2022 Special Districts Bulletins
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Appropriation of Federal and State Funds
Appropriations - Transfer Between Major Budget Classifications
IC 5-3-1-3.5 provides that each district fiscal officer shall have published an annual report of the receipts and expenditures of such district within 60 days after the close of each calendar year.
IC 5-11-1-4 requires such reports to be filed electronically on the Gateway portal with the State Board of Accounts no later than sixty (60) days after the close of the year.
Fiscal Officers are no longer required to mail a signed hardcopy of the Attestation Statement of the State Board of Accounts. The Attestation Statement submitted electronically with the AFR is sufficient.
The Cash and Investments Combined Statement of the annual report is to be published one time in two newspapers unless there is only one newspaper in the district, in which case publication in the one newspaper is sufficient. If no newspaper is published in the district, then publication is to be made in a newspaper published in the county in which the district is located and that circulates within the district.
The Cash and Investments Combined statement to be advertised is located in the Annual Report Outputs section under Advertising Outputs.
PLEASE NOTE that the requirement to publish the Combined Statement of the annual report in the newspaper(s) is applicable only to those districts with the power to levy a tax and with an annual budget of more than $300,000. However, the completion of the Annual Financial Report in Gateway is a requirement for all districts.
The Department of Local Government Finance may not approve the budget or a supplemental appropriation of a district until the annual report is filed for the preceding calendar year.
APPROPRIATIONS OF FEDERAL AND STATE FUNDS
When funds are provided by the federal government either directly to or through a state agency for any program or project, the following procedures should be followed:
Advance Grants. Advance grants should be handled as follows:
- Where funds are “advanced” directly by the federal government for a specific purpose prior to making any disbursements, the money should be placed in a separate project fund and disbursements subsequently made from that fund. No appropriation of the federal funds is required.
- Where federal funds are “advanced” through a state agency or department with no state funds added thereto prior to making any distributions, the money should be placed in a separate project fund and subsequent disbursements made from that fund. No appropriation of the federal funds is required.
- Where federal funds are “advanced” by a state agency or department and state funds are included along with the federal funds in one check or voucher and the funds are for a specific purpose, the money should be placed in a separate project fund and disbursements made from that fund. Appropriation(s) must be obtained for the combined total (i.e., federal and state) prior to any disbursement being made from that project fund.
Reimbursement Grants. Reimbursement grants should be handled as follows:
Where a federal or state grant provides for payments to be made directly on a “reimbursement” basis after payment of expenses, the entire amount of the federal or state reimbursement may be appropriated by the district board without using the additional appropriation procedures under IC 6-1.1-18-5, if the funds are provided or designated by the state or the federal government as a reimbursement of expenditures. [IC 6-1-1.1-18-7.5].
No separate fund for the project or program is required unless the terms of the grant require one. Matching Grants.
Matching Grants should be handled as follows:
When a federal grant or program requires expenditures or “matching” funds to be provided from district funds, an appropriation must be obtained for the amount of such expenditures or local matching funds. Individual program requirements will dictate whether the appropriation should be obtained within the applicable district fund for expenditures there from or whether an appropriation should be obtained within the applicable district fund for a transfer to a required separate fund. This matter should be set out in the terms and conditions entered into between the district officials of the federal agency.
Summary. To summarize, no appropriations of federal funds are necessary:
- when advanced directly from the federal government for a specific purpose prior to making disbursements, and the money is placed in a separate project fund with disbursements made from that fund; or
- when federal funds are received in advance through a state agency for a specific purpose prior to making disbursements and the money is placed in a separate project fund with disbursements made from that fund and there is no state match.
Please keep in mind, if a district wishes to obtain an appropriation for all funds to be spent (i.e., federal, state, and local), there is certainly no prohibition in state statutes.
APPROPRIATIONS - TRANSFER BETWEEN MAJOR BUDGET CLASSIFICATIONS
Political Subdivisions With Departmentalized Budget
Indiana Code 6-1.1-18-6 states:
“(a) The proper officers of a political subdivision may transfer money from one major budget classification to another within a department or office if:
- they determine that the transfer is necessary;
- the transfer does not require the expenditure of more money than the total amount set out in the budget as finally determined under this article; and
- the transfer is made at a regular public meeting and by proper ordinance or resolution. (b) A transfer may be made under this section without notice and without the approval of the department of local government finance.”
Political Subdivisions Without Departmentalized Budget
Indiana Code 6-1.1-18-6 restricts transfers to those “from one major budget classification to another within a department or office. . . .”
Attorney General Official Opinion No. 11, dated June 28, 1976, was written in response to a question from a public school corporation regarding transferring “money from one account of its general fund to another account within its general fund without additional prior notice to the public and without prior approval of the state board of tax commissioners.” The Attorney General, in Official Opinion No. 11, concludes:
“It is therefore, my official opinion that by enacting Indiana Code, section 6-1.1-18-6, the General Assembly intended to authorize a public school corporation, on the same basis as other political subdivisions of government, to transfer money from one major budget classification of its general fund to another classification within that same fund without additional public notice and prior approval of the State Board of Tax Commissioners; but such a transfer could only be made by ordinance adopted at a public meeting of the school board, and the ordinance could not authorize expenditure of money in excess of the total appropriation for the school corporation. This opinion, however, relates only to the intended applicability of Code section 6-1.1-18-6. Doubts remain as to the constitutionality of the provisions of that section which permit transfer of funds without notice.”
The State Board of Accounts recognizes the provisions of this statute and official opinion and recommends the political subdivision’s attorney review this information. With his written approval, the State Board of Accounts will take no audit exception in future audits of a political subdivision if transfers of appropriations are made within the General or Operating Fund, pursuant to the requirements of IC 6-1.1-18-6.
The Indiana Board for Depositories' website contains the most recent listing of approved depositories. The list can be accessed at www.in.gov/tos/deposit/.
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Capital Assets
Establishing the Estimated Cost of Capital Assets
Certified Report of Names, Addresses, Duties, and Compensation of Employees (100R)
Claims for Payments to State and Federal Agencies
Contributions, Donations, Gifts
Cybersecurity Incidents - Reporting
CAPITAL ASSETS
ESTABLISHING THE ESTIMATED COST OF CAPITAL ASSETS
When it is not possible to determine the historical cost of capital assets owned by a governmental unit, the following procedure should be followed.
