Johnson County Auditor
Johnson County, Kansas

PERFORMANCE AUDIT
December 6, 2007

Audit of Department of Corrections

"The department needed to unify its two separate divisions”

Report No. 2007-06

www.jocogov.org

Johnson County Audit Services
December 6, 2007
To: The Johnson County Board of County Commissioners
County Manager
Director, Department of Corrections

In accordance with the approved audit plan, we performed an audit of the Department of
Corrections. Our objectives were to review financial and management controls over major
functions of the Department and to determine compliance with county policy and Kansas law.
Audit results showed the department was not managed uniformly between divisions and lacked
sufficient internal controls. This created vulnerabilities and risks in some department programs
such as medication controls, key controls, collections and ethics. We made recommendations to
improve management and internal controls especially in the Adult division.
The new Department Director was receptive to the audit results and in many instances began
corrective measures during the audit. I appreciate the cooperation, candid dialog and quick
response to the issues reported. Detailed responses to the recommendations are included in each
issue reported and full text comments including comments on the audit conduct are included in
Appendix II, page 29.
The audit was conducted according to applicable standards contained in Government Auditing
Standards, issued by the Comptroller General of the United States, except that Peer Review has
not been performed, and included such tests of the procedures and records as considered
appropriate.

William D. Miller, CIA, CGFM
County Auditor
The following auditors contributed to this report:
John Middleton, CPA
Patrick McQueen
Michelle Holland, CFE

111 South Cherry Street, Suite 3300
Olathe, KS 66061-3441

(913) 715-1825
Fax: (913) 715-0440

AUDIT OF DEPARTMENT OF CORRECTIONS

TABLE OF CONTENTS
Page
RESULTS AND RECOMMENDATIONS..................................................................................1
1. Administration of the Department of Corrections Can Be More Efficient..................................1
Recommendations................................................................................................................1
Management Comments ......................................................................................................1
Discussion ............................................................................................................................3
2. Management Needs to Control Distributions of Medications .....................................................6
Recommendations................................................................................................................6
Management Comments ......................................................................................................6
Discussion ............................................................................................................................7
3. Management Needs to Improve ARC Key Control.....................................................................9
Recommendations................................................................................................................9
Management Comments ......................................................................................................9
Discussion ..........................................................................................................................10
4. ARC Accounts Receivable System Needs Improvement ..........................................................11
Recommendations..............................................................................................................11
Management Comments ....................................................................................................11
Discussion ..........................................................................................................................11
5. ARC Fee Forgiveness Practices Need Re-Evaluation ...............................................................13
Recommendations..............................................................................................................13
Management Comments ....................................................................................................13

i

Discussion ..........................................................................................................................13
6. Management Can Improve Delinquent Fee Collections............................................................16
Recommendations..............................................................................................................16
Management Comments ....................................................................................................16
Discussion ..........................................................................................................................17
7. JDC Application of Paid Time-Off Needs Improvement ..........................................................19
Recommendations..............................................................................................................19
Management Comments ....................................................................................................19
Discussion ..........................................................................................................................19
8. Management Can Improve Purchasing Efficiency ....................................................................20
Recommendations..............................................................................................................20
Management Comments ....................................................................................................20
Discussion ..........................................................................................................................20
9. The Department Could Benefit From Centralized Accounting Policies and Procedures..........22
Recommendations..............................................................................................................22
Management Comments ....................................................................................................22
Discussion ..........................................................................................................................22
10. The Performance Measurement System Could Be More Effective.........................................23
Recommendations..............................................................................................................23
Management Comments ....................................................................................................23
Discussion ..........................................................................................................................23
11. Ethics Violations Were Not Reported......................................................................................26
Recommendations..............................................................................................................26

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Management Comments ....................................................................................................26
Discussion ..........................................................................................................................26
APPENDIX I
OBJECTIVES, SCOPE AND METHODOLOGY .......................................................................27

APPENDIX II
FULL TEXT MANAGEMENT COMMENTS ............................................................................29

iii

RESULTS AND RECOMMENDATIONS

1. Administration of the Department of Corrections Can Be More Efficient
Johnson County Department of Corrections administrators allowed the Adult and Juvenile
divisions to operate without coordination or integration of common administrative functions.
This organizational separation was exemplified by the lack of internal controls over medications,
inventory, security, and accounts receivable at the Adult division while there were excellent
controls over the same functions in the Juvenile division. Conversely, the Juvenile division’s
timekeeping system did not fully comply with County policy while the Adult division’s did.
Interviews with senior and key staff in both divisions disclosed there had been no meaningful
communication on management and control issues between them for many years. The missions
and outcomes of these divisions are different, but the core administration functions – payroll,
accounting, inventory, accounts receivable and timekeeping – are exactly the same in both
divisions and many of the other administrative functions have more similarities than differences.
The lack of communication and coordination between the two divisions led to errors, duplicated
efforts and practices, and unnecessary costs to the County.
Recommendations
We recommend the Director, Department of Corrections:
1.1

Review all common functions between the Adult and Juvenile divisions and merge them
into one where feasible. Candidates for merger would be:
a. Payroll
b. Human Resources
c. Inventory
d. Vehicle management
e. Time control
f. Accounts Receivable
g. Medication Administration

1.2

Ensure consistency in managing administrative functions between the two divisions.

1.3 Develop procedures and train managers and staff regarding newly consolidated
administrative functions.
1.4

Ensure that County and departmental policies, as well as state and federal laws and
regulations, are applied uniformly across the entire Corrections department.

Management Comments
It became clear to me from the beginning of my employment that the Department of Corrections
has not been operating in a unified manner. I have been strongly communicating my goal to staff

1

to operate as a whole department, rather than separate divisions. I understand that there are
many benefits from a unified department with numerous shared services.
We have already begun the process of unification in many areas. For instance, in June we
formed an employee committee of both Adult Residential Center Correctional Advisors and
Juvenile Detention Center Corrections Officers for the purpose of recommending a new
standardized work uniform for this group of staff. The committee completed its work in August by
providing detailed specifications for a new, standardized uniform. We anticipate that these staff
will be proudly wearing their new uniforms in November. The staff who participated on the
committee communicated frequently with other staff in making their recommendations, so the
employees feel much empowered by the entire process.
Recommendation 1.1:
I agree with the recommendation for centralization of the Human Resources functions, including
payroll and time control, and we have already proceeded with these changes. All Human
Resource issues must come through the Assistant Director, prior to action to ensure consistency
and compliance with County regulations. I must approve all formal disciplinary actions. We are
in the process of hiring a new Human Resources Coordinator who will be responsible for all
departmental recruitment; interview processes; employee relations; position descriptions; job
orders; use of leave/time control; monitoring of FMLA, EEO, Affirmative Action, and employee
turnover rates; risk management; Workers Compensation claims; position control; and
organizational charts. This position will also be responsible for monitoring the employee payroll
functions to ensure all are performed consistently and appropriately I should note that this
position is not a new position but one that was vacated recently. This allowed us the opportunity
to revise the position description for the more centralized processes prior to posting and filling
the position.
I understand that the Department’s inventory process must be consistent through all divisions.
There is already a centralized reporting system for all purchases of items in the department, but
it appears that employees need more training regarding the application of that system and more
active auditing of the items under the value of $10,000. We will ensure that inventory procedures
are communicated to appropriate staff and that the Department’s central office carefully
monitors this function.
We agree that the department’s vehicle management needs to be unified rather than divided
between two separate systems: juvenile and adult. We will centralize this function and
appropriately share vehicle resources as needed.
We recognize that there are significant issues in the area of accounts receivable. The Assistant
Director will work with a committee of employees from both juvenile and adult services to
develop appropriate procedures and internal controls for purchases, bill payments, and
reconciliation processes. We are currently working with JIMS to develop an accounts receivable
system to meet the department’s needs and ensure internal controls are met.

