale in MUNIS was used to replace cash that was not recorded in MUNIS or deposited in the bank.
5. We found instances where check payments recorded in MUNIS were completely different form the amount deposited in the bank account. One check was recorded in MUNIS as $105; however, the bank deposit indicated that the check was for $40. It appears that the $65 difference was used to replace $65 of the $105 reversed/unrecorded check deposit mention in item four above. Also, a check payment totaling $40 was recorded in MUNIS with no check number and we could not find it deposited into the bank. It appears that this check was never remitted by a customer, is not a valid transaction and was made to reconciled MUNIS sales to the daily bank deposit inappropriately.
6. We found a cash payment made to the VRU that was incorrectly recorded in MUNIS but was in the daily bank deposit. The VRU supervisor received, as evidenced by a signed receipt from a funeral home, $170 cash payment. The cash payment was a reimbursement to the City for an insufficient funds returned check for a transaction purchasing six death certificates for $120 and a $50 bounced check fee. The VRU supervisor recorded in MUNIS $100 for death certificates and $50 for the NFS fee. The VRU supervisor did not follow the proper procedure related to an accounts receivable payment. The proper procedure for an accounts receivable payment is to create a single receipt batch for the total amount received and to notify the City Custody of Funds division, Treasurer’s Department, of the payment. Because the payment was not properly recorded in MUNIS the Custody of Funds division did not clear the accounts receivable amount until February 2021, more than four months after the payment was received. The $20 cash difference between the $120 received and the $100 that was recorded in MUNIS could not be located in the City bank account. The VRU supervisor could not explain the $20 difference.
7. We found another instance where the VRU supervisor received a check for $200 from a funeral home for the purchase of 10 death certificates; however, we could not find the related entry in MUNIS, but we found the deposit in the bank. It appears that in order to reconcile MUNIS transactions to the bank deposit for that day, the VRU supervisor recorded in MUNIS several fictitious check numbers to total $200. It appears that that these fictitious check numbers and amounts were inappropriately recorded to account for unrecorded funds of $200.
8. We found two instances where the VRU supervisor used check payments received, from three separate funeral homes for the purchase of death certificates, to apply in MUNIS to birth certificates and birth certificate plastic cover accounts. A detail review of these transactions indicates the following:
· One funeral home, applied, paid for, and obtained 20 death certificates and one burial permit for $405 through the VRU supervisor. However, the transaction recorded in MUNIS indicates that the funeral home received a birth certificate plastic cover for $2 and $383.00 for death certificates. The funeral home indicated that they only applied for 20 death certificates ($400) and one burial permit ($5) but didn’t apply for or receive any plastic cover. The difference of $20 not recorded in MUNIS and the cover recording could not be explained by the VRU supervisor. The difference could have the appearance of been used to account for unrecorded cash receipts.
· Three funeral homes purchased nine copies of two different death certificates, four burial permits and paid a total of $200. However, a review of the related MUNIS transactions indicates that the $200 in checks that were received for death certificates and burial permits, were recorded to the birth certificate and plastic cover charge allocation account. It appears that the inappropriate transactions made to the birth certificate and plastic cover account was done to account for unrecorded cash receipts.
9. On July 21, 2020, a customer applied for two separate birth certificates at $20 each. The applications for a birth certificate copies indicated that one application was for the applicant’s child and the other was for the applicant’s grandchild. The application for the grandchild also indicated that the applicant must present the child’s birth record. A review of the applications indicated that the VRU supervisor approved the customer application and when questioned the VRU supervisor did admit that the applications were approved. Based on the VRU supervisor approval, it appears that a $40 payment was received for the birth certificates, and they were given to the customer. We could not find the related transaction in MUNIS, nor could we find the cash deposit in the bank.