Develop an inventory of all capital assets which are significant for which records of the historical costs are not available. Obtain an estimate of the replacement costs of these assets. Through inquiry determine the year or approximate year of acquisition. Then multiply the estimated replacement cost by the factor for the year of acquisition from the Table of Cost Indexes. The resulting amount will be the estimated cost of the asset.
In some cases estimated replacement cost can be obtained from insurance policies; however, if estimated replacement costs are not available from insurance policies, you should obtain or make an estimate of the replacement costs.
If the replacement cost is estimated to be $76,000.00 and the asset was constructed about 1930, then the estimated cost of the asset should be reported as $5,320.00.
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Every library should have a complete inventory of all capital assets owned which reflects their acquisition value. Such inventory should be recorded in the Capital Assets Ledger, General Form 369. A complete inventory should be taken at least once a year for good internal control and for verifying account balances carried in the accounting records.
Capitalization Policy
The governing body should establish a capitalization policy that sets a dollar amount as a threshold to be used in determining which items will be recorded.
Land
The records of each library should reflect land owned, its location, its acquisition date and cost (purchase price). Infrastructure A capital asset account for the cost of infrastructure should reflect the location of each road, bridge, tunnel, drainage system, water, wastewater or stormwater system, dam, or lighting system.
Buildings
A capital asset account for buildings should reflect the location of each building and the cost value (being the purchase or construction cost) and, if improvements are made to the building, the cost of such improvements would be included. If a building is acquired by gift, the account would reflect its appraised value at the time of acquisition.
Improvement Other Than Buildings
A capital asset account should reflect the acquisition value of permanent improvements, other than buildings, which have been added to land. Examples of such improvements are fences, retaining walls, parking lots, and most landscaping. The improvements would be valued at the purchase or construction cost.
Equipment
Tangible property of a permanent nature, other than land, buildings and improvements, should be inventoried. Examples include machinery, trucks, cars, furniture, desks, safes, cabinets, etc. The value of such items should be carried in the inventory at the purchase cost.
Construction Work In Progress
Where construction work has not been completed in the current calendar year, the cost of the project should be carried as “construction work in progress.” When the project is completed, it will be placed on the inventory applicable to the assigned asset accounts.
CERTIFIED REPORT OF NAMES, ADDRESSES, DUTIES, AND COMPENSATION OF PUBLIC EMPLOYEES
All districts must file with the State Examiner on or before January 31, Form 100-R, a Certified Report of Names, Addresses, Duties and Compensation of Public Employees. This report is required by IC 5-11-13. Only the business address of each officer or employee listed is to be included on the form.
Such report must indicate whether the district offers a health plan, a pension, and other benefits to full-time and part-time employees
The report is to be filed electronically on the Gateway portal with the State Board of Accounts.
Fiscal Officers are no longer required to mail a signed hardcopy of the Attestation Statement to the State Board of Accounts. The Attestation Statement submitted electronically with the 100R is sufficient.
IC 20-33-3 places certain restrictions on work hours for children under 18 years old. For questions regarding child labor laws, please contact the Indiana Department of Labor. The Bureau of Child Labor home page is located at https://www.in.gov/dol/childlabor.htm. The preferred contact information is childlabor@dol.in.gov.
IC 20-33-3-39 through IC 20-33-3-41 list the penalties for violations of the child employment laws which can be as high as $400 per violation.
CLAIMS FOR PAYMENTS TO STATE AND FEDERAL AGENCIES
The State Board of Accounts’ audit position is that when statutory payments are due to state or federal agencies, there is no requirement for the state or federal agency to file an invoice or claim for such payments. This audit position would include payments for social security obligations, public employees’ retirement fund contributions, federal, state, or county taxes withheld, sales tax, utility receipts tax, and other such amounts due state or federal agencies. The disbursing officer should prepare an accounts payable voucher and attach any copies of payroll deduction reports, federal or state invoices, communications, etc., to document the payment. The accounts payable voucher will provide a posting media indicating to whom paid, fund on which drawn, accounts to be charged, and the approval by the proper boards.
CONTRIBUTIONS, DONATIONS, GIFTS
Following is a brief list of procedures to be followed by district officials in receiving and accounting for monetary contributions, donations, or gifts received by the district. (The term "donation" in this article includes donations, contributions and gifts.)
- Unrestricted donations are defined as those to which the donor has not attached terms, conditions, or purposes.
- Restricted donations are defined as those to which the donor has attached terms, conditions, or purposes.
- The governing body of the district has the option and responsibility to either accept or reject, in writing, any proposed donation.
- If the donation is a restricted donation, the board must agree, in writing, to the terms, conditions, or purposes attached to the proposed donation.
- Restricted donations can only be accepted for purposes within the scope of general statutory authority.
- Income or revenues in the form of tax distributions, tax receipts, fees, rentals, contractual payments, etc., are not to be considered donations.
- Donations which are accepted must be handled in one of the two following methods:
- Unrestricted donations shall be receipted into the operating fund of the district. Expenditure of such donated revenue from the operating fund shall be made only after an appropriation has been provided for the purpose of the expenditure. Claims must be filed and approved in the regular legal manner.
- A restricted donation shall be placed into a separate fund after such fund is established by the district board. Any appropriate descriptive name may be given the donation fund. The donation can be expended only for the purpose and under the terms and conditions agreed to on accepting the donation. Pursuant to Attorney General Official Opinion No. 68 of 1961, no further appropriation is required for expenditure of a restricted donation for the designated purpose. Even though no further appropriation is required, claims must be filed and approved in the regular legal manner before disbursements can be made from the fund.
- If the volume of restricted donations justifies it, a "control" fund may be established for all restricted donations. Separate, individual accounts would then be established to account for each restricted donation or each type of restricted donation. The total activities of the separate accounts -- receipts disbursements, balances – should be reflected on the control fund.
- Income from investments of restricted donations should be receipted into the same fund in which the principal of the donation has been receipted, provided it is to be used for the same purpose as the principal. However, if under the terms of the trust, the principal must be held in trust in perpetuity and only the income used by the governmental unit, there should be two funds established. One fund should be designated as "trust interest." In this situation, expenditures would only be permitted from the Trust Interest (Income) Fund".
- The district's fiscal officer should be the custodian of the unit's funds and securities.
The SBOA will not take exception to the use of credit cards by a unit provided the following criteria are observed:
The governing body must authorize credit card use through an ordinance /resolution, which has been approved in a meeting and documented in the minutes.
Issuance and use must be handled by an official or employee designated by the governing body.
