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HomeMy WebLinkAbout112-19 - Res. Adopting Mason County Capital and Trackable Asset Policies and Procedures RESOLUTION NO. A RESOLUTION for the Mason County Capital and Trackable Asset Policies and Procedures. Amending Resolution #78-16 and Mason County Code Chapter 3.56. WHEREAS, it is in the best interest of Mason County to revise the Capital Asset Policy to reflect(SAO) cash basis accounting since the County has implemented this method. NOW, THEREFORE BE IT RESOLVED by the Board of Mason County Commissioners, that we hereby adopt the Mason County Capital and Trackable Asset Policies. Adopted this?lotf November, 2019. BOARD OF COUNTY COMMISSIONERS MASON COUNTY, WASHINGTON ATTEST: Kevin Shutty, 114air Melis a wry, Clerk of the Board APPROVED AS TO FORM: Randy Neatherli , Commissioner Tim Whitehead, Chief DPA Sharon Tr as , Commissioner C:\Users\timw\AppData\Local\Microsoft\Windows\INetCache\IE\A3821DF4\Resolution CA.dooc 1 Policy 4��o� COa��A 'Mil Villilb.lik i , 1854 Mason County Capital and Trackable Asset Policies and Procedures I. PURPOSE: To establish a uniform policy and accounting for the County's real and personal property to ensure adequate stewardship of county resources through control,accountability and accurate capital/trackable asset listings and to establish departmental responsibility in the maintenance of the County's capital asset system. Mason County is on the cash basis of accounting as defined in the Washington State BARS Manual (Budgetary, Accounting and Reporting Systems). II. RESPONSIBILITY: All Mason County Departments are responsible for protecting and controlling the use of County assets assigned to their department. The department head/elected official must designate one or more employee(s) to be responsible for maintaining and safeguarding the department's capital and trackable assets ("inventory officer"). Any time an asset is added, deleted, or transferred; the inventory officer will complete or update a Capital Asset Project Form or Trackable Asset Form which will be submitted to the Auditor's Financial Services Department. Other suitable documentation, as determined by the Auditor's Office, may be submitted in lieu of the form. It is each department's responsibility to be familiar with and comply with SAO's BARS (Budgetary Accounting Reporting Systems) section regarding Capital Assets. III. DEFINITIONS: Ancillary charges: Costs that are directly attributable to capital asset acquisition and are necessary to place the asset into service in its intended location and use. BARS: Washington State Budgetary Accounting Reporting Systems. The Washington State Auditor's Office(SAO)designed and manages the chart of accounts for local governments within Washington State. In addition, SAO mandates accounting and financial reporting standards for local governments. 1 Buildings(and building improvements): The capital asset class that includes all buildings owned by the County. Components of a building, not normally replaced, are considered part of the building. Building improvements include subsequent additions of a new wing or extension, structural renovations and integral component replacement. There is a narrow definition for building improvements. Typically carpet, painting, roofing, minor remodel and the like are not capitalized for building improvements to existing buildings, only for new buildings. Capital asset: Tangible or intangible assets that meet all three of the following: a) it must have an initial useful life that extends beyond a single reporting period, i.e., one year; b) it must be used in the operations of the entity; and, c) it must not be specifically excluded by policy, e.g., capitalization threshold. Capitalization threshold: The minimum dollar value at which the County elects to capitalize its capital assets for financial reporting is $5,000 and an estimated useful life in excess of one year. All land is capitalized regardless of value. Capital assets are recorded at historical cost if purchased or constructed. Donated capital assets are recorded at estimated fair market value at the date of donation. Although trackable assets do not meet the county capitalization threshold, they are considered assets for purposes of marking and identification, records keeping, and tracking. Capitalize: To list the asset in the County inventory. All invoices coded as a capital expenditure (BARS account 594) should clearly identify which capital asset project it applies to. • A cost should be capitalized only if it is directly identifiable with a specific asset. The cost of a study undertaken to determine the best location for a new county building would not be capitalizable. • A cost should be capitalized only if incurred after acquisition of the related asset has come to be considered probable. The cost of a feasibility study should not be capitalized. • The cost of training employees to utilize a newly acquired capital asset should not be capitalized. Construction work-in-progress (CWIP, CIP): The capital asset class that includes the cost of assets under construction or in development. These costs are accumulated and moved to the appropriate asset class when substantially complete and/or placed in service. Construction work-in-progress is also referred to as work-in-progress (WIP) and construction-in-progress (CIP). BARS object code 65 should be used. Contributed/Donated assets: Real or personal property capital assets received in a voluntary non- exchange transaction from external parties and nonreciprocal transfer from another unit within the reporting entity. Disposal: The managed removal of an asset from the County's possession and retirement in the County's capital asset system. Estimated historical cost: Is an estimate of the value of an asset where actual historical cost is not available. An estimate may be derived using an alternative cost basis (e.g. current replacement cost)that is adjusted by an economic index to arrive at an estimate of the original historical cost. Fair value: Estimated dollar amount at which an asset might exchange between a willing buyer and a willing seller, neither being under compulsion, each having reasonable knowledge of all relevant facts, and with equity to both. "Estimated fair value" at acquisition may be obtained from manufacturers' catalogs or price quotes in periodicals, from objective appraisals, or similar sources. Estimated fair value is used in valuing donations. Furniture,machinery,and equipment:The capital asset class that includes all personal property acquired through purchase, donation, exchange, construction, evidence, conversion, etc. It generally includes all movable personal property and also plant equipment and other fixed equipment. 