10. Our review of 707 receipts recorded in MUNIS and labeled not reversed disclosed that 43 were manually reversed. We noted that 23 of the 43 transactions were for, either incomplete receipt and cash/credit payments and adjustments for reconciled items. It should be noted that 15 out of the 23 transactions were for credit card payments. We could not determine the reasons for this transaction due to a lack of MUNIS documentation.
11. A review of two of the VRU supervisor’s daily transactions batches, dated October 28, 2020, and July 21, 2020, disclosed that the VRU supervisor recorded in MUNIS, on October 28,2020, a cash payment of $20 for a copy of a marriage certificate. The recording was part of the total cash payments of $240. However, on October 29, 2020, the VRU supervisor included in the daily cash payments of only $220. On November 23, 2020, the VRU supervisor was informed by the Treasurer department that the daily batch did not match the deposit received by the bank. On November 24, 2020, the VRU supervisor, without conducting a due diligent research, reversed $20 from a check amount received from a funeral home for a death certificate. On the day of the initial October 28, 2020, recording, the VRU supervisor received $120 for six death certificates and the amount was correctly recorded in MUNIS and was part of the daily deposit. We also noted that on October 28, 2020, the Vital Records supervisor recorded in MUNIS a cash payment of $20 for a copy of a marriage certificate. This recording has part of the customer’s name, the amount, payment method and was never reversed in MUNIS. An actual copy of the application was found in the VRU supervisor’s daily batch package. After a review of the marriage certificate, we determine that the customer received a copy of the marriage certificate. It is our opinion that an actual customer came to the Vital Records office and apply for a copy of a marriage certificate, received a copy, and paid the correct amount in cash. However, the Vital Records supervisor could not account for the missing $20. We could not determine what happen to the $20 cash payment between the day of the transaction and the day it was prepared for deposit.
Interview with the VRU Supervisor
On June 16, 2021, a meeting was held with the VRU supervisor to explain the business purpose of several accounting transactions and other related issues noted in this report. In attendance were the Chief Auditor, VRU Supervisor, HEMEA Union Representative and two Internal Audit Staff. During the two-hour meeting, the Supervisor could not adequately explain the business reason for entering numerous transactions into MUNIS related to VRU cash, credit card and check transactions. Most of the Supervisor’s answers to Internal Audit’s questions were, I do not remember or do not know the answer, or it must be a mistake. The business reasons for adjusting/reversing transactions were not documented or could not be explained in most questioned instances. At times the Supervisor was agitated and confrontational.
Town Clerk Management Actions Taken to Date
This memo is to provide an update on steps taken by the Town Clerk to remedy identified concerns in the Vital Records Unit. This update is not a completed list of the corrections that need to be made but we hope are steps taken immediately to correct past accounting deficiencies.
- Installed IQS accounting software which will detail each transaction and will eliminate reversals and manual input to MUNIS. Each transaction is identified and put into separate accounts therefore removing Transcript of Records as the sole depository of transactions
- Installed receipt printers at POS, with connected cash drawers.
- Deposits are done with two persons in Town Clerk’s office under cameras.
- Safes repaired and are able be locked.
- Security cameras ordered and waiting vendor installation.
- Corrected process of collecting of NSF.
- We are in the process of updating all policy and procedures.
- Card key will be required to enter secured working area from lobby of Vital Records Unit.
- Removed Vital Records supervisor as authorized on Iron Mountain account to shred records, the Town Clerk will be the only authorized person.
- The Town Clerk will keep the Internal Audit Department up to date with future actions taken to improve the controls in the VRU.
- The Town Clerk will determine the appropriate personnel action to take, if any, related the VRU supervisor and he will work with the City Human Relations office and the City Corporation Counsel’s office based on the action he deems appropriate.
City Council Members
Internal Audit Commission Members
L. Bronin, Mayor
A. Cloud, Treasurer
J. Hockenhull, Chief Financial Officer
T. Montanez, Chief Operating Officer
L.A. Ralls, Finance Director
H. Rifkin, Corporation Counsel
V. Rossitto, Partner, Blum Shapiro