Internal Audit Slides
Port of Seattle Audit Committee June 28, 2019 Pier 69, Commission Chambers 11:00 AM – 1:00 PM Awards & Recognition 2 Audit Committee Recognition •Christina Gehrke – 8 years of outstanding voluntary service – 2011 - 2019 – 3rd term – Provided invaluable expert counsel to commissioners and to Internal Audit 3 Internal Promotions Spencer Bright – Capital Audit Manager Hired January 2017 Certified Internal Auditor, Certified Fraud Examiner Rumi Okuma – Senior Internal Auditor Hired November 2018 CPA, Certified Internal Auditor, Certified Fraud Examiner 4 Glenn Fernandes Internal Audit Director Organization Structure Pam Bailey Sr. Administrative Assistant Operational & Compliance Spencer Bright Bruce Klouzal Dan Chase Manager – Capital Audit Manager - IT Audit Sr. Manager - Internal Audit Ritika Marwaha Rumiko Okuma Open Sr. Internal Auditor Sr. Internal Auditor Internal Auditor Jennifer Albrecht Internal Auditor Nikita Goyal Internal Auditor Open Internal Auditor 5 2019 Audit Plan INTERNAL AUDIT Limited Contract Operational Information Compliance Technology •Sixt Rent A Car •Airport security screening program •Security of Personally LLC •Diversity Program Identifiable Information •Enterprise Rent A •Marine Maintenance •HIPAA – Compliance Car •PCI-Quality Security •Anton Airfood Capital Assessor • Mad Anthony’s •Baggage Optimization •Closed Network System •Marketing Fund- •Noise Insulation Programs (FAA Security Concessions Part 150) •T2 Airport Garage •Concourse D Hardstand Terminal Parking System •Shilshole Tenant Service Building Replacement 6 2019 AUDIT PLAN STATUS Audit Title Type Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Sixt Rent A Car LLC Limited Compliance Marketing Fund-Concessions Limited Compliance Security of Personally Identifiable Information IT Noise Insulation Programs (FAA Part 150) Operational - Capital Marine Maintenance Operational Mad Anthony's Limited Compliance Baggage Optimization Operational - Capital Anton Airfood Limited Operational Diversity Program Operational Closed Network System Security IT Enterprise Rent A Car Limited Compliance Airport Security Screening Program Operational Concourse D Hardstand Terminal Operational - Capital HIPAA Compliance IT Shilshole Tenant Service Building Operational - Capital PCI Quality Security Assessor IT Add: Inventory and Control of Hardware Assets IT Add: Architectural, Engineering & Related Support Services Operational - Capital Remove: T2 Airport Garage Parking System Replacement IT Complete Key: In Process 7 Request to Remove/Add from Audit Plan INTERNAL AUDIT Audits to be discussed 1) Marine Maintenance Shop 2) Diversity in Contracting 3) Checked Baggage Optimization - Phase I 4) Noise Insulation Program 5) Mad Anthony’s, Inc. 6) Anton Airfood 8 INTERNAL AUDIT Marine Maintenance Shop Maintains Port waterfront properties, fleet, and equipment 14 specialized crafts (Plumbing, Painting, Electrical, Carpentry, etc.) Operates one central repair facility at 25 South Horton Street Performs small works projects, generally < $300,000 9 Results INTERNAL AUDIT High – (self-identified) A process to issue and track keys and badges needs to be enhanced. Comprehensive list of physical access points did not exist Segregation of duties for authorization, custody, distribution did not exist Badges of terminated employees were still active Badge applications, showing authorization not retained Policies and procedures not established 10 INTERNAL AUDIT Results High – Internal controls to monitor and account for fleet and fuel usage need to be strengthened. Certain Fuel Master controls (functionality) need to be used Process to assure Fleet vehicles are only used for business purposes Process to monitor fuel usage for unusual patterns Fuel logs were not always complete / lost Surveillance camera on fuel pump 11 INTERNAL AUDIT MANAGEMENT RESPONSE Management to discuss in person. Detailed response presented in audit report. 