· According to information provided by the Clerk, the
former Director of MIS/Finance, during his employment, spent a significant amount of time
(approximately 19 weeks) at a location other than the Walton County Clerks office.
The Clerk informed us that for most of this period of time, the former Director reported
that he was in Texas due to the illness of his wife. During these periods of absence, the
former Director of MIS/Finance was paid for 198.5 hours of regular time (in lieu of having
to use earned leave) totaling $4,298.87, 315.6 hours of compensatory time totaling
$7,847.63 (see further discussion in paragraph 167), and 94.6 hours of sick leave totaling
$2,352.27. According to the former Directors job description, his responsibilities
as Director of Finance included supervising the training of personnel, advising employees
concerning work and personnel matters, and providing guidance and technical assistance to
Finance division employees in the resolution of operational problems. In response to our
inquiry as to whether the former Director could have effectively accomplished these duties
at an off-site location and what documentation was provided to establish the hours the
Director worked for Walton County while out of the Walton County area, as well as
compensatory hours earned, the Clerk stated, with respect to the former Director, that
" A close look at his job responsibilities will reveal a responsibility for planning
and directing that not only can be performed off-site (whether at home or in Texas), but
in many cases requires the uninterrupted work environment that the office denies most
first line managers. A well organized and defined operation can benefit from each
members presence, but will not lose its effectiveness in the absence of any. Through
good organization and good management team processes, there is no doubt that [the former
Director] was effective during those . . . hours that he worked in Texas." However,
we do not believe this adequately explains how the Clerk was able to provide adequate
supervision to the former Director and how the Clerk could have been assured that
employees reporting to the former Director were adequately supervised. Further, it is not
apparent how the Clerk, who approved the former Directors timesheets, could have
determined that the hours reported on the timesheets were actually worked and accurately
reported. The lack of on-site supervision by the former Director may have contributed to
many of the deficiencies cited in this report relating to areas within the former
Directors areas of responsibility. Furthermore, as discussed in paragraphs 210 and
211, a public accounting firm was paid $85,055 during the period October 1996 through June
1998 for various accounting-related services that were also within the areas of
responsibility of the former Director. While it is not possible to determine at this point
in time the extent to which such services might not have been needed had the former
Director been on-site, it appears likely that the need to contract with the public
accounting firm was, at least in part, attributable to the absence of the former
Director..
The Clerk, in his written response to this finding, concluded that the auditor is
not familiar with the concept of remote work stations and stated that employees were
required to provide daily updates as to their progress on their assigned task lists by way
of a shared computer system, with daily responses and directions from the former Director.
We recognize that there are situations in which periodic absences of an administrative
employee can be accommodated through careful planning and scheduling of activities and the
use of computers and communications technology. However, the Clerk did not provide
justification for his decision to allow the former Director of Management Information
Systems/Finance to be absent for extended lengths of time during a period of emergency. In
view of the emergency conditions that, as described by the Clerk in his response, existed
during the time of employment of the former Director and the dual responsibilities
required to be performed by the former Director, the decision to allow the extensive
absence of the former Director from the worksite does not appear to be appropriate.
The Clerk further stated, "If the auditor could point to one valid, documented
case where the decision to allow remote work had a specific negative impact, I would
reconsider the correctness of my decision." We believe that the numerous deficiencies
in the accounting records and practices of the Clerks Office that extended
throughout the period of this audit, as identified in this report, demonstrate that
adequate supervision and instruction to employees has not been provided. For example,
adequate guidance for the proper preaudit of expenditures had not been provided (see
paragraphs 177 through 181); proper reconciliations of bank accounts had not been prepared
(see paragraphs 67 through 70); and proper accountability was not maintained for
restricted revenues (see paragraphs 146 through 151).
The Clerk stated that the lack of approval of the former Directors time sheets
while the Director was in Texas was a management risk that is required to be taken by any
manager or supervisor at some time. We recognize that there are occasions when work at
remote work stations is necessary and reliance must be placed on the integrity of the
employees assigned to remote locations; however, such assignments should be dictated by
necessity and the Clerk has not demonstrated the necessity for the remote work station
assignment in the instant circumstances and the procedures in effect to assure that work
was properly performed.