The purposes for which the credit card may be used must be specifically stated in the ordinance/resolution.
When the purpose for which the credit card has been issued has been accomplished, the card must be returned to the custody of the responsible person.
The designated responsible official or employee must maintain an accounting system or log which would include the names of individuals requesting usage of the cards, their position, estimated amounts to be charged, fund and account numbers to be charged, date the card is issued and returned.
Credit cards must not be used to bypass the accounting system. One reason that purchase orders are issued is to provide the fiscal officer with the means to encumber and track appropriations to provide the governing body and other officials with timely and accurate accounting information and monitoring of the accounting system.
Payment cannot be made on the basis of a statement or a credit card slip only. Procedures for payments must be no different than for any other claim. Supporting documents such as paid bills and receipts must be available. Additionally, any interest or penalty incurred due to late filing or furnishing of documentation by an officer or employee may be the personal obligation of the responsible officer or employee.
If authorized, an annual fee may be paid. For additional suggestions regarding the use of credits, please see our Best Practices document on the Special Districts page of our website at www.in.gov/sboa.
REPORTING CYBERSECURITY INCIDENTS
House Enrolled Act 1169 (2021) added IC 4-13.1-2-9 as a new section to the Indiana Code which requires political subdivisions, as defined in IC 36-1-2-13, to report any cybersecurity incident using their best professional judgement to the Indiana Office of Technology (IOT) without unreasonable delay and not later than two business days after discovery of the cybersecurity incident. A cybersecurity incident may consist of one or more of the following categories of attack vectors: (1) Ransomware, (2) Business email compromise, (3) Vulnerability Exploitation, (4) Zero-day exploitation, (5) Distributed denial of service, (6) Web site defacement, (7) Other sophisticated attacks as defined by the chief of information officer and that are posted on the officer’s Internet web site. (IC 4-13.1-1-1.5)
Cybersecurity incidents can be reported on IOT’s web site at the following webpage. https://www.in.gov/cybersecurity/report-a-cyber-crime/
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DISASTER RELIEF FUNDS – ACCOUNTING AND BUDGETING
Based upon language contained in Indiana Code 10-14-3-17(j)(5) which states that a political subdivision may waive procedures and formalities otherwise required by law pertaining to the appropriation and expenditure of public funds where a national disaster or security emergency has been declared, the following procedures should be followed when disaster relief funds are received.
Money received or expected to be received form the Federal Emergency Management Agency (FEMA), the State Emergency Management Agency, or the State Lottery Commission for tornado, flood, ice storm, or other types of declared disasters should be accounted for in the following manner:
- If the money is to be used to reimburse funds for expenditures already incurred and paid and the conditions of Indiana Code 10-14-3-12 have been met, the amount received may be added back to the appropriation balances from which the expenditures have been previously made.
- If the money is to be used for future expenditures, a separate fund should be set up entitled “Disaster Relief Fund.” Such fund would not require appropriation or additional appropriation prior to spending the money in the fund.
It is recommended that all related expenditures records (claims, minutes, correspondence, contracts, damage survey report, etc.) be maintained in a separate file for future audits required by State and Federal agencies.
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FILING AND DOCKETING CLAIMS
Indiana Code 5-11-10 contains the requirements for the filing and docketing of claims. Certain special districts may have other statutory provisions for the payment of claims which are in addition to IC 5-11-10.
Indiana Code 5-11-10-1 applies to all political subdivisions except those political subdivisions which are specifically excluded in IC 5-11-10-1.
Indiana Code 5-11-10-1.6 applies only to those governmental entities that are specifically listed in IC 5-11-10-1.6.
Indiana Code 5-11-10-2 applies to all political subdivisions.
Indiana Code 5-11-10-2 states in part:
“(a) Claims against a political subdivision of the state must be approved by the officer or person receiving the goods or services, be audited for correctness and approved by the disbursing officer of the political subdivision, and, where applicable, be allowed by the governing body having jurisdiction over allowance of such claims before they are paid. If the claim is against a governmental entity as defined in section 1.6 [IC 5-11-10-1.6] of this chapter, the claim must be certified by the fiscal officer.
(b) The state board of accounts shall prescribe a form which will permit claims from two (2) or more claimants to be listed on a single document and, when such list is signed by members of the governing body showing the claims and amounts allowed each claimant and the total claimed and allowed as listed on such document, it shall not be necessary for the members to sign each claim.
(c) Notwithstanding subsection (b), only: (1) the chairperson of the board of directors of a solid waste management district established under IC 13-21 or IC 13-9.5 (before its repeal); or (2) the chairperson's designee; is required to sign the claim form described under this section.
(d) The form prescribed under this section shall be prepared by or filed with the disbursing officer of the political subdivision together with… the supporting invoices or bills...
(e) Where under any law it is provided that each claim be allowed over the signatures of members of a governing body, or a claim docket or accounts payable voucher register be prepared listing claims to be considered for allowance, the form and procedure prescribed in this section shall be in lieu of the provisions of the other law.”
The State Board of Accounts has prescribed General Form No. 364, Accounts Payable Voucher Register, which shall be prepared by, or filed with, the disbursing officer of the district, together with the supporting accounts payable voucher, and all such documents shall be carefully preserved by the disbursing officer as a part of the official records of the office.
If members of the governing body would rather approve and sign each individual accounts payable voucher in lieu of signing the Allowance of Vouchers section of General Form 364, this procedure is acceptable.
Indiana Code 5-11-10-1.6 states, in part:
“(c) The fiscal officer of a governmental entity may not draw a warrant or check for payment of a claim unless:
(1) there is a fully itemized invoice or bill for the claim;
(2) the invoice or bill is approved by the officer or person receiving the goods and services;
(3) the invoice or bill is filed with the governmental entity's fiscal officer;
(4) the fiscal officer audits and certifies before payment that the invoice or bill is true and correct; and
(5) payment of the claim is allowed by the governmental entity's legislative body or the board or official having jurisdiction over allowance of payment of the claim…
(d) The fiscal officer of a governmental entity shall issue checks or warrants for claims by the governmental entity that meet all of the requirements of this section. The fiscal officer does not incur personal liability for disbursements:
(1) processed in accordance with this section; and
(2) for which funds are appropriated and available.
(e) The certification provided for in subsection (c)(4) must be on a form prescribed by the state board of accounts.”
The district fiscal officer has the option of certifying either on each Accounts Payable Voucher or by signing the certification section of the Accounts Payable Voucher Register.
