Tuesday, March 22, 2011

Another APS audit, same findings

Another audit has been performed on the Albuquerque Public Schools. The audit was done by Griego Professional Services late last year and reported to APS in January. The audit concerned itself with internal controls.

I cannot find a copy of the audit on APS' website and for good reason; the audit reveals the same problems APS has always had and continues to fail to address; (The list is not comprehensive, I stopped reading about halfway through realizing my argument is made. The following points are pretty much verbatim, emphasis is added)

  1. the absence of a periodically acknowledged code of conduct
  2. the absence of HR processes to address nepotism conflicts of interest
  3. apparent lack of accountability for the protection of district assets
  4. a lack of process to notify the State Auditor of the discovery of any violation of a criminal statute in connection with financial affairs
  5. lack of background checks on those in fiduciary positions
  6. a lack of communication of management responses to conduct/ethical lapses
  7. the Districts practices and processes are reactive in nature (v proactive)
  8. board policy and procedural directives are outdated and inconsistently written
  9. employee standards of conduct are sparsely worded; due care of District property is not stated
  10. no code of conduct is formally acknowledged (not since the leadership abandoned its obligations as role models of the Pillars of Character Counts!)
  11. the whistle blower program is highly utilized (but due process is still being denied to every single one of the complaints)
  12. management culture shows varying emphasis on integrity and ethics
  13. no formal metric for measuring management responses to problems
  14. District management's approach to allegations of nepotism, cronyism and protection of property needs improvement
  15. it is unclear whether the District has reported to the State Auditor discoveries of cash fraud and property losses, or that they intend to rectify this finding in the future
  16. a perception that management is ineffective or ambivalent about enforcing standards of conduct, and enforces rules inconsistently
  17. the school board is not focused on evaluating the effectiveness of "the tone at the top" (yet they have extended Winston Brooks contract three times, three years into the future)
  18. the district does not publish a code of conduct
  19. significant turnover in the Chief Financial Officer position (the district argued "individual circumstances" for turnover; the record indicates otherwise)
  20. District assets are not protected from unauthorized access or use
  21. the District doesn't benchmark supervisory ratios
  22. overtime for managers is not tracked
  23. specific delegations of authority are not defined
  24. individuals hired for similar positions with similar education receive widely different compensation
  25. there is no management-related training program
  26. no systematic confirmation that required performance reviews are actually done
  27. it is unclear whether specific promotion criteria are documented or understood (the Council of the Great City Schools auditors wrote; administrative evaluations are subjective and unrelated to promotion or step placement)
  28. promotion criteria do not include adherence to behavioral standards
  29. HR policy does not require scrutiny of job candidates with frequent job changes or gaps in employment history
  30. there is no stated policy requiring employees to report criminal convictions
  31. credit checks are not done on employees with fiduciary responsibilities who handle cash
  32. activity level objectives are not periodically reviewed for continued relevance
  33. a lack of specific performance objectives in activity areas
  34. there are no formal processes for periodic risk assessment or root cause analysis of recurring issues
  35. I. T. back up plans are not periodically tested
  36. formal identification of risks at the activity-level have not been performed
  37. information on the function of internal controls has not been developed
  38. APS does not maintain an Ombudsman function
  39. no formalized process for employees to provide recommendations for improvements
  40. suppliers, customers and others are not made aware of District standards and expectations
  41. such standards are not reinforced in routine dealings
  42. improprieties are not reported to appropriate personnel
  43. no documentation of closure of complaints made to the Service Center or to the Superintendent
  44. no clear metrics showing top management is aware of the volume or nature of complaints
  45. formal monitoring of internal controls needs improvement
  46. personnel are not periodically required to acknowledge compliance with the code of conduct
  47. the Internal Audit Department is understaffed and therefore consumed with property issues and activity accounts at the expense of systematic issues of risk.
  48. the District does not conduct formal self-assessments of control processes
  49. no evidence of a single process or clearinghouse for tracking issues and corrective actions
The entire audit can be viewed here, link.

Though I haven't the expertise to evaluate all of these findings, it seems pretty clear that there is a lack of standards and accountability in the leadership of the APS and that little progress is being made in remediation of the problems.

The lack of progress is due, in my opinion, to the fact that the leadership of the APS are a bunch of good ol' boys, more interested in covering each others asses than in holding each other honestly accountable to any meaningful standards of conduct and competence.

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