2

Medication administration bears the same issues and liability for both the Juvenile Detention
Center and the Adult Residential Center. Because of the differences of their facilities, however,
they cannot operate identically. We have, however, taken the administration of medications out
of the hands of the Correctional Advisors at the Adult Residential Center and contracted for
medical services with a correctional healthcare provider. The provider’s nurses are responsible
for inventory and delivery of the medications to the residents, similar to the process at the
Juvenile Detention Center.
Recommendation 1.2:
I fully agree with the need for consistency of administrative functions within the Department, and
we are actively proceeding in that direction as quickly as possible.
Recommendation 1.3:
I agree that appropriate procedures need to be developed to address the department’s
administrative functions, and we are proceeding as quickly with this as possible. As new
procedures are developed, we will ensure consistent training to affected staff.
Recommendation 1.4:
I continue to emphasize with all departmental staff that we will follow County regulations and
departmental policies. Employees have been told that if they believe that a policy or regulation
needs to be revised, then they should make recommendations for the changes; otherwise, the
rules will be followed. We continue to hold staff accountable for their failures to follow policies
and regulations. I believe that the department’s culture is improving in this regard and that staff
want to do what is right.
In the past few months, we have ensured that all employees in the department have access to
electronic mail on departmental computers. Prior to this time, their were numerous staff in the
Juvenile Detention Center that had no access to electronic mail This impeded our abilities to
communicate well with staff. We are now using electronic mail as well as staff meetings to
communicate better will all staff regarding departmental issues.
Discussion
The Department of Corrections’ mission is to “successfully integrate criminal offenders back
into society as productive, law-abiding members of the community.” Organizationally, the
department is divided into two major divisions—Adult Corrections and Juvenile Corrections.
Each division has a series of programs and detention processes to accomplish the Department
mission. The audit team examined the administrative functions between the two divisions to
determine if these functions were managed effectively and efficiently. These functions included
accounting, medication handling, inventory, payroll, accounts receivable and timekeeping.

3

Identical functions were managed differently at the two divisions
Adult Corrections management officials did not install appropriate management controls and
major administrative functions were left vulnerable to fraud, abuse and unauthorized activity.
Examples include:
•
•
•

Lack of control over medications inventory and administration (See page 6)
Lack of security for facility keys (See page 9)
Lack of consolidation and internal controls for accounts receivable (See page 11)

The Juvenile Corrections division did not have these problems because
Juvenile Division
controls were well developed and managed. They did, however,
could be used as
misinterpret the County payroll rules and allowed employees to take time
benchmark
off which should have been recorded as vacation or sick leave. With minor
changes due to differences in missions, the management and internal
controls at both divisions could be improved by communicating with each other and developing
best practices to enhance the entire organization.
Executive and senior management are responsible for ensuring effective management controls
over vulnerabilities in major programs. Our interviews disclosed that poor communication and a
lack of integration of programs caused the two divisions to operate differently regarding
management and internal controls over programs. Prior top level leadership did not cultivate an
environment of unity within the department and missed the opportunity to share lessons learned
between the two divisions. Interviews in the Adult Corrections division disclosed employees
were aware of some of the weaknesses but were unsuccessful in receiving management support
to fix them. At the entrance conference for this audit, the acting director of Adult Corrections
requested a review of medication controls.
New leadership can make the Department of Corrections more effective
We discussed the internal control weaknesses with the new department director and she began
making appropriate changes during the audit. She also requested a review of small tool inventory
practices. The director expressed a need to develop a “one department” approach to
management. As the director assesses the organization; we believe the following should be
evaluated:
•
•
•
•
•

Centralizing common administrative functions between the two divisions under one
administrative division or integrate and coordinate the activities of the administrative
functions
Transferring resources as needed to accomplish the administrative functions
Developing operating procedures for the administrative functions that apply to both
divisions
Training all managers and staff on the appropriate internal controls and administrative
procedures
Developing an empowering management culture

4

This may require cross training between departments, or focus groups and training sessions to
share common problems and ideas.
Detailed discussions on the internal control weaknesses are contained in the following sections
of the audit report.

5

2. Management Needs to Control Distribution of Medications
Medications at the Adult Residential Center (ARC) were vulnerable to misuse due to poor
medication controls. No distinction was made in policy or procedures between the handling of
common prescription medication and controlled substances. As a result, access to medications,
including controlled substances was widely available to all staff members. Medication inventory
counts, while taken daily, were regularly adjusted to actual counts. As a result, neither we nor
ARC staff could determine if medications were missing or stolen. Staff were not trained to
properly identify the medication given, or the resident receiving the medication, prior to
dispensing drugs, as required by state law. In violation of federal law, unused or canceled
prescriptions, including controlled substances, were routinely mailed to contacts of a resident’s
choosing. In contrast, medication controls at the Juvenile Detention Center (JDC) are more
thorough and designed to meet federal and state requirements for the handling of medication.
Recommendations
We recommend the Director, Department of Corrections:
2.1

Bring all medications to a central location within the Adult Residential Center and
establish a system of control and accountability.

2.2

Comply with federal and state requirements for the handling of medications, including
controlled substances.

2.3

Institute appropriate supervision for the handling of all medications and ensure those
dispensing medication have the required training and knowledge.

2.4

Use the system in place at JDC as a model, making changes as needed to account for the
differences between the facilities.

Management Comments
Based on your observations and report the following actions have been taken to address the
audit team’s concerns:
•
•
•
•

We have dedicated one centrally located medication room in the Programs Building,
where medication is kept and distributed to all residents.
We have contracted for medication distribution services with Prison Health (PHS). PHS
provides trained/qualified medical staff to administer and account for the medications of
all clients.
We now require that the only medication accepted for distribution at the Center be prepackaged in “bubble-pack” style.
Over the counter medications are no longer stored in the control centers or dispensed by
Corrections staff. They are administered by PHS staff from the dedicated medication
room.