Indiana Code 5-11-10-1 states, in part:
“(b) No warrant or check shall be drawn by a disbursing officer in payment of any claim unless the same has been fully itemized and its correctness properly certified to by the claimant or some authorized person in the claimant's behalf, and filed and allowed as provided by law…
(d) The disbursing officer shall issue checks or warrants for all claims which meet all of the requirements of this section.
The disbursing officer does not incur personal liability for disbursements: (1) processed in accordance with this section; and (2) for which funds are appropriated and available. Indiana Code 2019 (e) The certificate provided for in subsection (b) must be in the following form: I hereby certify that the foregoing account is just and correct, that the amount claimed is legally due, after allowing all just credits, and that no part of the same has been paid.
The district fiscal officer has the option of certifying either on each Accounts Payable Voucher or by signing the certification section of the Accounts Payable Voucher Register.If any reduction is made by the Department of Local Government Finance in the district’s budget and tax levy, the appropriating body should comply with the section of the budget law found in IC 6- 1.1-18-4 which is quoted below:
“Appropriations not to exceed budget – Except as otherwise provided in this chapter, the proper officers of a political subdivision shall appropriate funds in such a manner that the expenditures for a year do not exceed its budget for that year as finally determined under this article.”
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HEALTH SAVING ACCOUNT PAYMENTS
It has come to our attention that some units are not using payroll withholding funds to account for the employee directed Health Savings Account payments. Instead, the units make direct deposits to the Health Savings Accounts in a similar manner to the process of making net pay direct deposits to the employee’s bank account. Historically, our audit position has been to take exception to this accounting practice because all payroll transactions were not being recorded in the financial records. The State Board of Accounts has revised the audit position on this process and we will not take audit exception to amounts approved by employees being deposited directly into Health Savings Accounts without the use of a payroll withholding fund, provided the following criteria are observed:
- Unit is following state and federal guidelines of Health Savings Accounts;
- Reports of amounts deposited into Health Savings Accounts are produced in detail by employee for each individual payroll period and maintained for audit; and
- Amounts deposited into Health Savings Accounts (employee and employer share) are approved by the governing board.
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We have received a number of questions on allowable investments and working with investment companies or brokerage companies. The following is our audit position on this issue.
Investing in Securities:
IC 5-13-9-2 authorizes an investment officer to invest in certain securities that are listed in the statute. There are three categories listed: (1) Securities backed by the full faith and credit of the United States Treasury (2) securities fully guaranteed and issued by a federal agency, federal instrumentality or a federal government sponsored enterprise and (3) Municipal securities issued by an Indiana local government, a quasi-governmental entity related to the state or a unit of government, municipal corporation, or special taxing district in Indiana, if the issuer has not defaulted on any of the issuer’s obligations within the last 20 years. The statue goes onto say in subsection (d) that “The investing officers of the political subdivision are the legal custodians of securities under this chapter. They shall accept safekeeping receipts or other reporting for securities from: (1) a duly designated depository as prescribed in this article; or (2) a financial institution located either in or out of Indiana having custody of securities with a combined capital and surplus of at least ten million dollars ($10,000,000) according to the last statement of condition filed by the financial institution with it government supervisor body.” To determine a duly designated depository, you may review the list of depositories on the Treasurer of State’s website. The definition of a financial institution may be found in IC 5-13-4-10.
IC 5-13-4-10"Financial institution"
Sec. 10. "Financial institution" means any of the following:
- A bank, trust company, or mutual savings bank that:
- was incorporated under the law of Indiana or any other state; and
- has its principal office or a branch in Indiana.
- A national banking association with its principal office or a branch in Indiana.
- A savings association operating as a deposit association incorporated under Indiana law.
- A federally chartered savings association with its principal office or a branch in Indiana.
- A federally chartered savings bank with its principal office or a branch in Indiana.
- A state chartered credit union in Indiana that is federally insured or privately insured and that has assets of three million dollars ($3,000,000) or more.
In order for the district to be compliant with statute, the district funds must be deposited with a designated depository or financial institute as defined in the statute. If that is followed, the designated depository or financial institution has custody of the funds. The investment companies may work with a district on the purchase of these securities but they may not directly sell the securities to the district or have custody of any district funds. As an example, a district could purchase a T-Bill from an investment company, however, the cash for the purchase should be sent to the financial institution and the financial institution would then deliver the cash to the investment company after the investment company delivers the T-Bill to the financial institution on behalf of the district. The financial institution would have custody of the T-Bill.
Investing in Money Market Funds:
IC 5-13-9-2.5 authorizes a political subdivision to invest money in money market mutual funds with certain restrictions. Again the statute describes the allowable securities for the portfolio of the money market fund. These include (1) direct obligations of the United States; (2) Obligations issued by a federal agency, a federal instrumentality or a federal government sponsored enterprise and (3) repurchase agreements fully collateralized by obligations describe in (1) or (2).
It also requires in subsection (b) “The investment described in subsection (a) shall be made through depositories designated by the state board of finance as depositories for state deposits under 5-13-9.5.” The money market fund must be in the custody of the designated depository.
Investing Officer Authority
All investments must comply with Indiana Code 5-13-9 and the investment policies of the district established under IC 5-13-9-5.7.
According to IC 5-13-9-5.7(f), the investing officer may contract with a federally regulated investment advisor or other institutional money manager to make investments under this section. Any contracts should be reviewed by your district attorney to ensure that the district funds are adequately safeguarded within the contract. Even when utilizing the services of an investment advisor, it is ultimately the responsibility of the investing officer to make the final decision on the investments, having done due diligence to ensure that the investments comply with statute and with the district’s investment policy. You should keep the documentation of your decision process.
- A bank, trust company, or mutual savings bank that:
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Each year the Department of Local government Finance will certify to each district’s figures which show one hundred two percent (100%) of the tax levy for each fund. If the property taxes received exceed one hundred two percent (100%) of the levy, the excess shall be receipted to a levy excess fund. However, if the amount is less than one hundred dollar ($100), no transfer is required. Please see Indiana Code 6- 1.1-18.5-17 for more information.
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Minimum Wage and Overtime Provisions
The following are excerpts from the Amended State Examiner Directive 2015-6 regarding a Materiality Threshold for reporting irregular material variances, losses, shortages, and thefts under IC 5-11-1-27(j). Note that this materiality threshold does not apply to a Report of Misappropriation under IC 5-11-1-27(l) as discussed in the previous article.