2 Grant funded assets: Capital assets purchased with grant funds and subject to specific requirements and instructions relating to recordkeeping, controls, and/or restrictions. Historical cost: The original cost of an asset at the time of acquisition including all ancillary charges (e.g., freight, installation, site preparation, etc.)to bring the capital asset to its intended location and its intended use. "Estimated historical cost" is an estimate of the value of an asset where actual historical cost is not available. An estimate may be derived using an alternative cost basis (e.g. current replacement cost)that is adjusted by an economic index to arrive at an estimate of the original cost. Impairment: A significant, unexpected decline in the service utility of a capital asset. Improvements other than buildings: The capital asset class that includes improvements to land other than those related to site preparation or conversion to a public road. This may include items such as airport runways, retaining walls, sidewalks, parking lots, ponds, landscaping, berms,fencing, outdoor lighting, etc. Inventory: The process of physically confirming the existence and location of capital and trackable assets. Infrastructure: Capital assets that are stationary or immovable in nature and that have useful lives that can be preserved over a longer time period than most capital assets. Roads, bridges, sidewalks, water lines, sewers, drainage systems and the like. Intangible assets: An asset that lacks physical substance, is nonfinancial in nature, and has an initial useful life extending beyond a single reporting period. Examples of intangible assets are easements, right of way, other land rights, patents, trademarks, licenses, permits and software. Land: The capital asset class that includes all non-depreciable land and all associated rights with land ownership. Land use rights: Land use rights may be purchased without the transfer of title and may include temporary easements, permanent easements, right-of-way, and development, air,timber and mineral rights. Land use rights are considered intangible assets. Loan: If a loan or bond is issued for the purchase of a capital asset, the transaction requires specialized accounting treatment. Proper budget authority needs to be established before the purchase is finalized. Personal property: All movable capital furniture, machinery, and equipment subject to an annual physical inventory. Purchased software: Software purchased and used without modifications. This does not include general software applications that are needed for basic computer operations or performing routine office tasks, the cost of which are normally bundled with the hardware cost or expensed. Real property: Land, buildings and building improvements, and improvements other than buildings. Substantially complete: The point at which construction is sufficiently complete in accordance with contract documents and the construction is determined to be ready for its intended use and/or occupancy. Surplus: Capital assets that are no longer used by the custodial department. Tag number: For personal property, a physical tag with a unique number that is affixed to the actual asset. For real property, the Assessor's parcel number should be used as the asset number. A number may be divided into a primary number and an attachment number suffix for attachments to the primary asset. 3 Trackable Assets(Small&Attractive Assets):Assets that are particularly at risk or vulnerable to loss and cost less than$5,000 but greater than$500 that have a useful life greater than a year. Certain assets such as cell phones and other electronics even they though have a value less than $500 should be tracked as well. These assets are mobile and might be easily replaced through a procurement system without raising suspicion. Examples include: • Computers, laptops, notebooks • Shop tools, public works power equipment • Handheld radios, other electronics • Monitors, tablets, phones, cameras • Firearms, tasers and related accessories • Televisions, video recorders Departments are responsible for reporting their trackable assets to the Auditor's Office Financial Services and maintaining good stewardship over them. Larger departments are encouraged to develop internal trackable policies following BARS guidance. Useful life: An estimate based on the known information regarding the type, expected use, and expected maintenance of the asset. It is the period of time during which a capital asset will provide service. IV. POLICIES: The County will report capital assets in the County's capital asset listing in accordance with BARS manual. The County will maintain a capital asset system to properly track and report the County's capital assets. Trackable asset inventories will be maintained at the department level but reported to the Auditor's Office. Capital Assets: The capitalization threshold is the minimum dollar value at which the County elects to capitalize assets. Expenditures that are greater than or equal to the threshold amounts and meet other capital asset criteria must be capitalized and recorded in the capital asset system, and as a capital expenditure in the general ledger. Thresholds generally should be applied to individual assets and not to the total of a group or with combined purchases, with the exception of infrastructure. Trackable Assets: Assets that meet the definition of a trackable asset will be included in the trackable asset inventory. Capital and trackable assets are recorded in the capital asset system at historical cost or estimated historical cost. Donated assets are recorded at fair value at the time of donation. The historical cost and fair value at the time of acquisition should include all ancillary charges necessary to place the asset in its intended location and condition for use. Collections(works of art and historical artifacts, for