12 12 INTERNAL AUDIT Diversity In Contracting Audit required per Policy Directive Revised Code of Washington 49.60.400 “The state shall not discriminate against, or grant preferential treatment to, any individual or group on the basis of race, sex, color, ethnicity, or national origin in the operation of public employment, public education, or public contracting.” Washington State Attorney General opinion Provides measures not prohibited: aspirational goals, outreach, training I-1000 Clarity of definitions / expanded scope 13 13 Results INTERNAL AUDIT Medium – The Port established a five-year goal to increase to 15% the amount spent on WMBE contracts and to triple the number of WMBE firms. However, the starting point or baseline that management was using to measure the goal was not consistent with the date within the Policy Directive. Table 1: 2018 Baseline - WMBE Goals 2018 2022 Percent of Total Spend 11.8% 15.0% Number of Firms 244* 732 * Adjusted to correct for overstatement of 14 firms Table 2: 2016 Baseline - WMBE Goals 2016 2020 Percent of Total Spend 5.3% 15.0% Number of Firms 118 354 14 INTERNAL AUDIT Results (Continued) Medium – 2018 WMBE utilization was overstated by 14 firms in the Diversity in Contracting 2019 Annual Plan. 15 MANAGEMENT RESPONSE INTERNAL AUDIT The five-year goal was formed under good faith efforts based upon the information we had at the time. Work began in 2017, where we had a full year of 2016 data to review; however, full Diversity in Contracting Program implementation was not complete until 2019. Staff recommends maintaining the 2016 baseline for the 5-year measurements to 2020. If 2018 is determined to be the starting point, staff recommends Commission re- evaluates the Diversity in Contracting utilization goals. During the audit process, the Planning and Analytics team discovered the problem, reported the issue to the audit team, and have developed standard reports that remove duplicate records. This will prevent double counting in the future. 16 Port of Seattle Operational Audit – Checked Baggage Optimization June 28, 2019 17 Checked Baggage Optimization Project Phase I Project Background Audit Scope Designer – BNP Associates, Inc. Evaluate Contract Compliance $12 million Service Agreement Lump Sum Agreement Contractor – PCL Construction Services, Subcontract Agreements Inc. Assess Project Management $52 million Lump Sum Agreement Pay Estimates $2.5 million of change orders increased contract to $54.5 million Change Order Management Reviewed progress at 83% complete at Reporting June 2019 Communications Target Completion - December 2019 Testing Actual Completion - Delayed (projecting March 2020) Schedule Analysis June 28, 2019 18 18 Checked Baggage Optimization Project Phase I Audit Area Description Contract Compliance Adequate by POS and PCL. Includes assessing pay estimates, submittals and project reporting PCL lacked proper oversight of subcontractors (J Webb) causing delays – MEDIUM RATING J Webb submittals delayed fabrication, delivery, testing and installation Project Management High turnover of project staff and lack of experienced professionals for specialized project Current PCL Project Manager was not approved by formal submission to POS per specifications and lacks BHS experience Contractor schedule appeared to be adequate to meet contractual completion dates Schedule Analysis POS has not formally accepted PCL’s revised completion dates / Liquidated damages can be pursued Potential additional three week schedule delay due to replacement of water damaged EDS equipment June 28, 2019 19 19 Checked Baggage Optimization Project Phase I What Went Well 1.POS Project Oversight Use of Serial Letters to document project risks / concerns Use of POS staff to mitigate testing and installation schedule risks Overall project cost management….sufficient contingency 2.Employment of Industry Best Practices Change Management Process Openness to accept the audit and recommendations June 28, 2019 20 20 Checked Baggage Optimization Project Phase I Audit Recommendation 1.Continued suitable oversight by POS project staff to maintain current budget condition and mitigate further scheduling delays 2.Upon completion of Phase I, Port management should calculate and pursue liquidated damages from PCL June 28, 2019 21 21 Checked Baggage Optimization Project Phase I Management Responses (to be provided in person) Management agrees and intends to pursue liquidated damages for unexcused delays. June 28, 2019 22 22 Checked Baggage Optimization Project Phase I Questions Ken Brzozowski, CCA, CCP Engagement Director kbrzozowski@talsonsolutions.com June 28, 2019 23 23 INTERNAL AUDIT Noise Insulation Program Commission requested IA look at program Established in 1985 to reduce noise in homes, condominium complexes, and schools $400 MM spent to date Historical mitigation costs funded by airport funds Future costs 80% FAA grants and 20% airport funds Audit focused on 2013 through 2016, work performed by Burton Construction Inc. Reviewed costs associated with 20 out of 48 houses 24 INTERNAL AUDIT Noise Insulation Program (cont.) Port utilized the Job Order Contract (JOC) project delivery method for noise insulation