6

•

Medication procedures have been established and implemented and have been
incorporated in our intake/orientation for new clients.
Discussion

JDC and ARC receive, store and distribute prescription medication, including controlled
substances. Controlled substances are pharmaceuticals identified by the United States Drug
Enforcement Administration (DEA) as high risk for abuse. DEA requires strict accounting and
record keeping for controlled substances from receipt to administration or destruction. These
requirements include storing controlled substances separately from other medications and
keeping accurate records of drug distribution.
ARC did not have appropriate controls over medications
Medication controls were not consistently applied at the two separate divisions. While JDC had
exemplary medication controls, ARC had little to no controls. ARC medications were stored on
carts in three separate buildings. Staff stored medications without distinguishing controlled
substances from other prescriptions. All correctional advisors and custodial staff had access to
the medications rooms within their assigned building. In addition, there was no formal inventory
of medication room keys. Federal and state law requires proper controls over medication
including separate storage of controlled substances and restricted access to appropriately
authorized individuals.
ARC staff routinely sent unused or canceled prescriptions to contacts of a resident’s choosing
through the United States Postal Service (USPS). According to USPS regulations Publication 52,
Chapter 48, Sections 482 and 483, such mailing is illegal. Staff expressed their discomfort with
this process but were not aware the practice violated any laws or regulations.
ARC staff who administer medications were not properly trained or supervised
ARC staff were not trained to properly identify medications or residents and the process was not
supervised by trained or knowledgeable personnel. Only one part-time nurse practitioner was
available, and she had no supervisory authority with respect to medications. ARC staff
distributed medicines throughout the day at designated times. Residents lined up in medication
call lines and received the container of their prescription from correctional advisors. There was
no procedure to positively identify the person receiving the medication. Instead, staff relied
solely on facial recognition. Residents were then instructed to self medicate and return the bottle
to the correctional advisor.
The correctional advisors were instructed to count the pills remaining and record the information
on a medication inventory sheet. Each night a medication count audit was taken and the total
compared to the inventory sheet. However, staff acknowledged if the count did not match, the
inventory was adjusted with little to no determination of the reason for the discrepancy. These
procedures were followed for all prescriptions regardless of their status as controlled substances.

7

In our interviews, ARC staff revealed concerns with the medication process and had expressed
them to previous Correction’s administrators. These concerns were repeatedly downplayed to the
point staff no longer felt comfortable bringing them to management’s attention.
JDC controls could be used as a benchmark
JDC used the services of a nursing contract agency to provide three registered nurses on staff 16
hours per day, 7 days per week. A qualified County Health Services Coordinator trained and
supervised contract service nurses. JDC followed detailed guidelines and procedures on the
receipt, storage and distribution of medication.
Access to a centralized medication room was highly controlled. Only on duty nursing staff, the
Health Services Coordinator and the Deputy Director had key access. Within the controlled
medical room, there was a locked medication closet. Within the closet, there was a separate
locked medication cabinet. All controlled substances were bubble packed to individual doses and
stored separately from other prescription medication. The medication room was institutionally
licensed by the Board of Pharmacy and received quarterly inspections.
Nursing staff dispensed medication to juveniles during regularly scheduled medication times. A
color coded dot system tracked individual medicine distribution schedules. Prior to delivery,
nursing staff divided medication into individualized doses. Nurses identified juveniles through
identity wrist bands and picture identification cards prior to dispensing medication. Residents
with medication allergies were required to wear red wristbands and all others wore white bands.
Nurses were instructed to remember the “5 Rights of Medication”:
1.
2.
3.
4.
5.

Right patient
Right time and frequency of administration
Right dose
Right route of administration
Right drug

New Director of Corrections takes action
We issued a Quick Reaction memorandum On April 13, 2007, to the new Director of Corrections
to provide for immediate corrective action. The director took immediate action and on May 29,
2007, announced plans to fund nursing coverage in conjunction with establishing medication
controls similar to those in place at JDC.

8

3. Management Needs to Improve ARC Key Control
There were no controls over permanently issued ARC building keys. Staff did not maintain an
inventory and did not have an accurate count of keys. Although there were procedures for
controlling keys from time of issuance to time of turn-in, they were not followed. As a result, the
facility was not fully secured and was at risk for:
•
•
•
•
•

Unauthorized access by former employees
Property theft
Unauthorized access to medication
Compromised safety of staff and clients
Compromised public safety

In contrast, key controls at JDC were more thorough, secure and designed to meet the needs of a
correctional facility.
Recommendations
We recommend the Director, Department of Corrections:

3.1

Establish a system of accountability and control over ARC keys commensurate with the
security requirements of the facility including:
• Placing the key control function at the level of a security officer
• Clearly establishing the responsibility for each key and the management of the key
control system
• Removing the ability of the maintenance staff to reproduce keys
• Establish an accountability system to ensure terminated employees relinquish keys
prior to their last day

Management Comments
During the course of the Johnson County audit of Corrections operations, it was brought to our attention
that key control at the Adult Residential Center (ARC) needed to be significantly improved.
Based on your observations and report, the following steps have been taken to address the audit team's
concerns and to ensure the safety and security of our facility, residents, staff, and the public.
•

We have designated one staff person to control facility keys. Currently we are using our
Executive Assistant in this role. We have, however, considered making this an Operations
function once the process is in place and some restructuring of operational staff is complete.

•

Each ARC staff person was provided a key control form and was instructed to inventory all
keys in his/her possession and the purpose/type of each key. From this, a spreadsheet was
created with staff names, keys in their possession, and the purpose of the keys.

9

•

In coordination with facility maintenance staff, each building key has been stamped with a
letter and corresponding number assigned to each staff member to better identify/track the keys
assigned to individual staff members.

•

The Key Controller has met with all staff to verify keys assigned and has re-issued numbered
keys to staff.

•

A master key log has been created for each housing unit and the programs building to identify
keys to file cabinets, desks, cubicle drawers/file cabinets, and fire alarm systems. This log will
be maintained to track keys being issued and keys returned or not returned.

Discussion
Effective key control is essential to the security of a correctional institution. Compromised key
control poses safety threats to staff, the public and inmates. Components of effective key control
are accountability and the control of the duplication of keys. 1 We met with representatives of
both ARC and JDC to discuss their key control systems.
ARC did not have effective control over facility keys
ARC did not maintain a list of building keys and did not have an accurate count of keys issued.
Permanently issued ARC building keys provide access to all exterior and most interior doors.
ARC Policy 03.10 states, “All keys will be inventoried on a quarterly basis the first week of each
month by the Key Inventory Controller or designee.” However, interviews with staff revealed the
correctional advisor previously assigned as the Key Controller never created or maintained an
inventory of keys. In addition, there is no accountability system to ensure terminated employees
relinquish keys prior to their last day.
JDC key controls were more secure
JDC key controls were thorough and well administered. The JDC Deputy Director of Operations
acts as the facility key controller. Each key is stamped with a security series number and an
individually assigned key number. Issued key documentation is kept on file along with a Key
Security Agreement all employees are required to sign. Unassigned keys are located in a secure
key box with restricted access. Keys are inventoried on a regular basis.
New Director of Corrections takes action
We issued a Quick Reaction memorandum On May 29, 2007, to the new Director of Corrections
to provide for immediate corrective action. The director took action to establish and enforce
adequate ARC key controls commensurate with the security and operational needs of the facility.