The Clerk requested that this finding be removed, apparently because the accounting
firm and the former Director were assigned differing tasks and the absence of the former
Director did not affect the responsibilities assigned to the accounting firm. The Clerk
identifies specific tasks as having been assigned to the accounting firm, including
meeting the immediate processing needs and extracting knowledge from the previous Finance
Supervisor. These are functions that would normally be assigned to a Director of Finance,
assuming the Director of Finance is on-site and available to perform the functions.
· According to the Clerk, he never received any written correspondence from the former
Director or other individuals regarding the former Directors wifes illness and
his knowledge of the illness was based solely on the former Directors verbal
communications to the Clerk. It is not our intention to question whether the former
Directors wife was ill; however, documentation evidencing the severity of the
illness (e.g., a physicians statement), would have helped provide a basis for the
Clerks decision to allow the former Director to work off-site for an extended period
of time.
· Assuming that the former Director was entitled to sick leave in the same manner as
other Clerk employees, our recalculation of sick leave earned and used by the former
Director disclosed that he was paid for 12.7 hours of sick leave totaling $335 to which he
was not entitled.
(164) We recommend that the Clerk discontinue the practice of allowing staff to take
extended absences of leave with pay and, in the future, require proper documentation as to
family illnesses to ensure the propriety of sick leave usage due to family illnesses
and/or the necessity for absences of leave without pay to attend to family illnesses. We
also recommend that the Clerk take appropriate action to recover the amount overpaid the
former Director of MIS/Finance for sick leave.
(165) The Clerk, in his written response to this recommendation, stated that the
policy on extended leaves of absence and the requirement for documentation to ensure the
propriety of sick leave with or without pay is fully documented in the Policies and
Procedures Manual (Manual) that went into effect June 5, 1998. The referenced policies
were included in the Manual; however, the Manual did not address the
circumstances described in the finding, i.e., the assigning of remote work locations and
the control of absences from work by employees at such locations. As to the overpayment to
the former Director for sick leave, we have provided the Clerk with details of the
calculation on which the finding was based. In a memorandum dated January 15, 1999, the
Clerk acknowledged that the mistake had been made by the payroll department and that he
did not feel that the former Director should pay for such mistakes.
(166) There was no documented basis for $11,494 of compensatory time paid to seven
Clerk employees prior to June 5, 1998.
(167) Our audit disclosed that during the period January 1997 through June 5, 1998,
seven supervisory Clerk employees, designated as " exempt" by the Clerk
(presumably exempt from the minimum wage and overtime standards of the Fair Labor
Standards Act), were permitted to earn, and were paid for, 529 hours of compensatory time
totaling $11,494 (based on their hourly rates of pay at the time of payment). This
included 436 hours of compensatory time totaling $10,008 paid to the former Director of
MIS/Finance. Prior to June 5, 1998, the Clerk did not have any written policies and
procedures regarding the earning and use of compensatory leave by Clerk employees.
However, in correspondence dated January 6, 1997, the Clerk addressed the subject of
overtime regarding supervisory (exempt) and nonsupervisory employees. For supervisory
(exempt) employees, the correspondence stated " Supervisory personnel are considered
exempt employees and will work a scheduled 40 hour work week (80 hours per pay period) and
such additional hours as needed to meet the needs of their responsibilities. Supervisory
personnel are not eligible for overtime." The correspondence did not provide for the
accrual or use of compensatory time and, as stated, specifically prohibited payment for
overtime for supervisory (exempt) employees. Thus, there was no documented basis for the
payment of this compensatory time. Effective June 5, 1998, the Clerk adopted a Policies
and Procedures Manual (Manual). Page 16 of the Manual provides, " When an
exempt employee works beyond the forty (40) hours in his or her designated work week, the
employee may be granted compensatory time in accordance with the Fair Labor
Standards Act." However, because the Fair Labor Standards Act does not address
compensatory time for exempt employees, the intent of this provision of the Manual is
unclear.
(168) We recommend that the Clerk take appropriate action to recover these improper
payments for compensatory time from the applicable employees and to clarify the Manual provision
regarding the granting of compensatory time to exempt employees.