example)are capitalized at historical cost or if donated, fair value at the time of donation. Assets purchased, but not yet placed in service, are recorded in the capital asset system at their acquisition date. Ancillary costs should be included in the cost of a capital asset. However, minor ancillary costs, not measurable at the time a capital asset is recorded in an authorized property inventory system, are not 4 required to be capitalized but may be capitalized if the information becomes readily available. Ancillary costs include such items as: • Legal and title fees • Professional fees of engineers, attorneys, appraisers, financial advisors, architects, etc. • Surveying fees • Appraisal and negotiation fees • Site preparation costs • Costs related to demolition of unwanted structures • Transportation/freight charges • Sales and use tax • Installation costs • Warranties (excluding extended warranties) • Any other normal or necessary costs required to place the asset in its intended location and condition for use • Clean-up of known pollution at the time of acquisition • Relocation costs Capital assets acquired with grant funds must comply with all state, federal and grantor requirements and be identified as grant funded assets in the County's capital asset accounting system. Not all phases of capital project's constructed asset are capitalizable. Costs should be capitalized only if they are directly identifiable with a specific asset and only if incurred after the acquisition of the related asset has come to be considered probable (i.e. likely to occur). Thus the planning phase and preliminary design phase of a capital project are generally not capitalized. The final design phase, implementation phase and acquisition phases are capitalized. The close out phase which involves administrative processes and monitoring would generally not be capitalized, but rather expensed to operations. The County's infrastructure is on a cash basis of reporting. Improvements that increase the service capacity and functionality of infrastructure are capitalized. Other costs are considered maintenance and are expended in the period incurred. The Public Works — Road Services Division maintains the roads and bridges infrastructure historical asset records within a separate reporting system. Insurance recoveries related to impaired assets are reported net of the related loss when the recovery is realized or realizable in the same fiscal year as the loss. Otherwise, restoration or replacement costs of an impaired asset are reported as a separate transaction from the related insurance recovery. An annual physical inventory of personal property capital and trackable assets will be performed to verify their existence, location and status. An annual review of real property will be performed to verify accuracy and ownership status. An official listing of property records for all usable buildings, including those that fall below the capitalization thresholds will be maintained by Auditor's Financial Services. Personal property items are generally handled through each department. Real Property transfers and dispositions are handled by the Support Services Property Manager. Capital assets still in service remain on the books until disposed. Trackable assets are the responsibility of each individual County department but may be audited by the Auditor's Office Financial Services, SAO and outside asset inventory companies. 5 V. PROCEDURES: 1) Improvement/Repair/Maintenance Expenses Routine repair and maintenance costs will be expensed as they are incurred and will not be capitalized. Major repairs will be capitalized if they result in betterments/improvements. An improvement provides additional value. Such added value is achieved either by 1) lengthening a capital asset's estimated useful life (beyond original) or 2) increasing a capital asset's ability to provide service (i.e., greater effectiveness or efficiency); must be measureable. In contrast to improvements, repairs and maintenance retain value rather than provide additional value. Outlays will not be capitalized for a project that replaces the old part of a capital asset. 2) Additions The county may acquire property by purchase, construction, donation, or lease. Capital assets shall be capitalized and purchased from an object code capital BARS line known as the"60's": 61 - Land and Land Improvements 62 - Buildings and Structures 63-Other Improvements 64- Machinery and Equipment 65-Construction of Capital Assets, Construction in Progress (CIP) Trackable assets will use: 535099—Trackable Assets—Standard 535098—Trackable Assets— IT (Information Technology) The buyers name must be Mason County, not individual departments. When a capital/trackable asset is purchased,the department will complete an asset form or other approved documentation. The documentation is sent to the Auditor's Financial Services Office with the voucher. The department should use a unique asset tag number (available from Financial Services) or similar method which will be used for inventory purposes. If possible, the department should identify the asset as Mason County property on the tag, and the tag shall be affixed on the principal body of the asset. Damage or lost tags should be replaced with a new inventory ID tag. Tags may be removed when the asset is sold or disposed. Occasionally it may be impractical or impossible to tag a capital asset, for example: • The asset is stationary and not susceptible to theft (such as land, infrastructure, buildings, and improvements). • The asset has a unique permanent serial number that can be used for identification (such as vehicles). • The asset would lose significant historical or resale value by the tag. • The asset would have its warranty negatively impacted. For these assets, the department should apply alternative procedures for identification and inventory. 3) Deletions Asset deletion may be required due to the sale of the asset, scrapping, lost or stolen, or involuntary conversion (fire, flood, etc.). Due to the monetary value, capital assets deleted from the capital asset system for any reason require the department to complete the Capital Asset-Project Form, Asset Disposal Information section. Trackable assets use a similar method. 