1

Prison and Jail Administration: Practice and Theory, Peter M. Carlson and Judith Garrett, Jones and
Barlett, 2005

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4. ARC Accounts Receivable System Needs Improvement
ARC accounts receivable system does not retain permanent records of amounts charged for
services or unpaid balances due to the County when the client is released from the facility.
Currently, ARC records charges and payments on individual Excel spreadsheets for each
resident. A copy of the spreadsheet is printed when the client leaves the system and the
electronic spreadsheet is deleted. In many cases the printed copy is not retained in the client file
as required by ARC procedures. No comprehensive receivable reports are prepared and
receivables are not totaled or reconciled. Consequently, Correction’s management is unable to
monitor, report on, or effectively collect receivables. As a result, revenue remains uncollected
and there is a substantial risk of theft or fraud.
Recommendations
We recommend the Director, Department of Corrections:
4.1

Establish an accounts receivable system complete with standard internal controls.

4.2

Reconcile receivables and create internal management reports complete with beginning
and ending account balances as well as detailed additions and subtractions.

4.3

Immediately stop the practice of deleting electronic ledgers upon a resident’s release.

4.4

Take appropriate steps to collect assessed fees prior to a resident’s release from the facility.

Management Comments
I fully agree that the ARC’s accounts receivable system needs to be completely revised.
Management is currently working with JIMS to determine if they can build an accounts
receivable system to meet Corrections Department needs and ensure internal controls are met.
Management will ensure that receivables are reconciled and that internal management reports
are created with beginning and ending account balances as well as detailed additions and
subtractions. Corrections stopped the practice of deleting electronic ledgers when a resident is
released immediately after we became aware of the problem. Corrections will implement a
process in which we will collect residents’ fees as much as possible prior to release from the
facility. We will also ensure that we have appropriate forwarding addresses to which collection
notices can be mailed for those offenders who do not have enough money to pay their fees prior
to leaving the facility.
Discussion
The main ARC objective is to reintegrate criminal offenders into the community as successful
and productive citizens. While sentenced to the facility, able residents are required to work or to
be actively seeking employment. Upon admission, each client is assigned to a Resource
Developer who provides orientation and pre-employment training and assistance if needed.

11

ARC clients are charged $13 dollars per day for room and board, laundry and transportation
services. Residents are also assessed additional charges for the actual cost of medication,
urinalysis tests, and program related fees. Residential case managers work with clients to prepare
a weekly budget, including the payment of all ARC fees assessed. Residents are required to have
all income and debts reviewed prior to the deposit of each paycheck. Case managers are required
to actively monitor adherence to prepared budgets.
In our review of the accounts receivable system, we examined account ledgers, interviewed ARC
staff including management and case managers and reviewed applicable policies and procedures.
County policy requires adherence to generally accepted accounting principles. These principles
require an adequate system of internal controls for management to ensure appropriate accounting
and compliance with management direction.
The accounts receivable system was not effective
The accounts receivable system failed to meet generally accepted accounting principles based on
weak internal controls and poor record keeping and reporting mechanisms. ARC administrative
secretaries maintained individual Excel spreadsheets created for each client in order to track fees
assessed and payments made. At the end of each week, case managers submitted a written
activity statement to administrative staff detailing weekly assessed charges and payments. The
administrative staff entered charges and payments into a client’s individual spreadsheet. At the
beginning of the following week, the spreadsheets were printed creating an account statement for
each client. These statements were given to the case managers. ARC staff did not combine the
individual spreadsheets to determine the aggregate amount due to Corrections. Therefore, the
accounts receivable balances were not reported or managed.
Account ledgers were missing
We examined files for 184 ARC clients who resided at the facility during 2006 to determine the
accounts receivable balance based on the client financial ledgers. The client ledgers were missing
from 18 percent of the files reviewed. In these cases, we were not able to determine total ARC
fees charged to, or payments collected from the clients. In addition, no electronic copies were
available to review because they were routinely deleted once a resident was released from the
Center. As a result we were not able to determine an accurate accounts receivable balance.
Fees assessed were not collected
Of the account ledgers we were able to review, 28 percent of the total fees charged were not
collected prior to a resident’s release. Uncollected ARC balances in our statistical sample totaled
$48,003. When projected upon the remaining population, this equates to an estimated yearly
uncollected balance of $181,203.

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5. ARC Fee Forgiveness Practices Need Re-evaluation
ARC did not consistently assess appropriate resident fees. There are no policies or procedures
governing the forgiveness of fees beyond the first 2 weeks of residency. In the absence of
policy, case managers waived additional fees based on their own perception of prevailing
circumstances. This contributed to an inconsistent and inequitable application of fee forgiveness
and resulted in a significant loss of revenue for ARC. In addition, case managers were collecting
resident Court Services fees, placing them unnecessarily in the loop of payments to the Court.
These payments occurred without proper internal controls needed to protect both Corrections
employees and ARC residents.
Recommendations
We recommend the Director, Department of Corrections:
5.1

Evaluate the purpose and effectiveness of resident fee waivers,

5.2

If management continues the practice of fee forgiveness, internal controls are needed
including:
•
•
•

Detailed fee forgiveness policies and procedures including specific conditions needed
to satisfy waiver criteria,
Active management analysis and oversight to ensure the equitable and consistent
application of forgiven fees,
Integrating the recording and tracking of forgiven fees into the accounts receivable
system in order to report on and account for waived revenue.

Management Comments
We are in the process of developing policies and procedures for fee collection and forgiveness
that will include specific conditions needed to satisfy waiver criteria. Management will be
responsible for analyzing and oversight to ensure equitable and consistent forgiveness of fees,
only in rare instances as appropriate. Management will ensure that the recording and tracking
of forgiven fees are integrated in the new accounts receivable system. In order to provide a more
immediate resolution, we have implemented a process in which each fee forgiven must be
approved by the Director of the Adult Residential Center prior to forgiving the fee. Also, case
managers can no longer accept payments. All payments must be received through the Mall
Control area.
Discussion
ARC waives the first 2 weeks of a resident’s rent and boarding fees per Corrections policy.
There are however no written policies concerning the waiving of additional fees. ARC does not
track or report aggregate total fees forgiven. In the absence of policy or management oversight,
there are no internal controls to ensure appropriate compliance with management direction.

13

ARC Fee waivers were significant
We examined a statistical sample of 184 files of clients who resided at the facility during 2006.
We reviewed financial ledgers to calculate waived ARC fees. Client ledgers were missing from
33 files (18%) of those reviewed. In these cases, we were unable to determine the total fees
waived. Table 5.1 shows the impact of these waivers.
Table 5.1: Impact of Fee Waivers
Fees Waived
Sample
Projected
Items
Yearly

Waiver Type
Standard First 2 Weeks

$26,008

$98,176

Additional Waivers

$24,234

$93,308

Total

$50,242

$191,484

Source: Audit analysis of a selected sample of account ledgers

Additional fee waivers were granted inequitably
In the absence of written policy, case managers and senior case managers developed fee waiver
criteria based on their perceptions of a resident’s prevailing financial circumstance.
The sample revealed these additional waivers were granted inconsistently and inequitably. While
one case manager forgave fees in 92 percent of assigned cases, two others granted no additional
waivers. The difference in case managers presented in Graph 5.1 demonstrates the need for
detailed written policy in conjunction with active management review and oversight of the fee
waiver process.
Graph 5.1: Comparison of Case Manager Waiver Activity
% of Cases Additional Waiver Is Granted

% of Cases w/ Additional Waiver

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
1

2

3

4

5

6

7

8

9

10

11

12

13

14

Case Manager

Source: Audit analysis of a selected sample of account ledgers

14

Case managers unnecessarily collect court payments
Prior to July 2006, clients were able to make ARC payments to virtually any available
Corrections employee, including correctional advisors, case managers and residential supervising
officers. Residents are now required to make payments at the centrally located Mall Control area
within ARC. This change protects Corrections staff by removing them from the cycle of
payments. However, interviews with staff revealed many continue to accept resident payments
of Court Services fees. Once accepted, the case manager places the payment into a sealed
envelope and sends it through County interoffice mail to Court Services. This practice places
case managers unnecessarily at risk by placing them once again in the cycle of resident
payments.