(169) The Clerk, in his written response to this finding, stated that he disagreed
with the finding that payments based on a verbal policy, during a time in which documented
policies and procedures were nonexistent and being developed, were improper. As indicated
in the finding, the Clerk had specifically stated in writing that supervisory personnel
were not eligible for overtime. In the absence of authorization for overtime, it is not
apparent how an exempt employee could accrue compensatory time, which is based on working
overtime. The Clerk further stated that the finding did not include mention of any
violations of Florida Statutes. Matters such as overtime and compensatory time for local
governments are not controlled by the Florida Statutes, but rather by Federal law (Fair
Labor Standards Act) and local policy, which were cited in the finding. Procurement of
Goods and Services
(170) Local governmental entities, such as a board of county commissioners and a clerk
of the circuit court, possess only such power and authority as is expressly granted by law
or necessarily implied therefrom in order to carry out an expressly granted power, except
that boards of county commissioners may adopt home rule ordinances in any area of local
government not preempted by general or special law. If there is any doubt as to the
existence in law or ordinance of a particular power, the further exercise of the power
should be arrested.
(171) The authority for Walton County officials to expend moneys is set forth in
various provisions of general or special law and in ordinances enacted by the BCC.
Expenditures of public funds must, to qualify as authorized expenditures, be shown to be
authorized by applicable law or ordinance; reasonable in the circumstances and necessary
to the accomplishment of authorized purposes of the governmental unit; and in pursuit of a
public, rather than a private, purpose. These limitations require County officials seeking
to expend public funds to identify the authority relied upon for the contemplated
expenditure and to adequately describe how the expenditure will further an authorized
public purpose. The Attorney General has stated, in part, in Opinion No. 068-12, dated
January 25, 1968, that:
" Vouchers for payment of public funds, whether state, district or county,
submitted or to be submitted to the paying agency should contain sufficient information
for the paying agency, or its preauditors or officials and the postauditor to determine
whether the requested payment is authorized by law. Doubtless, in many instances the
purposes for which payment is requested will appear, without explanation, from the face of
the voucher; however, in many other instances the legality of the payment requested will
not appear from the face of the voucher. In those instances where the legality of the
requested payment is not readily apparent to the paying agency the paying agency is
justified in turning down the request for payment or requesting clarification. The person
issuing the voucher for payment is obligated to cast such vouchers in such language as
will indicate to the postauditor or the public the legality of such payments."
(172) The documentation of an expenditure in sufficient detail to establish the
authorized public purpose served, and how that particular expenditure serves to further
the identified public purpose, should be present at the point in time when the voucher is
presented to the Clerk to make payment of funds. Unless such documentation is present, the
request for payment should be denied. For BCC expenditures, the BCC is responsible for
obtaining and presenting such documentation to the Clerk and the Clerk, as pre-auditor of
BCC funds, is responsible for assessing the adequacy of the documentation and affirming
the legality of the proposed expenditure prior to payment. For the Clerks
expenditures, the Clerk is responsible for obtaining such documentation.
(173) To provide documented assurances that expenditures of County funds are for
authorized public purposes, the BCC and the Clerk are responsible for establishing and
maintaining internal controls, including the adoption of sound accounting practices, that
will provide for the proper recording, processing, summarizing, and reporting of financial
data. The internal controls should include an accounting system to identify, assemble,
analyze, classify, record, and report transactions and to maintain accountability for the
related assets and liabilities.
(174) With respect to BCC funds, the BCC is responsible, under applicable law and the Joint
Stipulation (see paragraph 6), for procurement activities, including the selection of
vendors, issuance of purchase orders, receipt of invoices, and matching of invoices to
purchase orders. The Clerk is responsible for pre-audit of the expenditures, the issuance
of checks, and the recording of expenditures. Prior to the effective date of the Joint
Stipulation, the Clerk was also responsible for the issuance of purchase orders,
receipt of invoices, and matching of invoices to purchase orders. With respect to funds of
the Clerks Office, the Clerk is responsible for all expenditure-related functions.
(175) The nature of our audit required that we form judgments as to the propriety of
County expenditures. Our audit included an examination of the policies, procedures, and
records inherent in the accomplishment of the functions described in the preceding
paragraph, insofar as they pertain to the expenditures of the BCC and the Clerk. Our audit
disclosed a number of expenditures for which the BCC and/or Clerk had not adequately
documented: (1) the propriety of the expenditures (i.e., that they served a public purpose
and were in compliance with applicable laws, ordinances, and other guidelines); (2) the
amounts expended were reasonably determined in relation to the goods or services acquired;
and/or (3) the goods or services were acquired using good business practices (i.e., a
competitive selection process and/or written agreements). These expenditures totaled
$6,117,336 ($5,821,501 for the BCC and $295,835 for the Clerk), including $888,193
($868,758 for the BCC and $19,435 for the Clerk) that were unauthorized and/or
inadequately supported as to their propriety.