6 Equipment acquired under a grant or sub grant that is no longer needed for the original project may be disposed as follows: • Equipment with a current per-unit fair market value of less than $5,000 may be retained, sold, or otherwise disposed of with no further obligation to the awarding agency. • Equipment with a current per-unit market value of $5,000 or more may be retained, sold, or otherwise disposed of only as authorized by the agency that awarded the grant. If the county is provided with federally owned equipment: • Title will remain vested with the federal government. • The county will manage the equipment in accordance with federal agency rules and procedures, and submit an annual inventory listing. • The county will request disposition instructions from the federal agency when the equipment is no longer needed. 4) Lost or Stolen Assets When suspected or known losses of capital/trackable assets occur, departments should conduct a search for the missing property. The search should include transfers to other departments, storage, scrapping, conversion to another asset, etc. If the missing property is not found: • Notify the department head and the employee responsible for department inventory. • The department shall prepare a signed statement to include a description of the events surrounding the disappearance of the property, who was notified of the loss, and steps taken to locate the property. A copy of the report will be sent to the Auditor's Financial Services Office. • The Auditor shall report the suspected asset loss to the State Auditor's office in accordance with RCW 43.09.185, and a copy of the report shall be given to the Board of County Commissioners. • The lost or stolen property shall be removed from the department's inventory and accounting records. 5) Asset Transfers Occasional transfers of property may occur between departments or funds. The original controlling department is accountable for all assets in its inventory and for initiating a notice of transfer. The sale price will be fair market value, which may result in a gain or loss on the sale of capital assets. 6) Asset Modifications Large assets such as equipment, water or sewer lines, and many buildings are often modified to increase their lifetime or usefulness. Modifications may include partial additions or deletions, major repairs (new engine for truck), or component replacement(new roof, heating system, etc.). Several vouchers may be prepared for the modification as the work progresses. Therefore it's very important to notify the Auditor's Financial Services Office that modifications are coded as capital outlay. The inventory number of the asset being modified should be included on the voucher. 7 7) Asset Inventory A physical inventory will be conducted at least once every year. Around January of each year, Support Services will provide a Department Asset Accountability Form to each department which contains all Department's equipment with a value of$5,000 or more as of December 31 St of the prior year. The Auditor's Office Financial Services will send a form for the remaining capital assets (land, buildings, other improvements, infrastructure and intangible). Each department will conduct a physical inventory of the items, verifying the existence and condition of each item on the form, and making note of any additions, deletions, interdepartmental transfers, modifications, or leases of the items that are not reflected on the form. Verification of inventory may be done annually by the Auditor's Office Financial Services by performing a sampling of inventory items. Each County Department is responsible for its Trackable Asset inventory but it is subject to audit and verification by Financial Services. 8 2 SAO BARS Capital Asset Management 3. ACCOUNTING 3.3 Capital Assets 3.3.8 Capital Assets Management 3.3.8.10 Definitions Capital assets are real and personal property used in operations, above a specified value, the government intends to use or keep for more than one year. Capital assets include land and land rights; buildings, their furnishings, fixtures, and furniture; infrastructure assets, intangible assets equipment, machinery,vehicles,and tools. Capitalize means to report an expenditure for real and personal property or intangible assets as a capital outlay. These expenditure transactions are coded to 594 and 595 account codes. Accountability means the obligation to demonstrate good management of or control over those matters for which the government is responsible. Capital assets management system is the set of written policies and procedures used to control a government's capital assets and demonstrate accountability. Public officials have several broad responsibilities with respect to capital assets such as tracking assets for accountability purposes; maintaining records for insurance purposes; ensuring assets are safeguarded from loss,waste, damage, or neglect; for compliance purposes such as when purchased with federal funds; and long term capital budgeting and planning. Capitalization threshold is a dollar amount set in a formal policy defining when an item with more than one or more years of usefulness will be classified as a capital asset. Physical inventory is a procedure where the existence of assets on the inventory list is confirmed by physically observing the assets at their location in the field. Small and attractive assets are assets that last longer than one year, but do not qualify as capital assets. They are less than the capitalization threshold and may be susceptible to theft or misuse. 3.3.8.20 Reporting Capital Asset Transactions Cash basis accounting only reports inflows and outflows of cash. When a capital asset is purchased the entire expenditure is recognized in the period as "capital outlay" when the cash outflow occurs. Because the entire asset cost is reported when it was purchased the reporting of depreciation accounts is not appropriate. Determination of when a purchased item is classified as a capital asset (and reported as a "capital outlay") will depend upon the capitalization threshold established in policy of the government. Each government should establish a formal policy that includes a capitalization threshold. The cash basis financial reporting requirements for capital assets are limited; however, this does not remove the responsibility of the government from its stewardship of public resources. Entities must have policies and procedures in place to track, demonstrate accountability and ensure security of their capital assets. • 3.3.8.30 General Tracking Requirements Specific capital asset tracking requirements of the State Auditor's Office are contained on the subsequent pages. In addition,the federal government has issued property management requirements that apply to all governments that receive federal assistance. Title 2 of the Code of Federal Regulations (CFR) sections 200.310-316 outlines specific requirements related to real property, equipment, supplies and intangible property purchased with federal funds. Note that these requirements involve broad stewardship responsibilities and specific accounting records. 