Indiana Code § 5-11-1-27(j) states: “All erroneous or irregular material variances, losses, shortages, or thefts of political subdivision funds or property shall be reported immediately to the state board of accounts…“.
In general, each political subdivision must develop their own policy on materiality because the causes of irregular variances, losses, shortages, and thefts are as broad and varied as the political subdivisions in which the incidents occur. For example, a $500 variance in Fort Wayne is not necessarily as concerning as a $500 variance in Pershing Township, Jackson County. On the other hand, a $100 variance in Fort Wayne that occurs every Friday may be material. Moreover, each political subdivision is the best determiner of the qualitative and quantitative factors unique to the unit in arriving at materiality.
Political subdivisions must recognize that variances, losses, shortages, and thefts may occur. If an incident occurs, it is imperative that the political subdivision have a policy in place that outlines the steps to be taken. Such a policy must include a materiality threshold at which point the political subdivision reports incidents to the State Board of Accounts.
The policy must be detailed, and it is essential that materiality thresholds distinguish between incidents involving cash and other types of assets. The policy needs to address maintenance of documentation and resolution of incidents that do not meet the materiality threshold…
If a political subdivision does not develop a policy on materiality, then the threshold is $0.00 and the political subdivision is required to report all irregular variances, losses, shortages, and thefts to the State Board of Accounts…
When an irregular variance, loss, shortage, or theft is determined material pursuant to a political subdivision’s policy on materiality (or, if no policy on materiality is developed, whenever there is any incident of irregular variance, loss, shortage, or theft), the subdivision must report the incident to the State Board of Accounts. On the State Board of Accounts’ website there is a notification link, which allows public officials to report via e-mail material irregular variances, losses, shortages, or thefts. Telephone and in-person reporting is also acceptable. Reports will be followed up with a return e-mail or call to gather additional information as necessary…”
Please review the entire contents of the Amended State Examiner Directive 2015-6.
FEDERAL AND STATE MILEAGE RATES
The Federal business mileage rate is available at www.irs.gov. The State mileage rate can be found on the Indiana Department of Administration’s website.
MINIMUM WAGE AND OVERTIME PROVISIONS
Your attorney should be consulted concerning the federal minimum wage and overtime provisions of the Fair Labor Standard Act applicable to libraries.
The overtime pay issue has required the State Board of Accounts to prescribe General Form No. 99C, Employee Weekly (work period) Earnings Record, which is designed to meet the record keeping requirements of the minimum wage and overtime provisions of the Fair Labor Standards Act (FLSA). The form should be maintained for employees who are not exempt from FLSA and who are not on a fixed work schedule when the governmental unit pays other than weekly.
Districts should constantly be aware of all the areas of employment in the district where overtime right attaches and establish a system to accurately record hours worked.
The U.S. Department of Labor Wage and Hour Division’s new nationwide program, the Payroll Audit Independent Determination (PAID) program facilitates resolution of potential overtime and minimum wage violations under the FLSA. Please see the U.S. Department of Labor website for more information: https://www.dol.gov/agencies/whd/paidIndiana Code 5-13-6-1(e) states that all local investment officers shall reconcile at least monthly the balance of public funds, as disclosed by the records of local officers, with the balance statements provided by the respective depositories.
In addition to compliance with statute, monthly bank reconcilements provide internal controls to achieve the safeguarding of public assets. We have received numerous reports that bank routing and account information is being used to create false checks that are clearing bank accounts and stealing public funds. If the unauthorized payments from the account are brought to the attention of the bank in a timely manner, the bank will replace the amount that was stolen. However, if you are not reconciling monthly, you would not be aware of these fraudulent transactions and the delay in reporting these fraudulent transaction to the bank may make it more difficult to get the bank to restore the funds to the bank account. Review the bank statement monthly and verify that all of your recorded deposits are credited to your account and all withdrawals from the account are transactions that trace to checks prepared by your office or electronic funds transfers that you have authorized. By doing this, you would catch any bank errors in a timely manner. In addition you would be able to identify any fraudulent activity as early as possible.
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OVERDRAWN FUNDS AND APPROPRIATIONS
The overdraft of a fund or appropriation is prohibited by law. Expenditures are limited to the balance in the particular fund and, in the case of budgeted funds, to the balance of the appropriation therefore. Please see IC 6-1.1-18-4. The following Uniform Compliance Guideline is in the Accounting and Uniform Compliance Guidelines for Special Districts, Chapter 1:
“The cash balance of any fund may not be reduced below zero. Routinely overdrawn funds could be an indicator of serious financial problems which should be investigated by the unit. In an instance in which a unit receives a reimbursement grant, the unit must be claiming reimbursement in a timely manner. In this case, it would be possible for a fund to be overdrawn for a short period of time.”
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Public Work Projects Costing Less than $150,000
The Public Employees’ Retirement System (PERF) Hybrid plan has two components, the defined benefit plan and the member’s annuity savings account. The member’s annuity savings component has been redefined as a “defined contribution” plan effective January 1, 2018. This change in definition will require a change in the disclosure in the notes to the financial statements for pensions. The defined contribution plan must be disclosed in a separate paragraph from the defined benefit plan component. In the past, these plans were presented together.
For the Enhanced Regulatory financial statements for 2019, this information will be shown in the pension note disclosure, however, in reviewing and approving the financial statements and notes to the financial statements, you will need to review that the defined benefit component has been separately identified. On the SBOA website at www.in.gov/sboa under 2019 Gateway-Annual Financial Report (AFR) Changes there are example reports. These reports provide an example of how the note disclosure for the defined benefit component should be reported. If any of your employees are enrolled in the My Choice plan rather than the PERF Hybrid plan, this will also need be disclosed as a defined contribution plan.
PUBLIC WORKS PROJECTS COSTING LESS THAN $150,000
IC 36-1-12-4.9 states:
- This section applies to a public work for the routine operation, routine repair, or routine maintenance of existing structures, buildings, or real property if the cost of the public work is estimated to be less than one hundred fifty thousand dollars ($150,000).