(176) Our detailed findings and recommendations concerning noncompliance with governing
laws, administrative rules, and other guidelines, as well as those detailed findings and
recommendations concerning the public purpose for particular expenditures and the adequacy
of documentation to demonstrate such public purpose, are presented under appropriate
headings below.
General Disbursements
Clerks Pre-Audit Procedures
(177) The Clerk had not implemented adequate pre-audit procedures to ensure that BCC
and Clerk expenditures serve an authorized public purpose and are in compliance with
applicable laws, ordinances, and other guidelines.
(178) As indicated in paragraphs 4 and 5, the Clerk is county auditor and custodian of
county funds and has a constitutional and statutory responsibility for pre-auditing the
expenditures of the BCC, as well as a responsibility for pre-auditing the expenditures of
the Clerks office. Our audit, as discussed under appropriate subheadings in this
report and in Exhibits B, C, D, and E, disclosed numerous inadequately supported and/or
improper expenditures. Based on the results of our audit, it was apparent that the Clerk
had not established adequate pre-audit procedures to ensure that BCC and Clerk
expenditures serve an authorized public purpose and are in compliance with applicable
laws, ordinances, and other guidelines. The absence of adequate pre-audit procedures was a
contributing factor to the questionable expenditures disclosed by our audit as discussed
in paragraph 175. We recommend that the Clerk implement appropriate pre-audit procedures
to ensure that BCC and Clerk expenditures serve an authorized public purpose and are in
compliance with applicable laws, ordinances, and other guidelines.
(179) Our test of expenditure vouchers disclosed several deficiencies in the
Countys disbursement processing procedures that could result in the purchase of
unauthorized goods or services, duplicate payments, or budget
overexpenditures.
(180) Our test of 60 BCC and Clerk expenditure vouchers totaling $83,649 disclosed
deficiencies in the Countys disbursement processing procedures. Specifically, for 58
of these expenditure vouchers totaling $83,621, including $82,163 of BCC expenditures and
$1,458 of Clerk expenditures, we noted one or more of the following deficiencies:
· In 13 instances, there was no documentation of purchase order approval prior to the
acquisition of goods or services. In 3 of these instances, the expenditure was not
supported by an approved purchase order. In the other 10 instances, the goods or services
were received prior to purchase order approval (the purchase orders were dated from 1 to
111 days after the invoice date). Prior approval of purchases of goods or services is
necessary to ensure that only authorized purchases are made and that sufficient budgeted
resources are available for the purchase. We recommend that the BCC and the Clerk review
and revise the Countys purchasing practices as necessary to ensure that purchases of
goods and services are properly approved prior to acquisition.
· In 9 instances, the payment voucher had not been signed as approved by authorized
County personnel prior to the disbursement of the funds. Failure to approve payments could
result in improper disbursements of County funds. We recommend that procedures be
implemented that require all payment vouchers to be signed as approved by authorized BCC
or Clerk personnel prior to the disbursement of the funds.
· In 58 instances, invoices submitted for payment were not properly canceled or
stamped as paid after payment. Failure to properly cancel all paid invoices could result
in duplicate payments. Although our tests did not disclose any duplicate payments, we
recommend that procedures be implemented to ensure that all invoices are properly
canceled.
(181) Failure to effectively control purchases can result in the purchase of
unauthorized goods or services, vendor billing disputes, and/or budget overexpenditures
(see discussion of budget overexpenditures in paragraph 50). The BCC and the Clerk should
ensure that the recommendations discussed above are promptly implemented.
Contributions to Nongovernmental Organizations
(182) The BCC made contributions totaling $128,661.97 to nongovernmental organizations
during the period October 1996 through June 1998 for which the BCC had not taken adequate
measures to ensure that the public funds were used for a specified public purpose.
(183) Article VII, Section 10 of the Constitution of the State of Florida, states,
" Neither the state nor any county, school district, municipality, special district,
or agency of any of them, shall become a joint owner with, or stockholder of, or give,
lend or use its taxing power or credit to aid any corporation, association, partnership or
person. . . ." According to Attorney General Opinion No. 96-90, the purpose of this
provision is " to protect public funds and resources from being exploited in
assisting or promoting private ventures when the public would be at most incidentally
benefited."