3.3.8.40 Establishing Capital Assets Policies The duty to make certain that public property is adequately protected and that its use is properly managed is one of the fundamental responsibilities of government officials. Local governments with capital assets should develop policies and procedures for management of these public resources. At a minimum the policies should be reviewed and approved by the governing body. Once a policy is adopted, it should be periodically reviewed and updated to ensure it meets the needs of the local government. The following are items the government must consider when developing policies for tracking and safe guarding their capital assets. • Capitalization Threshold. Governments must set the dollar amount at which the purchase of an asset with a useful life of more than one year will be classified as a capital asset, for which the expenditure will be recognized as a capital outlay. The cost of maintaining the information versus the benefit of the information should be evaluated when setting the threshold. The amount of the capitalization threshold is up to the government and may vary. Many governments have set their policy at$5,000. • Inventory Requirements. Policies should require inventories at reasonable intervals to verify the existence and condition of capital assets. The policy should define the categories or types and threshold of assets to be inventoried. These policies should require an inventory interval based on the nature of assets, number of assets and extent of decentralization. The policy should also assign overall responsibility for conducting the inventory — ideally by personnel other than those charged with custody of the assets. The policy should include how to follow up on damaged or missing assets, including when inventory results or issues are communicated to the governing body. The policy should direct losses of public resources to be reported to our office,as required by state law. Inventory policies should conform to any statutory or regulatory requirements, such as the requirement for counties to inventory all capital assets per RCW 36.32.210 or the requirement for all assets over$5,000 per unit purchased with federal grant funds to be inventoried at least once every two years per the 2 CFR§200.313. • Recordkeeping. Policies should address how the capital assets will be tracked and what records will be maintained for operational and accountability purposes. Governments should maintain records of what they own, where it is located, the condition, and who is responsible for the asset. Records should be sufficient to prove any losses for insurance purposes. Inventory and maintenance records will confirm that a lost or damaged asset has been in use recently, which will support the validity and timeliness of a theft or damage report. Specific information captured may vary by type of asset. • Disposition Procedures. To the extent procedures are not defined by statute(such as Chapter 39.33 RCW for intergovernmental disposition of property, or property sales for ports in Chapter 53.08 RCW, etc.), policies should define authority and authorized procedures for determining assets require replacement or are otherwise surplus, and their subsequent disposition. • Asset Replacement. Policies should provide sufficient direction on when assets should be replaced. Replacement may be based on a set schedule, based on specified conditions, or delegated to specified staff positions or groups to determine or recommend on an asset-by- asset basis. Replacement policies often differ by asset type and should be established to align with and support the governments capital budgeting and planning process. 3.3.8.50 Small and Attractive Assets These are assets that are below the government's capitalization threshold for financial statement reporting purposes and last longer than a year, but may be susceptible to theft or misuse. Each government should perform an assessment to identify those assets that are particularly at risk or that otherwise need to be tracked for operational purposes. Governments should implement specific measures to track and control these assets to minimize identified risks, as appropriate for the nature of the assets, value of the assets, and risks. Controls may range from basic measures such as policies, tagging, assigned custody, restricted access or other physical controls - to limited systems such as check-out systems or reserve inventories(where only items not in use are tracked)—to comprehensive tracking and inventory controls such as that done for capital assets (compete tracking lists, periodic physical inventories, see below for more information). Governments should also consider the cost/benefit of tracking certain types of assets and the resources it has available when establishing control measures, as compared to the risks involved. The SAO Resource Database provides an additional tool Best Practices for Small and Attractive Assets designed to help local governments develop policies and procedures related to small and attractive assets. 3.3.8.60 Capital Asset Tracking System When a government has capital assets it must establish and maintain a tracking system for them. It may be maintained using either a computerized or manual system. The tracking system must adhere to the formal asset policies approved by the governing body. It must include: 1) Inventory list containing capital assets owned by the government. 