15

6. Management Can Improve Delinquent Fee Collections
By Corrections policy, ARC residents who fail to pay fees for a continuous period of 60 days
may have their accounts referred to a collection agency for recovery. However, the files
reviewed lacked clear documentation regarding what information is sent to the collection agency,
who sent it, and when they sent it.
Corrections did not actively monitor the delinquent fee collections process. Management did not
request or receive regular, detailed reports from the contracted collection agency. As a result,
staff did not review balances assigned or collected. The collection agency contract had not been
evaluated for a number of years. Cost effective collections alternatives such as the State of
Kansas Setoff Program, were not considered. Corrections collection policies were vague,
contributing to a potentially inequitable referral process. Weak policies, a failure to analyze and
evaluate the collections process, and the failure to determine accounts receivable balances may
have resulted in loss of revenue recovery and contributed to the undermining of the collections
process.
Recommendations
We recommend the Director, Department of Corrections:
6.1 Actively monitor and continually evaluate the delinquent fee collections process by:
• Maintaining accurate accounts receivable balances
• Requesting and analyzing regular, detailed reports of referred and collected balances,
• Annually reviewing and evaluating third party collections agency contracts,
• Have all collections contracts reviewed by County Legal staff.
6.2 Seek cost effective alternatives to delinquent fee collections such as the State of Kansas
Setoff Program or assistance from the County Treasurer collections services.
6.3 Create collections management policies that mitigate inequities and maximize returns by
clearly establishing specific and direct criteria for the delinquent accounts referral process.
Management Comments
Improvement of this process is directly linked to the revamping of the accounts receivable
system. Management will actively monitor and evaluate the entire collections process. We will
maintain accurate accounts receivable balances. We will request and analyze regular detailed
reports of referred and collected balances. We will annually review and evaluate third party
collections agency contracts and have all collections agency contracts reviewed by the County’s
legal staff. We will look at all cost effective alternatives to delinquent fee collections, including
the State’s Setoff Program. We will develop appropriate collections management policies. Our
overall goals will be to maximize our returns through aggressive collections practices and to
cease inequities in the process.

16

Discussion
During the course of the audit we reviewed the policies, procedures and practices concerning the
collection of delinquent client fees. Good collections management practices are components of
effective internal controls. These controls contribute to an effective organization and help ensure
compliance with management direction.
Collections policies were vague
Corrections debt referral policy 07.25 8(a) states:
“Should a client fail to pay program fees as directed for a continuous period of 60 days,
incurred balances may be forwarded to the contracted collection agency for recovery”.
The use of the word “may” leaves opportunity for increased discretion from those making
collections referral decisions. This combined with the absence of clear, specific criteria creates
increased potential for the inequitable referral of delinquent accounts. Amending the policy to
include direct language such as “shall” would convey that the referral of delinquent accounts is
the rule and not the exception.
Collection agency contracts were not actively reviewed
Contract agreements between Corrections and a third party collections agency had not been
reviewed for a number of years. The current ARC agreement was signed in May of 2000 and has
subsequently been automatically renewed without any documented evidence of management
reevaluation. JDC contractual agreement was signed in November of 2003 and has also been
automatically renewed each subsequent year.
These contractual agreements consisted of one page documents composed by the collection
agency. Department contractual agreements should be reviewed by County Legal staff to ensure
the inclusion of standard built in protections to County interests.
Collection activity reports were not requested or received
Prior to the audit, the department never requested or received a detailed list of referred collection
activity including: client name, balance referred, total recovered, and account status. Upon
request, this information was available from the collection agency and they were willing to
provide it regularly. Review of this information could be used as a collections management tool
and could assist management in evaluating the effectiveness of the collections process.
Cost effective collections alternatives could be explored
Alternative or complimentary programs could potentially improve the collections process. For
example, the State of Kansas Setoff Program allows participating state agencies, municipalities
and district courts to set off moneys the State of Kansas owes debtors against moneys owed to
the State of Kansas. Debts are matched to income tax refunds, state payroll, unclaimed property

17

and other miscellaneous payments including state lottery payoffs. Participants keep control of
referred accounts and the fee charged for the service is considerably less than standard collection
agency fees.

18

7. JDC Application of Paid Time-Off Needs Improvement
The department administered Paid Time-Off (PTO) differently between ARC and JDC. A lack of
communication or coordination between the two major divisions created an environment in
which two separate applications of PTO developed. ARC accounted for and paid employees for
all scheduled leave, regardless of hours regularly worked. In contrast, when a JDC employee
worked over 40 hours and took paid leave during that week, for example, 44 hours on the time
sheet including 40 hours worked and 4 hours vacation, payroll representatives adjusted the
employees paid time off so only 40 hours was paid during the week and no vacation was
charged. JDC adjustment of PTO is inconsistent with County policy requiring accounting for
scheduled time off.
Recommendations
We recommend the Director, Department of Corrections:
7.1 Ensure JDC accounts for all scheduled Paid Time Off appropriately and consistent with
County policy.
Management Comments
We changed the practice that was taking place at the JDC immediately after learning about the
discrepancies between the JDC and ARC. We announced the appropriate method of reporting
leave to all staff in the department and learned that many of the department’s case managers and
field staff were also reporting leave incorrectly. All employees are now aware of the changes,
and management is monitoring the process carefully to ensure consistent and appropriate
application.
Discussion
We reviewed 263 timesheets from the department, 152 from ARC and 111 from JDC. We
observed ARC charged PTO, vacation and sick leave, when an employee had worked 40 hours
or more during the work week. JDC did not use this method.
We reviewed this process with County legal counsel. Their opinion was the employee’s
scheduled hours need to be accounted for. If an employee is not available during a time when he
or she is scheduled to work, some form of PTO must be recorded for that period whether or not
the employee subsequently, or previously, works additional, unscheduled time in that day or
work week.
For example, an employee scheduled to work from 8 to 5 M-F schedules vacation for Monday
from 8 to 5. If the employee works on Saturday in that week from 8 to 5 at the request of his or
her supervisor, 8 hours of vacation would be charged and 48 hours would be paid. No overtime
would be accrued because there are 40 hours of work time and 8 hours of time off.

19

8. Management Can Improve Purchasing Efficiency
Management can improve purchasing efficiency by more effectively using the County
Purchasing Card (P-Card) program. Corrections ranked last among all County departments in the
percentage of purchases made via P-Cards. Management did not effectively delegate purchasing
responsibility to subordinate staff or take the responsibility of managing the P-Card System. As
a result, the department purchasing process was inefficient and potential savings were not
realized.
Recommendations
We recommend the Director, Department of Corrections:
8.1

Use the Office of Financial Management established purchasing criteria which encourages
the use of P-Cards as the preferred method of payment for a majority of purchases under
$10,000,

8.2

Delegate purchasing responsibilities to subordinate staff while actively managing and
monitoring the purchasing process.