(184) The question of whether a governmental entity can make donations to or otherwise
use its resources to aid a nongovernmental entity has been the subject of several court
decisions and Attorney General Opinions. According to Attorney General Opinion No. 079-56,
the Florida Supreme Court has held that a governmental entity may utilize a nonprofit
corporation as a medium to accomplish a public purpose provided that certain conditions
are met. There must be a clearly identified and concrete public purpose as the primary
objective and a reasonable expectation that such purpose will be substantially and
effectively accomplished. Also, the governmental entity must retain sufficient control
over the use of the public funds by the nonprofit corporation. Similarly, in addressing
the issue of whether a board of county commissioners was authorized to donate moneys to a
nonprofit organization, the Attorney General, in Opinion No. 86-44, states that the board
must maintain some degree of control over the public funds to assure accomplishment of the
public purpose.
(185) Our audit disclosed the following contributions totaling $128,661.97 by the BCC
to nongovernmental organizations during the period October 1996 through June 1998 for
which the BCC had not, of record, identified the public purpose and/or made provisions to
ensure that the public funds were used for a specified public purpose:
· The BCC contributed a total of $87,750 to the Walton County Economic Development
Council, Inc. (WCEDC), during the period October 1996 through June 1998. At one time, the
BCC had a written agreement with the WCEDC dated in July 1990. According to that
agreement, the WCEDC was established for the purpose of encouraging the growth of existing
businesses, attracting new industry, and promoting sound economic development in Walton
County. However, because there was some question as to whether the agreement was still in
effect and whether WCEDC records were subject to the Sunshine Law, the County, in a
Resolution dated February 11, 1997, resolved that the previous agreement was no longer in
effect. The WCEDCs purpose as stated in the former agreement dated July 1990 appears
to be a valid public purpose; however, since February 11, 1997, the County has not had an
agreement in place specifying the purposes for which its contributions are to be used. In
addition, we noted that correspondence from the WCEDCs Executive Director dated
December 12, 1996, states that most of the WCEDCs public funds generally were not
earmarked and it was not possible to say which public dollars were used for which
expenses.
· The BCC contributed a total of $29,999.97 to the North Walton YMCA during the period
October 1996 through June 1998 (all of which was paid during the 1997-98 fiscal year).
Payments to the YMCA were made pursuant to BCC approval at its May 13, 1997, meeting. The
purpose for which the contributions were to be used is not stated in the minutes for that
meeting. Also, the County does not have an agreement in place specifying the purposes for
which its contributions are to be used. The BCCs Administrative Supervisor, in
response to our inquiry, stated that the YMCA promotes health, safety, welfare, education,
and fitness of youth.
· The BCC contributed $7,000 and $3,912 to the DeFuniak Springs and Freeport Little
Leagues, respectively, during the period October 1996 through June 1998. Of these amounts,
$5,000 paid to the DeFuniak Springs Little League, and $1,000 of the amount paid to the
Freeport Little League, were paid pursuant to BCC approval at its April 14, 1998, and
March 11, 1997, meetings, respectively (there was no evidence of BCC approval for the
other amounts paid to these organizations). The purposes for which these contributions
were made were not stated in the minutes of those meetings. Also, the County did not have
agreements in place specifying the purposes for which these contributions were to be used.
The BCCs Administrative Supervisor, in response to our inquiry, stated that the
little leagues promote health, safety, welfare, education, and fitness of youth.
(186) According to the BCCs Administrative Supervisor, a Walton County
Commissioner serves on the WCEDC board of directors, the YMCA provides a verbal report
every other month, and the DeFuniak Springs Little League provides a verbal report at
least annually. However, given the above-noted lack of written agreements, it is not
apparent how the BCC can maintain proper oversight as to the use of moneys provided to
these organizations. To ensure compliance with Article VII, Section 10 of the Constitution
of the State of Florida, we recommend that the BCC enter into written agreements with the
above-noted nongovernmental organizations, and any other such organizations to which the
BCC makes contributions, which state the specific purposes for which the contributions are
to be used and include provisions necessary for the BCC to maintain proper oversight as to
the use of moneys. Such provisions should include a requirement that the nongovernmental
organization maintain adequate records of its expenditures and the right of BCC staff to
examine such records.