2) Individual information record for each capital asset: • Detailed description • Location of the asset • Cost of the asset/source of funding(federal grant, etc.) • Estimated life • Condition of the asset • Identifying number for the asset • Disposal—date and method used to determine disposal value Note: These components are expected to be included in the inventory for counties prepared in accordance with RCW 36.32.210. 3) A reconciliation of asset records and performance of a physical inventory. The capital assets list and individual asset records should be compared/reconciled. This is to assure the addition of new assets and removal of old ones are updated in both sets of records. Reconciliations should be performed at least once per year. 4) Adequate internal controls over additions and deletions to the capital asset tracking system. 5) A method to track changes in custody and assigned responsibility for the assets. 3.3.8.70 Uniform Guidance—Property Mana¢ement Capital assets purchased with federal funds are subject to federal property standards found in 2 CFR §§200.310-316. The requirements are known as the Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards (Uniform Guidance). They apply whether the assets are purchased in whole or in part with federal resources and are in addition to the accountability requirement prescribed by our office. The federal rules are in effect during the time the asset is owned by the government until official disposition has occurred. Also, government should be aware some federal agencies may publish deviations from the Uniform Guidance due to statutory requirements. 3 SAO BARS Best Practices Small & Attractive Assets (Trackables) Office of the Washington State Auditor ‘4 tit 9SBING� Performance Center Best Practices for Internal Controls over Small and Attractive Assets What are small and attractive assets? Small and attractive assets are below the government's established capitalization threshold for financial statement reporting purposes, and might be susceptible to loss, theft or misuse. These assets last longer than a year, are mobile and might be easily replaced through a procurement system without raising suspicion.Although they can vary by government, some examples include: • Computers,laptops,notebooks • Shop tools,public works power equipment • Handheld radios, other electronics • Monitors,tablets,phones, cameras • Firearms,Tasers and related accessories • Televisions,video recorders Are there requirements for state and local governments to follow? State agencies in Washington must follow the State Administrative and Accounting Manual (SAAM), which establishes guidance over small and attractive assets in section 30.40.20. State governments should perform a risk assessment and develop written policies for managing small and attractive assets or at a minimum track specific assets as required by the manual. The Budgeting,Accounting and Reporting System (BARS) Manual and the Accounting Manual for Public School Districts in the State of Washington provide guidance for local governments in Washington. Local Governments are expected to have internal controls in place over these assets to safeguard them from misuse or loss; however the extent of controls may vary by asset type. In addition,grantors might impose requirements when assets are purchased with grant funding. For example,if a government purchased assets with federal funds,certain tracking,inventory and disposal requirements apply.The Code of Federal Regulations (CFR) 200.310-316 outlines specific requirements related to real property,equipment, supplies and intangible property purchased with federal funds. Why are internal controls over small and attractive assets important? Conducting an inventory of and tracking assets reduce the possibility of misappropriation, and detect misappropriation should it occur. Internal controls over small and attractive assets also might: • Protect public safety or limit public liability(such as with firearms) • Provide records for insurance purposes or for completion of police reports,helping to prove ownership • Demonstrate compliance with grants or other requirements • Safeguard sensitive or confidential information (such as with tablets, USB drives or cell phones) • Track for assignment, cost control or re-order purposes (such as with uniforms,badges or computer equipment) June 2018 Best Practices for Internal Controls over Small and Attractive Assets 11 Should governments track all small and attractive assets regardless of monetary value? Governments have flexibility in this area, depending upon their risk assessment and how they structure their policy.A government may achieve this flexibility and limit tracking small-dollar items by employing one or more of the following approaches: • Threshold.Governments may elect to establish a threshold to limit tracking smaller dollar items.State agencies in Washington must use a$300 threshold for laptop and notebook computers and a$1,000 threshold for other assets such as desktop computers,television sets and cameras (for a complete list, refer to the SAAM).All weapons,firearms,signal guns and their related accessories must be accounted for regardless of the dollar amount. Local governments are not required to follow these requirements,but should consider them. • Specific exclusions.A government may choose to include or exclude certain types of assets based on the results of a risk assessment.Excluding asset types that typically have low monetary value can achieve the same purpose as establishing a threshold. For example,a government might choose to track computers but not peripheral devices,such as monitors,keyboards and scanners. Governments might find exluding certain asset types is more effective than establishing a threshold and results in clearer guidance. Regardless of the method employed, care should be taken to ensure the government is not spending resources tracking and monitoring items that might not be worthwhile. What is a risk assessment? A risk assessment helps to identify those assets that are most vulnerable to loss. It should be conducted before developing a policy and periodically as changes occur to update the policy. According to the Office of Financial Management's"Small and Attractive Capital Asset Risk Assessment Guidelines,"an assessment should consider: • Public perception about what the government should be tracking • Operational risks with data security,such as on mobile