Management Comments
When the department learned about its failure to use P-Cards as much as possible, we issued 12
additional P-Cards and have instructed appropriate staff to utilize the P-Cards. As of September
2007, we had already increased our P-Card usage rate by 26% over 2006 and had incurred 196
transactions more than last year. In September 2007, the Corrections Department was the 15th
highest user of P-Cards of all County departments. In September 2007, we had achieved a 40%
to 60% P-Card to Purchase Order Ratio. Staff will continue to review purchases and determine
if additional cards are needed and will continue to delegate purchasing responsibilities to
subordinate staff while actively managing and monitoring the purchasing process.
Discussion
County departments and agencies are obligated to follow County expenditure policies and
procedures. When possible, County guidelines encourage the use of P-Cards as an efficient
means to reduce the processing cost of procuring goods and services.
Opportunities exist to improve efficiency
According to the County Office of Financial Management (OFM), the transaction cost for
Purchase Orders (POs) under $10,000 is $91.13. In contrast, costs for P-Card transactions are
significantly less, at $21.79 per transaction. This represents a potential savings of $69.34 on
every transaction conducted with a P-Card instead of a PO. For this reason, OFM established a
goal to achieve an 80/20 P-Card to PO use ratio Countywide.

20

In 2006, Corrections had the lowest percentage of P-Card transactions of any County
department. Corrections P-Card use for transactions under $10,000 was 24 percent, in contrast to
the County average of 67 percent. If Corrections increased P-Card use to County average levels,
audit analysis revealed a potential transaction cost savings of $68,691 per year.

Table 8.1 Breakdown of 2006 P-Card Use V. Purchase Orders
Average County
Department of
Transaction Type
Department %
Corrections %
P-Card
67
24
Purchase Order
33
76
100
100
Source: OFM Purchasing Activity Report & Audit Services Analysis

21

9. The Department Could Benefit From Centralized Accounting Policies and Procedures
The department did not have centralized comprehensive financial accounting policies or
procedures. The lack of a written centralized accounting policy or procedures created an
environment in which ARC and JDC developed their own written and unwritten accounting
procedures. As a result, there are accounting inconsistencies between the separate divisions of
the department.
Recommendations
We recommend the Director, Department of Corrections:
9.1 Develop centralized, comprehensive financial and accounting policies and procedures.
Management Comments
We agree that centralized accounting policies and procedures are necessary and have begun
working on these policies. Our goal is to have the policies and new systems in place by spring
2008.
Discussion
Generally accepted accounting principles require an adequate system of internal controls for
management to ensure appropriate accounting and compliance with management direction.
Clear, written and centralized accounting policies and procedures are a component of good
internal controls. Corrections did not have centralized, comprehensive financial and accounting
policies and procedures. Interviews with staff revealed frustration with this condition, which they
believed was a product of turnover and instability within the Administrative division of the
department. In the absence of centralized policies, each division developed their own written and
unwritten financial and accounting procedures.

22

10. The Performance Measurement System Could be More Effective
The performance goals and measures submitted in County Budget documents lacked clarity and,
in some cases, measurability. Key terms and intentions used in the goals were not defined clearly
to make the measured result useful. In some cases, any achievement satisfied the goal. In one
instance, the outcome data reported was in error. We attributed the cause for this condition to a
lack of understanding of the clarity needed in defining goals and measuring performance to
obtain a useful outcome. As a result, outcome measures as reported in the budget did not produce
meaningful assessments of program activity.
Recommendation
We recommend the Director, Department of Corrections:
10.1 Reassess the current performance goals and measures and develop goals that specifically
describe the outcome desired and develop specific performance measures to measure the
outcomes and goal achievements.
Management comments
We have reviewed the Performance Goals and Measurements and plan to modify the stated
performance measures in 2008. Prior to that time, the department’s vision and mission
statements will be modified and as an extension of that process, new goals and better
measurements of those goals will be established. Many of the stated goals did not directly
correlate with meaningful outcome measurements. Additionally, the Kansas Department of
Corrections is implementing statewide initiatives to reduce the number of probationers who are
remanded to the custody of the Secretary of Corrections due to probation condition violations.
The statewide measurements will be incorporated into the local goals and measurements.
Discussion
The objective of establishing performance goals and measures is to
evaluate progress, success or failure of programs. The goals set the targets Specific goals set
organization
for the organization—targets that are deemed to be the most important
targets
points of concentration for the managers. These goals must be clearly
stated so progress can be measured and course changes made as needed to
keep the organization moving in the appropriate direction. Performance measures must be
precise and relevant to the performance goal. These measures must provide the data necessary to
determine progress for achieving the goals.
Performance goals were not well-defined
Many of the performance goals did not have sufficient definitions of the terms used in the goals.
Consequently, measures of these goals could not be effective. For example:

23

Goal:

Successfully discharge a high percentage of adult felony offenders from
JOCO corrections programs

Measure:

Increase the percentage of adult felony offenders who are successfully
discharged without serving their controlling sentences.

Outcome:

The reported outcome for this measure was 80 percent discharged in 2002
and 2004 and 61 percent discharged in 2006 and an estimated 63 percent
discharged for 2007.

The term “high percentage” is not defined. What percentage range equals
normal? What range signifies “high”? The performance measure does not
match the definition of the goal. The performance measure is not calling
for a “high percentage” of successfully discharged offenders, only an
increase in percentage. Without a definition of “high percentage” any
percentage increase could be claimed a successful outcome.

Define “high
percentage”

Since the definitions are not clear, the interpretation of the results is also unclear. Although the
reported outcomes show a significant decrease in percentage (19%) between 2004 and 2006,
there is no way to determine if the outcomes are good or bad. One could say one is better than
the other, but did the department meet the goal? Perhaps the 80 percent and 61 percent are both
considered “high percentage”. Perhaps neither is considered “high percentage”.
In response to our inquiry, the Director stated:
The 80% success rates for 2002 and 2004 appear inaccurate and the method utilized to
determine those rates is unknown. According to the information collected from the Total
Offender Activity Documentation System (TOADS), the percentage of felony offenders who
successfully discharged from department programs in 2004 was 54%.
The percentage increase will be modified to reflect realistic increases over time with
consideration given to the statewide initiative which will provide funding to decrease the number
of offenders sent to prison for technical violations in FY2006 by 20% (during FY2008 and
FY2009).
In another example, the goal for a series of corrections case management programs is to ensure
case manager/client ratio of 1:15, 1:20 etc. The term “ensure” means guarantee. This is not an
effective expectation. The department has no control over the number of population served and
only has a set level of resources. A population increase may affect the actual ratio by adding
more cases to the case managers. A population decrease may affect the ratio by having fewer
cases per case manager. The overall outcome to satisfy the goal is a resource outcome—increase
or decrease which is driven by the population numbers. While the department can always reduce
resources, it may not be able to acquire additional resources to meet population surges. As a
result the goal is not achievable.