- The board may award a contract for public work described in subsection (a) in the manner provided in IC 5-22
We will not take audit exception to expenditures for projects under $150,000 that maintain the existing condition of the asset or restore the asset to normal operating efficiency and which might qualify as routine operation, routine repair, or routine maintenance of existing structures, buildings, or real property under IC 36-1-12-4.9. Included in our audit position could be expenditures for the replacement and repair of elevators, flooring, ceiling, tile, bathroom fixtures, windows, sidewalks parking lots and roofs which would not be part of another public works project. Additionally, the costs associated with reconfiguring the interior of offices (additions/deletions of wiring for electrical outlets, lighting, data lines, and telephones, cubicle walls, etc.) and reconfiguring offices with movable walls which would not be part of another public works project, could be considered. Not included would be additions to the structure, reconfiguring offices with permanent walls, change of purpose of an area that involves substantial addition or removal of plumbing or gas lines (adding a kitchen area or bathroom), addition of elevator shafts, parking lots and other like changes to the interior or exterior that involve changes to the structural integrity of the building or improvements to real property, etc. or expenditures for which a determination has been made of the applicability of other provisions of the Public Works Law, IC 36-1-12-1 et seq. Our audit position is with the assumption a determination has been made by the governmental unit in a public meeting of the applicability of IC 36-1-12-4.9 to the proposed public works project.
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Ransomware is a type of malicious software designed to block access to a computer system until a sum of money is paid. The principle of ransomware is that the malware encrypts files on a system’s hard drive using an unbreakable key, and this is decrypted by the attacker once a ransom is paid.
There have been increased instances of ransomware recently, both locally and nationally. Beware of unexpected or suspicious emails, especially those containing a link or requesting a reply. Most ransomware is delivered via email and the typical overall themes are shipping notices from delivery companies. Also, many attacks are delivered by mass random emails because the intention is to infect as many as possible to maximize the chances of getting a result.
Consider your district’s policies related to the protection of computer information. The most common advice to recover from an attack by ransomware relies largely on whether a good backup policy is employed. Backup expectations are discussed in the Accounting and Uniform Compliance Guidelines for Special Districts and Accounting and Uniform Compliance Guidelines for Indiana Political Subdivisions – Information Technology. Governmental entities also should keep their anti-virus software up-to-date and apply security patches in a timely manner.
RECORD OF HOURS WORKED
For officers and employees who are employed by more than one (1) public agency or in more than one (1) position by the same public agency, detailed time records are to be maintained for the hours worked for each public agency or each position at the same public agency. (IC 5-11-9-4)
An employee who works for more than one (1) governmental unit should not be paid by more than one (1) governmental unit for the same period of time worked. Such employee should use his/her accumulated leave time from one (1) governmental unit while serving the other governmental unit when there is an overlap in a work schedule.
In governmental units where time cards are not used, this requirement can be met by preparing an endorsement on the payroll claim form showing the general work schedule and listing the specific affected employees who worked hours different from the general work schedule. Such endorsement should be reviewed and approved by the individual responsible for approving payroll claims.
Another alternative is to add a statement on each affected Employee’s Service Record, General Form 99A and/or Employee’s Earning’s Record, General Form 99B indicating the specific hours to be worked daily by that employee. (Example: 8 a.m. to 4 p.m.) Time cards should be reviewed and approved by the individual responsible for approving payroll claims.
IC 5-15-6-3 states:
“No financial records or records relating to financial records shall be destroyed until the earlier of the following actions:
- The audit of the records by the state board of accounts has been completed, report filed, and any exceptions set out in the report satisfied.
- The financial record or records have been copied or reproduced in accordance with a retention schedule or with the written consent of the administration.”
IC 26-2-8-111 states in part:
“(a) If a law requires that certain records be retained, that requirement is met by retaining an electronic record of the information in the record that:
- Accurately reflects the information set forth in the record after it was first generated in its final form as an electronic record or otherwise; and
- Remains accessible for later reference…
(e) If a law requires retention of a check, that requirement is satisfied by retention of an electronic record of the information on the front and back of the check in accordance with subsection (a).”
More information on record retention is available on the Indiana Archives and Records Administration website at www.in.gov/iara , including retention schedules and electronic records management.
Indiana Code 5-11-1-27(l) requires a public officer who has actual knowledge or reasonable cause to believe that there has been a misappropriation of public funds or assets to immediately send a written notice to the State Board of Accounts and the prosecuting attorney.
Indiana Code 5-11-1-27(l) states:
(l) A public officer who has actual knowledge of or reasonable cause to believe that there has been a misappropriation of public funds or assets of the public office, including:
- information obtained as a result of a police report;
- an internal audit finding; or
- another source indicating that a misappropriation has occurred;
shall immediately send written notice of the misappropriation to the state board of accounts and the prosecuting attorney serving in the area governed by the political subdivision.
The State Examiner Directive 2015-6 also addresses this statute.
The policy must also consider Ind. Code § 5-11-1-27(l), which requires public officials who have actual knowledge of or reasonable cause to believe that there has been a misappropriation of public funds to immediately send written notice of the misappropriation to the State Board of Accounts and the prosecuting attorney. There is no materiality threshold applicable to Ind. Code § 5-11-1-27(l). Thus, whenever a political subdivision has actual knowledge or is reasonably certain that a misappropriation of public funds has occurred (regardless of the dollar amount), the political subdivision must send written notice of the misappropriation to the State Board of Accounts and the local prosecuting attorney. Misappropriation occurs when an employee or in-house contractor of the political subdivision wrongly takes or embezzles public funds. When there is a known misappropriation or embezzlement of public funds by an internal actor, materiality is irrelevant. Indiana law requires the political subdivision to report the activity to the State Board of Accounts and the local prosecutor. Ind. Code § 5-11-1-27(l).
We are finding that the requirements of this statute are not being followed consistently. If a public official fails to report the misappropriation of funds or assets in a timely manner, this will result in a finding in the audit report. This may also result in additional audit costs. Also, be aware that reporting the misappropriation to a law enforcement agency does not fulfill the requirements of the statute. Even when you have notified law enforcement officials, you must still notify the State Board of Accounts and the prosecutor. If there are any concerns on the response the board of accounts will take after a report is received or how they will liaison with the law enforcement investigation, you can contact our Director of Special Investigations at (317) 232-2513.
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SOCIAL SECURITY VERIFICATION
The Social Security Administration provides an online verification of social security numbers of current and former employees at this link:https://www.ssa.gov/employer/ssnv.htm
This service is useful to ensure that your current employees’ social security numbers match those on file with the Social Security Administration and can provide some assurance that retirees of single-employer pension plans are not deceased. This verification could be a necessary audit procedure if the district offers a single-employer pension plan. Our Field Examiners may request that you provide documentation that you have verified retirees receiving benefits from these plans are not, if fact, deceased. Consider enrolling for this service if you have not already done so and performing this verification prior to the start of the audit to avoid any delays in completion of the audit timely.