devices • Tracking or monitoring that may already be done for operational purposes • Pre-existing controls (such as an asset beingstored in a secured location) • Recent problems with missing or unusable equipment • New asset types being purchased • Degree of decentralization and how this affects risk • Ease to sell or convert to personal use • Perceived risk associated with the asset • Replacement cost compared with the cost to track it The risk assessment's purpose is to consider which assets are most susceptible to theft, loss or misuse and then decide the extent of internal controls that should be put in place to safeguard the assets. These decisions can be affected by the risk tolerance of the government's officials and available resources. For example, a government might decide laptops should be inventoried quarterly because of their mobility and data security concerns,but that stationary computers that are observed by management daily could be inventoried semi-annually. Local governments should document the risk assessment and periodically revisit it when circumstances change. The assessment results should be helpful in developing a government's policy. June 2018 Best Practices for Internal Controls over Small and Attractive Assets 12 What elements should be considered in a small and attractive asset policy? A policy should identify the asset types to be covered as well as those to be excluded. If the government desires a minimum threshold to avoid tracking smaller dollar assets, policy should address the amount and whether it applies to all asset types.It is a best practice to establish expectations entity-wide in a policy rather than leave it to each individual department to establish them.The policy could include general information such as how the asset should be treated (e.g., handled with care) and maintained, and if personal use is permitted (if not covered by a different policy).The policy should also include: • Expectations about asset tracking.The policy should address who is responsible for tracking the various asset types. For example,its important to address situations where there could be confusion,such as whether the IT department or the individual department(where the equipment is located) is responsible for tracking computer-related assets. The policy should also address how often the small and attractive asset list should be updated.A best practice is to update it promptly upon receipt of the asset. However, some governments wait until the asset is placed into service. The policy should also address how the assets will be safeguarded,tracked and monitored.These efforts can vary by asset type and may include various levels of controls: o Basic controls.Examples include tagging assets as identifiable to the government,assigning custody to specific individuals,or restricting access except for specific authorized personnel. o Limited controls.These include check-out systems or reserve inventories (where only items not in use are tracked). o Comprehensive controls.This is a tracking system ranging from a handwritten record to a spreadsheet,database or software module,as well as periodic physical inventories. • Segregating duties or oversight.The policy should address how duties will be segregated,or alternatively how oversight and monitoring will be conducted to compensate if duties cannot be segregated. There are several instances when segregation of duties can be an issue: o The person conducting the inventory also has responsibility for the assets (this would be akin to checking yourself). a The person tracking assets(e.g.,maintaining the list) also has access to the assets during the ordering/ receiving process,daily use or surplus process.The risk is that the person who has access to the master list might make unauthorized changes to it to conceal theft or loss. o The asset custodian has the authority to purchase replacement assets. • Inventory-process requirements.The policy should include expectations about the frequency of inventories,who will conduct them and how they will be documented. In addition,variances or missing items are likely to occur at some point,and the process should address how these discrepancies will be resolved.Governments should be aware that longer time between inventories can make it more difficult to follow up on discrepancies.The policy should include a process for reporting stolen or damaged items, as well as who will be responsible for reporting losses to the State Auditor's Office in accordance with state law(RCW 43.09.185).Additional information about what and how to report is located on our website at www.sao.wa.gov. • Disposal procedures.The policy should consider various risks relating to the disposal process.Assets could be misappropriated(or the sales proceeds diverted or used for unallowable purposes) at the point assets are no longer needed for operational purposes and ready to be surplused. In addition,there can be conflicts of interest where the employees responsible for managing asset sales are also interested in acquiring them. Further,some assets might require special handling or consideration during disposal, such as equipment with sensitive information or firearms that have certain requirements if they are sold to third parties.Governments should also be aware of any specific requirements for surplus procedures for their municipality type. Disposal procedures may also be drafted and referred to as a separate policy. June 2018 Best Practices for Internal Controls over Small and Attractive Assets 13 What are best practices for identifying and tracking assets? Assets should be visually identifiable as belonging to the government, as well as tagged or marked with an asset number that traces back to an inventory list. Inventory lists should have enough information to uniquely identify the assets, such as detailed descriptions with serial numbers. An asset's location and custodian are important to include on the inventory list to provide accountability and so that the items can be easily located at any time by the government or during an audit.Inventory lists should also comply with federal requirements,if applicable.Federal requirements call for property records to include specific information (CFR 200.313). What are the best practices for maintaining the inventory list? The