24

In response to our inquiry, the Director stated:
This measurement will be modified or eliminated in 2008 as it is not a meaningful measurement
of productivity or cost effectiveness.

25

11. Ethics Violations Were Not Reported
During 2003 to 2005, two members of the family of a Correction’s employee were assigned to
the supervision of ARC. Normal operating procedures were not followed for these two
individuals. Not all required fees were collected, unpaid fees were not referred to collections, and
records related to these individuals were not maintained in compliance with policy. Management
was able to override the policy and controls used to manage clients. In addition, other members
of Corrections staff were aware of these conditions and did not report them.
Recommendations
We recommend the Director, Department of Corrections:
11.1

Provide training to staff to emphasize their responsibility to report violations of ethics
policies.

11.2

Modify the ethics policy to indicate how to report violations outside the organization
when necessary.

Management Comments
We agree that ethical violations must be reported. In my initial meetings with all staff of the
department in April and May, I emphasized that any staff violations of policies or other
misconduct must be reported immediately to a supervisor. I told staff that such violations would
not be tolerated and that all employees were obligated to report, that they could not just “look
the other way.” I believe that we have created a culture of integrity and openness so that staff
will feel comfortable in reporting violations. We will revise our Ethics policy to ensure that staff
know to whom they can report violations when they are not comfortable reporting the
information to Departmental administrators.
Discussion
The department policy “Ethics - Conflict of Interest,” which is based on the Johnson County
Code of Ethics, states, in part:
•
•
•
•

No staff member will act in his/her official capacity in any matter in which he/she has
personal interest that could in the least degree impair his/her objectivity.
No staff member shall give gifts, favors, or services to a client, client’s family, or
close associate.
Each staff member will report without reservation any corrupt or unethical behavior
which could affect either a client or the integrity of the organization.
Staff members will have only professional relationships with clients while in the care
and custody of Johnson County.

26

APPENDIX I
OBJECTIVES, SCOPE AND METHODOLOGY
Objectives
Our objectives were to review financial and management controls over major functions of the
Department and to determine compliance with county policy and Kansas law along with the
following additional areas:
•
•
•
•
•
•
•
•

Review organizational structure
Identify management and accounting structures for reporting and financial transactions
Identify programs
Evaluate the effectiveness of management and accounting controls
Follow-up on results of prior Corrections internal audit reports
Review transactions in AP, P-Card, and expense reimbursements for 2005 and 2006
Small asset inventory review
Review compliance with county policy and Kansas law

Background
The audit was selected because of a transition in the leadership of the Department. The
Department of Corrections provides various degrees of detention programs for individuals
referred through the court system.
Johnson County Corrections has two main management divisions, Adult and Juvenile Services,
and central management functions that support both divisions. Adult Services manages the Adult
Residential Center (ARC) in Gardner as well as other Adult offender programs, such as house
arrest. Juvenile Services maintains the Juvenile Detention Center (JDC), has oversight
responsibility for the Juvenile Intake and Assessment Center (JIAC), and operates other
programs, such as house arrest.
The central management functions include the directors’ office and financial management.
There have been two internal audit reports issued concerning the Corrections department. One
concerned the JIAC facility and the other dealt with specialized funds managed by Corrections
such as the Client Reimbursement Fund.
Scope and Methodology
To accomplish the audit objectives the auditors:
•
•
•
•
•
•

Obtained copies of financial records
Interviewed Corrections staff
Toured Corrections facilities
Reviewed Trial balances for 2004 to 2006
Tested payroll transactions
Reviewed employee timesheets
27

APPENDIX I
•
•
•
•
•
•
•
•
•
•

Reviewed drug handling procedures
Used statistical sampling to test application of fee waivers and collections
Tested small asset inventory
Tested capital inventory
Analyzed purchasing card activity
Analyzed space use plans including waiting list data
Reviewed cash tracking by documenting process from billing to cash deposit
Benchmarked correctional facility user fees
Consulted with Legal Counsel
Reviewed appropriate State laws and Federal regulations

We analyzed the department’s financial operations, policies and procedures, and internal controls
and developed our conclusions and recommendations based on the materials gathered and results
of this analysis.
The audit scope was impaired by the inability to obtain records for part of our review of inmate
accounts receivable. Eighteen percent of the files included in our statistical sample were
destroyed leaving no record of what was paid or owed by inmates who were released from
Corrections programs. The impact on our audit was the inability to give a precise analysis of
outstanding fees owed the Department of Corrections. Consequently neither we nor the
Department of Corrections knows the status of accounts for some discharged inmates.

28

APPENDIX II
FULL TEXT MANAGEMENT COMMENTS

DATE:
TO:

October 25, 2007
William D. Miller, County Auditor

FROM: Elizabeth Gillespie, Director Department of Correc
SUBJECT: Response to Internal Audit Results and Recommendations
The audit of the Department of Corrections commenced very shortly after I began my
employment with Johnson County. I was pleased to see that the audit was taking place so quickly
following the transition in leadership of the department. The practice of auditing operations
following this type of change has been very beneficial for all concerned but especially so for me
as I have been leading the establishment of goals and priorities for the department.
Department of Corrections staff appreciated the manner in which the audit was conducted. Your
staff were very considerate of the employees’ needs to continue their normal work while they
were retrieving materials that your staff requested. I also appreciate your taking the time to
update administrative staff about significant problems as they were discovered. We were
obviously able to begin correcting those situations immediately.
I also want to say that the Department of Corrections has many dedicated, hard working
employees who have committed themselves to working with offenders to help them succeed.
They are very proud of their accomplishments. Perhaps some of the issues that have surfaced
through this audit reflect the fact that the staff have been focused on their goals of offender
behavioral changes with not enough attention to infrastructure. They are learning that there are
many other areas in which they need to focus their attentions too, and they are working hard to
make necessary improvements.
I will address each of the results/recommendations provided as follows:
1. Administration of the Department of Corrections Can Be More Efficient
It became clear to me from the beginning of my employment that the Department of Corrections
has not been operating in a unified manner. I have been strongly communicating my goal to staff