Contributions to Governmental Entities
(187) In several instances totaling approximately $84,160, the BCC either incurred
expenditures on
behalf of, or made disbursements to, other governmental entities during the period
October 1996 through June 1998. The BCC had not, of record, demonstrated why these
expenditures were the responsibility of the County rather than the other governmental
entities.
(188) Pursuant to Section 125.01(1), Florida Statutes, the BCC is authorized to carry
on Walton County government to the extent not inconsistent with general or special law.
Within the boundaries of Walton County, there are several governmental entities, including
municipalities, special districts, a district school board, and a community college, that
have been created pursuant to State law and/or the State constitution. Pursuant to their
enabling legislation, each of these governmental entities is responsible for generating
sufficient revenues, through taxes, special assessments, fees, and other sources to allow
them to carry out their specified purposes as prescribed by law.
(189) Our audit disclosed the following instances totaling approximately $84,160 in
which the BCC either incurred expenditures on behalf of, or made disbursements to, other
governmental entities during the period October 1996 through June 1998:
· During the period August 1996 through November 1996, the BCC incurred $45,275 of
labor, equipment, and material costs on behalf of the Walton County District School Board
(DSB) for paving/construction work done at Walton Senior High School. In response to our
request for documentation evidencing that the BCC approved incurring these expenditures on
behalf of the DSB, the BCCs Administrative Supervisor stated that the BCCs
minutes do not reflect full board approval but that the expenditures were approved by the
former District 3 Commissioner. Although we were not provided with documentation
evidencing the BCCs intent regarding this matter, a letter dated July 24, 1997, from
the current District 3 Commissioner to the DSB indicates that he had previously billed the
DSB for $45,275. However, the BCCs Administrative Supervisor, in response to our
inquiry in July 1998, confirmed that the DSB had not reimbursed the BCC this amount.
· The current District 3 Commissioners letter dated July 24, 1997, indicates
that the BCC also incurred approximately $14,400 of costs on behalf of the DSB related to
resurfacing Walton Road and adding turn lanes into Walton Senior High School and Maude
Saunders Elementary School. In the letter, the current District 3 Commissioner further
stated, " It appears that approximately $14,400.00 should be added to the original
bill of $45,274.32 for the paving and construction of the turn lanes." Based on the
minutes for the BCCs November 12, 1996, meeting, it appears that it was the
BCCs intent for the DSB to participate in the cost of this project and to bill the
DSB accordingly. The BCCs Administrative Supervisor, in response to our inquiry in
July 1998, confirmed that the DSB had not reimbursed the BCC this amount.
· During the period September 1997 through November 1997, the BCC made payments
totaling $4,485 to a construction contractor for roof construction work on behalf of the
United Fire District. In response to our request for documentation evidencing that the BCC
approved incurring these expenditures on behalf of the Fire District, the BCCs
Administrative Supervisor stated that full Board approval was not required. Based on the
BCCs Administrative Supervisors response to our inquiry in July 1998, the Fire
District had not reimbursed the BCC this amount and had not been requested to do so.
· During the 1997-98 fiscal year as of June 30, 1998, the BCC made payments totaling
$20,000 to the Okaloosa-Walton Community College Foundation, Inc., to help support the
Okaloosa-Walton Community College (OWCC) Chautauqua Center. According to the minutes for
the BCCs May 12, 1998, meeting, the BCC did not intend for the OWCC to repay this
amount to the BCC.
(190) The question of whether a county government may utilize its resources for the
benefit of another governmental entity has been addressed on several occasions by the
Attorney General. For example, in addressing the issue of whether a board of county
commissioners could use moneys in its general fund to help operate a fire tax district
located within the county, the Attorney General, in Opinion No. 074-269, states that such
usage was doubtful as to legality. In the above instances, the BCC had not, of record,
demonstrated why these expenditures were the responsibility of the County rather than the
other governmental entities. In response to our inquiry, the BCCs Administrative
Supervisor cited several reasons why the use of County funds in this manner served a
public purpose. While we concur that they serve a public purpose, it is not apparent why
the BCC used County revenues in lieu of revenue sources available to the other
governmental entities.
(191) We recommend that the BCC seek legal clarification from the Attorney General as
to the legality of incurring expenditures on behalf of, or making disbursements to, other
governmental entities. We also recommend that the BCC continue its efforts to seek
reimbursement from the DSB and, if appropriate, based on the Attorney Generals legal
clarification, seek reimbursement from the United Fire District and OWCC for expenditures
made on behalf of, or to, those entities.