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Temporary Transfers to Depleted Funds
Timely Filing of Required Reports
TEMPORARY TRANSFERS TO DEPLETED FUNDS
Indiana Code 36-1-8-4 states:
“(a) The fiscal body of a political subdivision may, by ordinance or resolution, permit the transfer of a prescribed amount, for a prescribed period, to a fund in need of money for cash flow purposes from another fund of the political subdivision if all these conditions are met:
- It must be necessary to borrow money to enhance the fund that is in need of money for cash flow purposes.
- There must be sufficient money on deposit to the credit of the other fund that can be temporarily transferred.
- Except as provided in subsection (b), the prescribed period must end during the budget year of the year in which the transfer occurs.
- The amount transferred must be returned to the other fund at the end of the prescribed period.
- Only revenues derived from the levying and collection of property taxes or special taxes or from operation of the political subdivision may be included in the amount transferred.
(b) If the fiscal body of a political subdivision determines that an emergency exists that requires an extension of the prescribed period of a transfer under this section, the prescribed period may be extended for not more than six (6) months beyond the budget year of the year in which the transfer occurs if the fiscal body does the following:
(1) Passes an ordinance or a resolution that contains the following:
- A statement that the fiscal body has determined that an emergency exists.
- A brief description of the grounds for the emergency.
- The date the loan will be repaid that is not more than six (6) months beyond the budget year in which the transfer occurs.
(2) Immediately forwards the ordinance or resolution to the state board of accounts and the department of local government finance.”
Funds advanced shall be derived from taxes on property, special taxes, or any other revenue received from any operation of the municipal corporation.
Such temporary transfers should be affected by issuing a warrant and receipt for the amount of the transfer. The warrant should be endorsed and deposited in the depository account designated for the depleted fund. No appropriation is required either for the transfer or the repayment. Also, no interest should be charged on any such temporary transfer.
TIMELY FILING OF REQUIRED REPORTS
The Certified Report of Names, Addresses, Duties and Compensation of Public Employees (Form 100-R) and Annual Financial Report (AFR)
As previously discussed and pursuant to IC 5-11-13-1, all governmental units in the state must file the certified personnel report (Form 100-R) in January of each year with the SBOA. Also, pursuant to IC 5-11-1-4, all local governmental units in the state must file an Annual Financial Report (AFR) not later than 60 days after the close of each fiscal year. The Indiana Gateway for Government Units (Gateway) system was created to collect both of these reports.
Due to the importance of these reports, the State Examiner has established the following procedures for reports not filed timely:
If either the 100R or the AFR are not filed by the statutory due date, the State Board of Accounts will subpoena the fiscal officer to appear in our Indianapolis office with the information necessary to complete the 100R or AFR, as applicable. This subpoena will be served either by certified mail or through personal service by a representative of the Office of the Attorney General (OAG).
If the fiscal officer does not appear or does not submit the 100R or AFR in response to the subpoena, the State Examiner will send a notification to the OAG requesting the OAG to compel the fiscal officer to appear in court to answer as to his or her failure to file the report. The State Examiner may also send notification of the officer’s failure to comply with the law to the local prosecuting attorney.
Indiana Code 5-11-1-10 addresses the penalty for not filing a required report and not following the directions of the State Examiner:
A public officer who:
- fails to make, verify, and file with the state examiner any report required by this chapter;
- fails to follow the directions of the state examiner in keeping the accounts of the officer's office;
- refuses the state examiner, deputy examiner, field examiner, or private examiner access to the books, accounts, papers, documents, cash drawer, or cash of the officer's office; or
- interferes with an examiner in the discharge of the examiner's official duties; commits a Class B infraction and forfeits office.
If you need submission rights or have any questions regarding the use of Gateway, please contact our help desk at gateway@sboa.in.gov. Also, please feel free to contact our Directors of Audit Services if you are having difficulty completing your Form 100-R or AFR. Contact information is available on our website at www.in.gov/sboa.
The following sets forth the audit position of the State Board of Accounts with regard to reimbursements made by local governmental units to their officers and employees for travel and meal expenses.
A local unit may reimburse such persons for actual miles traveled in their own motor vehicles on official business of the local unit at a reasonable rate per mile as fixed by an ordinance or resolution of the unit’s legislative body. The mileage rate should be fixed by the board or commission having authority to approve claims for travel expenses. No particular mileage rate has been set by the State of Indiana for local units of government and, consequently, the mileage rate lies within the discretion of legislative body, board or commission, unless otherwise provided by statute. The body setting the mileage rate should also determine whether parking fees and toll charges are included in the rate or, on the other hand, whether such expenses are to be reimbursed separately based on the submission of receipts.
Reimbursed mileage should not include travel to and from the officer’s or employee’s home and regular place of employment. If more than one person rides in the same vehicle, only one mileage reimbursement is allowable. General Form 101 (or an approved substitute) should be used for claiming mileage. The odometer reading columns on this form are to be used only when the distance between points cannot be determined by fixed mileage or official highway maps.
When traveling outside the local unit’s boundaries on official business, officers and employees may also be reimbursed for meals, lodging, and incidental expenses as defined in the travel policy. The claim for reimbursement should be supported by itemized receipts from hotels, restaurants, and taxi cabs used by the officer or employee while traveling on official business.
It is permissible for the legislative body of the local unit or the board or commission having the authority to approve claims to adopt an ordinance or resolution establishing a reasonable per diem rate intended to cover travel expenses other than hotel and mileage costs and the officer or employee may be reimbursed on the basis of such a per diem rate in lieu of submitting receipts. If a fixed per diem rate is established by policy, the policy should clearly indicate which type of expenses, in addition to meals, are included in the rate and which related expenses are to be reimbursed on the basis of actual receipts being submitted by the officer or employee. The policy should also define the local unit’s boundaries for purposes of reimbursing travel; i.e. outside a 50-mile radius of the office, outside of the county, etc. The policy should cover a proportionate reduction in the per diem rate when meals are provided by an outside party.
When state statutes govern the amounts of allowable travel reimbursements, those statutes supersede local policy. Also, when determining the reasonableness of a mileage rate or per diem rate, consideration should be given to rates established by the State of Indiana and the Federal government. The local unit should, however, consider the income tax implications of setting its rates higher than the current Federal rates.