29

APPENDIX II
to operate as a whole department, rather than separate divisions. I understand that there are many
benefits from a unified department with numerous shared services.
We have already begun the process of unification in many areas. For instance, in June we formed
an employee committee of both Adult Residential Center Correctional Advisors and Juvenile
Detention Center Corrections Officers for the purpose of recommending a new standardized
work uniform for this group of staff. The committee completed its work in August by providing
detailed specifications for a new, standardized uniform. We anticipate that these staff will be
proudly wearing their new uniforms in November. The staff who participated on the committee
communicated frequently with other staff in making their recommendations, so the employees
feel much empowered by the entire process.
Recommendation 1.1:
I agree with the recommendation for centralization of the Human Resources functions, including
payroll and time control, and we have already proceeded with these changes. All Human
Resource issues must come through the Assistant Director prior to action to ensure consistency
and compliance with County regulations. I must approve all formal disciplinary actions. We are
in the process of hiring a new Human Resources Coordinator who will be responsible for all
departmental recruitment; interview processes; employee relations; position descriptions; job
orders; use of leave/time control; monitoring of FMLA, EEO, Affirmative Action, and employee
turnover rates; risk management; Workers Compensation claims; position control; and
organizational charts. This position will also be responsible for monitoring the employee payroll
functions to ensure all are performed consistently and appropriately. I should note that this
position is not a new position but one that was vacated recently. This allowed us the opportunity
to revise the position description for the more centralized processes prior to posting and filling
the position.
I understand that the Department’s inventory process must be consistent through all divisions.
There is already a centralized reporting system for all purchases of items in the department, but it
appears that employees need more training regarding the application of that system and more
active auditing of the items under the value of $10,000. We will ensure that inventory procedures
are communicated to appropriate staff and that the Department’s central office carefully monitors
this function.
We agree that the department’s vehicle management needs to be unified rather than divided
between two separate systems: juvenile and adult. We will centralize this function and
appropriately share vehicle resources as needed.
We recognize that there are significant issues in the area of accounts receivable. The Assistant
Director will work with a committee of employees from both juvenile and adult services to
develop appropriate procedures and internal controls for purchases, bill payments, and
reconciliation processes. We are currently working with JIMS to develop an accounts receivable
system to meet the department’s needs and ensure internal controls are met.

30

APPENDIX II
Medication administration bears the same issues and liability for both the Juvenile Detention
Center and the Adult Residential Center. Because of the differences of their facilities, however,
they cannot operate identically. We have, however, taken the administration of medications out
of the hands of the Correctional Advisors at the Adult Residential Center and contracted for
medical services with a correctional healthcare provider. The provider’s nurses are responsible
for inventory and delivery of the medications to the residents, similar to the process at the
Juvenile Detention Center.
Recommendation 1.2:
I fully agree with the need for consistency of administrative functions within the Department,
and we are actively proceeding in that direction as quickly as possible.
Recommendation 1.3:
I agree that appropriate procedures need to be developed to address the department’s
administrative functions, and we are proceeding as quickly with this as possible. As new
procedures are developed, we will ensure consistent training to affected staff.
Recommendation 1.4:
I continue to emphasize with all departmental staff that we will follow County regulations and
departmental policies. Employees have been told that if they believe that a policy or regulation
needs to be revised, then they should make recommendations for the changes; otherwise, the
rules will be followed. We continue to hold staff accountable for their failures to follow policies
and regulations. I believe that the department’s culture is improving in this regard and that staff
want to do what is right.
In the past few months, we have ensured that all employees in the department have access to
electronic mail on departmental computers. Prior to this time, their were numerous staff in the
Juvenile Detention Center that had no access to electronic mail This impeded our abilities to
communicate well with staff. We are now using electronic mail as well as staff meetings to
communicate better will all staff regarding departmental issues.
2. Management Needs to Control Distribution of Medications
As already stated within your report, this problem has been satisfactorily addressed. The
County’s contract for offender medical services for the Adult Detention Centers and the
Department was recently re-bid. A new provider, Correct Care Solutions, will assume
responsibility on January 1, 2008. We have ensured that appropriate medication management
staffing and procedures will be continued at both the Adult Residential Center and the Juvenile
Detention Center with the new contract.

31

APPENDIX II
3. Management Needs to Improve ARC Key Control
As already stated within your report, we have addressed this problem and have established and
implemented an effective key control policy at the Adult Residential Center.
4. ARC Accounts Receivable System Needs Improvement
I fully agree that the ARC’s accounts receivable system needs to be completely revised.
Management is currently working with JIMS to determine if they can build an accounts
receivable system to meet Corrections Department needs and ensure internal controls are met.
Management will ensure that receivables are reconciled and that internal management reports are
created with beginning and ending account balances as well as detailed additions and
subtractions. Corrections stopped the practice of deleting electronic ledgers when a resident is
released immediately after we became aware of the problem. Corrections will implement a
process in which we will collect residents’ fees as much as possible prior to release from the
facility. We will also ensure that we have appropriate forwarding addresses to which collection
notices can be mailed for those offenders who do not have enough money to pay their fees prior
to leaving the facility.
5. ARC Fee Forgiveness Practices Need Re-evaluation
We are in the process of developing policies and procedures for fee collection and forgiveness
that will include specific conditions needed to satisfy waiver criteria. Management will be
responsible for analyzing and oversight to ensure equitable and consistent forgiveness of fees,
only in rare instances as appropriate. Management will ensure that the recording and tracking of
forgiven fees are integrated in the new accounts receivable system. In order to provide a more
immediate resolution, we have implemented a process in which each fee forgiven must be
approved by the Director of the Adult Residential Center prior to forgiving the fee. Also, case
managers can no longer accept payments. All payments must be received through the Mall
Control area.
6. Management Can Improve Delinquent Fee Collections
Improvement of this process is directly linked to the revamping of the accounts receivable
system. Management will actively monitor and evaluate the entire collections process. We will
maintain accurate accounts receivable balances. We will request and analyze regular detailed
reports of referred and collected balances. We will annually review and evaluate third party
collections agency contracts and have all collections agency contracts reviewed by the County’s
legal staff. We will look at all cost effective alternatives to delinquent fee collections, including
the State’s Setoff Program. We will develop appropriate collections management policies. Our
overall goals will be to maximize our returns through aggressive collections practices and to
cease inequities in the process.

32

APPENDIX II
7. JDC Application of Paid Time-Off Needs Improvement
We changed the practice that was taking place at the JDC immediately after learning about the
discrepancies between the JDC and ARC. We announced the appropriate method of reporting
leave to all staff in the department and learned that many of the department’s case managers and
field staff were also reporting leave incorrectly. All employees are now aware of the changes,
and management is monitoring the process carefully to ensure consistent and appropriate
application.
8. Management Can Improve Purchasing Efficiency
When the department learned about its failure to use P-Cards as much as possible, we issued 12
additional P-Cards and have instructed appropriate staff to utilize the P-Cards. As of September
2007, we had already increased our P-Card usage rate by 26% over 2006 and had incurred 196
transactions more than last year. In September 2007, the Corrections Department was the 15th
highest user of P-Cards of all County departments. In September 2007, we had achieved a 40%
to 60% P-Card to Purchase Order Ratio. Staff will continue to review purchases and determine if
additional cards are needed and will continue to delegate purchasing responsibilities to
subordinate staff while actively managing and monitoring the purchasing process.
9. The Department Could Benefit from Centralized Accounting Policies and Procedures
We agree that centralized accounting policies and procedures are necessary and have begun
working on these policies. Our goal is to have the policies and new systems in place by spring
2008.
10. The Performance Measurement System Could be More Effective
As we already reported, we plan to modify the performance measures in 2008.
11. Ethics Violations Were Not Reported
We agree that ethical violations must be reported. In my initial meetings with all staff of the
department in April and May, I emphasized that any staff violations of policies or other
misconduct must be reported immediately to a supervisor. I told staff that such violations would
not be tolerated and that all employees were obligated to report, that they could not just “look the
other way.” I believe that we have created a culture of integrity and openness so that staff will
feel comfortable in reporting violations. We will revise our Ethics policy to ensure that staff
know to whom they can report violations when they are not comfortable reporting the
information to Departmental administrators.

33