of single family residential residences Burton Construction paid $2.8 million Subcontracted more than 90% of work, as required Job Order Contracting Delivery Method Price Book used to establish Job Order pricing Contractor bids a price “co-efficient” to cover overhead, profit and management costs Contractor submits a work authorization request for each project by priced item list 25 INTERNAL AUDIT Noise Insulation Program (cont) Example of summary costs by description The coefficient is bid by the JOC Billed amount is “Bare Cost” X “Cost Index” X “Contractor Coefficient” Abatement not consistent with asbestos/lead and work done 26 INTERNAL AUDIT General Conditions: Costs of a general and administrative nature Per “Blueprint to Construction Auditing”, should average 5-8% High General Conditions % warrants further review Burton averaged 30% 27 Noise Insulation Program (cont) INTERNAL AUDIT General Conditions / Adjustment Factors for Work Order 24 Usage curtailment is billed twice; both the minimum and maximum Per the RFP this should have been in the coefficient A charge for a pickup truck? 28 INTERNAL AUDIT Results High – Port’s controls related to review of Job Order Contract proposed work not functioning effectively. Burton charged the Port a 51% average mark-up • Results are the same whether you look at mark-up or detail line items Assuring line items and quantities proposed are appropriate requires a diligent review and necessitates questioning items that appear inaccurate Our work indicated a reasonableness review was not always performed. 29 Results INTERNAL AUDIT Medium – Highline School District (HSD), an FAA Airport Improvement Plan grant recipient, was not always in compliance with Grant requirements. Port is responsible to verify subrecipient compliance with FAA grant requirements Failure of HSD to comply with requirements can jeopardize current federal grants Port working with HSD to assist with Federal Procurement Contracting guidelines and compliance with grant requirements 30 INTERNAL AUDIT MANAGEMENT RESPONSE - JOC Management to discuss in person. Detailed response presented in audit report. 31 INTERNAL AUDIT MANAGEMENT RESPONSE – FAA Grant Port staff appreciates and supports Audit’s recommendation to enhance current processes to ensure grant recipient awareness. Our recent experience with the Highline School District (HSD) provides a good basis for that enhancement. Management to provide more information in person. 32 INTERNAL AUDIT Mad Anthony’s Anthony’s at Fisherman’s Terminal (Chinook’s) Lease Agreement established in 1987 Percentage Rent 6.25% of gross sales in 1990 up to first $3 MM, thereafter 8% $3 MM adjusted annually since 1990 using CPI Gross Revenue Range 2014 – 2018 between $6.600 MM and $7.391 MM / year Annual Percentage Rent Range 2014 – 2018 between $437,000 and $491,000 / year 33 INTERNAL AUDIT Results Medium – Revenue underreported by $194,461 during the two- year audit period. $15,557 in additional percentage rent due. Surcharge – 4% added to customer bills between January 2017 and March 2018. Half (2%) paid to kitchen staff ($172,055 ) not included in Gross Revenue. Employee Meals – $22,406 included family and friends of employees. 34 INTERNAL AUDIT MANAGEMENT RESPONSE Management accepts that Mad Anthony’s has understated revenues during the audit period and will pursue collection of $15,557. 35 INTERNAL AUDIT Anton Airfood Anthony’s Restaurant and Fish Bar at Sea-Tac Lease Agreement established in 2003, expired March 31, 2019 Managed by Host Gross Revenues between April 2016 – March 2019 between $18 - $20 million / year Percentage Fees Paid between $2.0 - $2.3 million / year 36 Results INTERNAL AUDIT High – Anton did not provide a complete chart of accounts, the daily point of sale data, cash register z-tapes, and guest checks in its original format resulting in a scope limitation. IA unable to obtain sufficient and appropriate audit evidence to provide reasonable assurance. Medium – Anton did not report $42,022.90 in gross revenue in January 2019. $5,420.46 in additional percentage fees is due to the Port. 37 INTERNAL AUDIT MANAGEMENT RESPONSE Management agrees with this finding. Airport Dining and Retail staff continues to work with Host and Internal Audit staff to resolve this specific issue and will emphasize to all ADR tenants, the need to maintain accounting records for three (3) years so as to avoid this problem in the future. Management to discuss in person if needed. Detailed response presented in audit report. 38
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