In all cases, an officer or employee requesting reimbursement for overnight travel is required to submit a receipt from the hotel or other meeting place where such accommodations were provided.
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The following is a listing of duties and reports that occur each year end.
- Monthly and Annual Engagement Uploads
- Audit Preparation
- Cancellation of Warrants – Old Outstanding Checks
- Certification of Names and Addresses to County Treasurer
- Encumbered Appropriations – Balance Available
- Dormant Fund Balances – Transfers Authorized
- Internal Control Considerations
MONTHLY AND ANNUAL ENGAGEMENT UPLOADS
In keeping with State Examiner Directive 2018-1, the following files and governmental unit information are required to be uploaded annually:
- Year-end bank statement
- Year-end outstanding check list
- Year-end investment statements
- Detail of receipts for the year
- Detail of disbursements for the year
- Current year salary ordinance
- Annual vendor history report
Annual files are due to be uploaded on Gateway no later than February 29, 2020.
SBOA personnel have developed a user guide for the Upload App located at: https://gateway.ifionline.org/userguides/engagementguide. If, after consulting the user guide, you still have questions, please contact the helpdesk at gateway@sboa.in.gov.
Exceptions to certain requirements set forth in this Directive, such as for manual records, units audited by private CPA firms, and other exceptions, are discussed in the user guide. Contact information for questions and other help, including a "Frequently Asked Questions" section, is also available on the user guide.
More information is available on the SBOA website by clicking the “Political Subdivisions” link on the left hand menu and then by selecting the appropriate unit type. Then scroll down and select the Gateway section and the Gateway Upload Application link.
AUDIT PREPARATION
When we arrive to conduct an audit, oftentimes officials have to spend time gathering information, records, and other documentation per our requests. Year-end is a good time to consider preparing some of those items in advance of our arrival so they can easily be produced when we arrive – saving time for you and the examiners.
Here are some items you can get ready at year-end that should help your engagement get off to a good start:
- Minutes of Board meetings
- Bank reconcilements complete and bank information (statements, etc.)
- Claims in order with supporting documentation available
- Copies of new resolutions, or significant contracts from the year
- Written policies and procedures (internal controls, accrued leave, travel, etc.)
- Financial reports filed with other state or federal agencies
- Grant awards and agreements (federal and state)
CANCELLATION OF WARRANTS – OLD OUTSTANDING CHECKS
Pursuant to IC 5-11-10.5, all checks outstanding and unpaid for a period of two years as of December 31 of each year are void.
Not later than March 1 of each year, the fiscal officer shall prepare, or cause to be prepared, a list in duplicate of all checks outstanding for two or more years as of December 31 last preceding. The original copy shall be filed with the district board and the duplicate copy maintained by the fiscal officer of the district. The fiscal officer shall enter the amounts so listed as a receipt to the fund or funds upon which they were originally drawn and remove the checks from the list of outstanding checks. If the fund from which the check was originally drawn is not in existence or cannot be ascertained, the amount of the outstanding check shall be receipted into the operating fund of the district.
The list prepared must include:
- the date of issue of each warrant or check;
- the fund upon which the warrant or check was originally drawn;
- the name of the payee;
- the amount of each warrant or check issued; and 5. the total amount represented by the warrants or checks listed for each fund.
CERTIFICATION OF NAMES AND ADDRESSES TO COUNTY TREASURER
IC 6-1.1-22-14 states that on or before June 1 and December 1 of each year, the disbursing officer of each political subdivision shall certify the name and address of each person who has money due the person from the political subdivision to the county treasurer of each county in which the political subdivision is located. Upon the receipt of this information, the county treasurer shall search the records to ascertain if any person so certified is delinquent in the payment of property taxes.
IC 6-1.1-22-15 states that if the county treasurer finds that a person whose name is certified to him under 6-1.1-22-14 is delinquent in the payment of taxes, he shall certify the name of that person and the amount of delinquency to the official of the political subdivision who is to make payment to the person. The disbursing officer shall periodically make deductions from money due the person and shall pay the amount of these deductions to the county treasurer.
ENCUMBERED APPROPRIATIONS – BALANCE AVAILABLE
With the opening of a new budget year and a new set of ledgers, it is advantageous to review the unpaid purchase orders and contracts which remain on the ledgers as “encumbered.”
Unpaid purchase orders and those items under contract are to be added for each appropriation account and the total carried to the new corresponding account. The actual unpaid amount of the purchase orders or contracts should be totaled and shown as a separate amount on the appropriation ledger sheet for, with proper explanation, and added to the appropriation for the same purpose. By properly carrying out this procedure, the budget will not be expected to stand any expense not anticipated in making the budget.
We suggest the proper officials of the district make a listing of these encumbered items and make it part of the minutes in the last business meeting of the year. The Department of Local Government will request this information from each unit. The information will be used to validate the current year financial worksheet during following year’s budget cycle.
Keep in mind the appropriations encumbered and carried forward can be used for no other purpose other than the purchase order or the contract for which they were appropriated.
DORMANT FUND BALANCES - TRANSFERS AUTHORIZED
IC 36-1-8-5 gives the district board the authority to order the transfer to the general fund or rainy day fund any unused and unencumbered balance in any fund raised by a general or special tax levy, the purposes of which have been fulfilled. This action may be taken by the district board at any public meeting.
IC 36-1-8-5 states in part:”
- This section applies to all funds raised by a general or special tax levy on all the taxable property of a political subdivision.
- Whenever the purposes of a tax levy have been fulfilled and an unused and unencumbered balance remains in the fund, the fiscal body of the political subdivision shall order the balance of that fund to be transferred as follows, unless a statute provides that it be transferred otherwise….
(4) Funds of any other political subdivision, to the general fund or rainy day fund of the political subdivision, as provided in section 5.1 of this chapter...”
INTERNAL CONTROL CONSIDERATIONS
At the end of the year, it is a good idea to evaluate the effectiveness of the internal controls of your district and determine whether changes are necessary to provide reasonable assurance that the objectives of your district are met. We also recommend documenting internal control procedures and reviewing for evidence of procedures being performed as intended. Please note that IC 5-11-1-27 requires all “personnel,” as defined in the statute, to be trained on internal controls. Please make sure that all “personnel,” including newly hired employees in 2019, have viewed the SBOA approved training video. The SBOA approved training is required only one time, but we do always recommend additional training on internal controls as determined by your district.
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