Government Finance Officers Association's (GFOA)best practice guidance indicates tracking should occur at the departmental level with oversight from the central accounting function or other designated finance function. It's best to avoid duplicating tracking efforts if possible. However, if multiple lists are in use for the same asset type, such as one for finance and another for operational purposes, then they should be reconciled to each other periodically. The inventory list should be maintained by staff who are independent of the assets they are tracking, meaning they do not have custody of the assets at any point in the asset's life cycle. Governments should avoid the risk that an employee could take an asset and delete the corresponding asset record from the inventory list without detection. If this separation of duties is not feasible, then compensating controls need to be established. These controls likely would involve periodic supervisory reviews to spot check that the inventory list is being maintained and is complete. The list should be kept current and periodically monitored to ensure it completely accounts for all assets expected by policy. Ideally, a list should be updated as purchases, assignments or disposals occur. Governments are discouraged from allowing lists to become out of date. What are the best practices for conducting the asset inventory? The frequency of an inventory may vary by asset type. State agencies must perform inventories at least every other fiscal year but otherwise have flexibility in establishing a schedule. Local governments should use their risk assessment results to determine the nature and frequency of the inventory process,keeping in mind the resources available and other mitigating factors. For example, an asset that is used daily by a specific employee to perform job duties that are subject to daily supervision might not need the same level of oversight as assets that are available and used by many employees on a semi-infrequent basis. In the first instance, it's possible the inventory could be done when the assets are assigned or reassigned. Local governments should be mindful of the applicability of federal requirements for inventories. Current requirements (CFR 200.313) for equipment call for a physical inventory at least once every two years. Inventories are most effective when conducted by someone other than the person responsible for the asset; otherwise, oversight controls shouldbe put in place. An example of an oversight control might be periodic spot checks to confirm the asset's existence. In addition to identifying missing assets,inventory procedures may include objectives such as determining: • Whether all existing assets are included on the inventory list • Property is marked with the government's name,tagged, or properly secured • Location shown on the list corresponds to the actual location • Description shown on the list corresponds to the asset's actual appearance and features • Damage or misuse Governments should ensure the inventory results are documented, any variances or issues are resolved promptly, and the inventory list is updated based on the inventory results. June 2018 Best Practices for Internal Controls over Small and Attractive Assets 14 Additional references/resources • Government Finance Officers Association's best practices guidance- "Control over Items that Are Not Capitalized" (2005):www.gfoa.org/control-over-items-are-not-capitalized • State of Washington Office of Financial Management, "Small and Attractive Capital Asset Risk Assessment Guidelines":www.ofm.wa.gov/resources/capital_assets/CAsmallattract.pdf • Budgeting,Accounting,and Reporting System (BARS) Manual- "Controls over Capital Assets GAAP entities)"or"Capital Asset Management (cash entities)":www.sao.wa.gov/local/Pages/BarsManual.aspx • State Administrative and Accounting Manual (SAAM) - Section 30.40.20: www.ofm.wa.gov/sites/default/files/public/legacy/policy/30.40.htm • The Code of Federal Regulations 2CFR 200 - Section 200.310-316: www.gpo.gov/fdsys/granule/CFR-2014-title2-vo ll/CFR-2014-title2-voll-sec200-310 For assistance This resource has been developed by the Performance Center of the Office of the Washington State Auditor.Please send any questions, comments or suggestions to performance@sao.wa.gov. June 2018 Best Practices for Internal Controls over Small and Attractive Assets 15 4 Capital Asset Project Form Mason County Capital Asset-Project Form ASSET/ACQUISITION INFORMATION: Fund Name(s): Fund Number(s): BARS No(s) Used: Asset Code/Grant/Project No: Will this asset be contributed to ER&R? Asset/Acquisition Description: Asset/Acquisition Location: Estimated Life of Asset/Acquisition: Serial Number: (if applicable) Model Number: (if applicable) Acquisition Date: Total Costs/Estimate: Project Begin /Complete Date: Vendor(s) Number: Special insurance, maintenance, repair, etc. instructions or needs: Signature of Department Custodian: PHYSICAL VERIFICATION OF ASSET Verification by: Date: Asset Tag#: Condition: Comments: ASSET DISPOSAL INFORMATION Sold/Traded To: Disposition Date: Receipt Number: Disposition Authorization: Date: Grant Source: Grantor Notified On: Grantor Disposal Instructions: Proceeds of Sale/Insurance Claim Less: Net Book Value Gross Gain (Loss) Less: Amount Due to Grants Net Gain (Loss) $ - *Excerpt from State Auditor's BARS Manual 5 Trackable Form Mason County Trackable Asset ASSET/ACQUISITION INFORMATION: Fund Name(s): Fund Number(s): BARS No(s) Used: •Asset Code/Grant/Project No: Will this asset be contributed to IT? Asset/Acquisition Description: Asset/Acquisition Location: Estimated Life of Asset/Acquisition: Serial Number: (if applicable) Model Number: (if applicable) Acquisition Date: Total Costs/Estimate: Project Begin/Complete Date: Vendor(s) Number: Special insurance, maintenance, repair, etc. instructions or needs: Signature of Department Custodian: PHYSICAL VERIFICATION OF ASSET Verification by: Date: Asset Tag #: Condition: Comments: ASSET DISPOSAL INFORMATION Sold/Traded To: Disposition Date: Receipt Number: Disposition Authorization: Date: Grant Source: Grantor Notified On: Grantor Disposal Instructions: Proceeds of Sale/Insurance Claim Less: Net Book Value Gross Gain (Loss) Less: Amount Due to Grants Net Gain (Loss) $ - *Excerpt from State Auditor's BARS Manual