MANAGEMENT LETTER
City of Cincinnati
Hamilton County
801 Plum Street
Cincinnati, Ohio 45202
To the Honorable Mayor and Members of the City Council:
We have audited the financial statements of the City of Cincinnati, Hamilton County, Ohio (the City) in
accordance with Government Auditing Standards, as of and for the year ended June 30, 2018, and have
issued our report thereon dated December 28, 2018.
Government Auditing Standards require us to report significant internal control deficiencies, fraud,
(including noncompliance with laws and regulations), and also abuse and noncompliance with contracts
and grant agreements that could directly and materially affect the determination of financial statement
amounts. We have issued the required report dated December 28, 2018, for the year ended June 30, 2018.
2 CFR Part 200 subpart F requires that we report all material (and certain immaterial) instances of
noncompliance, significant deficiencies, and material weaknesses in internal control related to major federal
financial assistance programs. We have issued the required report dated December 28, 2018, for the year
ended June 30, 2018.
We are also submitting the following comments for your consideration regarding the City’s compliance with
applicable laws, regulations, grant agreements, contract provisions, and internal control. These comments
reflect matters that do not require inclusion in the Government Auditing Standards or Single Audit reports.
Nevertheless, these comments represent matters for which we believe improvements in compliance or
internal controls or operational efficiencies might be achieved. Due to the limited nature of our audit, we
have not fully assessed the cost-benefit relationship of implementing these recommendations. However,
these comments reflect our continuing desire to assist your government. If you have questions or concerns
regarding these comments please contact your regional Auditor of State office.
Noncompliance
115 Trust Fund Policy
The Collaborative Settlement Agreement Operative Settlement Terms Section Paragraph 25 states
that "Healthcare Funding Obligation: The City shall develop and present a proper funding policy for the
115 Trust Fund no later than 30 days prior to the Fairness Hearing. The funding policy will satisfy all consent
decree requirements including but not limited to the City's obligation to fully fund the 115 Trust at actuarially
appropriate levels for the term of this Agreement."
The City has not presented a proper funding policy for the 115 Trust Fund which fully funds the 115 Trust
at actuarially appropriate levels for the term of the Agreement.
Failure to present and implement a funding policy as required could lead to the City's accumulating an
unfunded liability for the 115 Trust and/or could lead to possible litigation for the City not being able to meet
healthcare requirements per the Agreement.
Corporate Centre of Blue Ash, 11117 Kenwood Road, Blue Ash, Ohio 45242 
Phone:  513‐361‐8550 or 800‐368‐7419          Fax:  513‐361‐8577 
www.ohioauditor.gov  

 City of Cincinnati
Hamilton County
Management Letter
Page 2
Noncompliance
(Continued)
We recommend the City develop a proper funding policy for the 115 Trust Fund and fund it at actuarially
appropriate levels sufficient to provide benefits for the term and as required by the Collaborative Settlement
Agreement.
Recommendations
1.

IT Operations – Disaster Recovery
In order to ensure minimal disruption to the services it provides, the City should maintain a disaster
recovery plan that identifies procedures to perform which facilitate the City’s continued processing of
information in the event of a disaster.
The City did not have a formal disaster recovery plan documenting processes/procedures to follow
in the event of a disaster.
Without an adequately documented disaster recovery plan with contingency arrangements for
alternate processing, the City may experience considerable and untimely delay in restoring its data
processing functions following a disaster.
The City should develop a formal disaster recovery plan. Upon its completion the plan should be
tested and updated periodically to ensure its applicability to the City’s data processing function.
The plan should include, but is not limited to the following:

2.



assessment of mission critical systems/prioritization of software applications



team member contact information



team member responsibilities



vendor contact information



evaluation of damages/planned contingency measures



hot site designation



hardware profile needs



data backup and restore procedures

Active Directory Password Parameters
System level users should be granted access to the accounts and functions they require to perform
their job. To help ensure this, passwords are used to authenticate the identity of the user attempting
to gain access to the system. To prevent the integrity of these passwords from being compromised,
passwords should be changed periodically and have a minimum length required.
The Active Directory passwords for the City are not set to industry standards.
These weaknesses increase the possibility that passwords could be compromised and attempts
could be made to gain unauthorized access to the system.

 City of Cincinnati
Hamilton County
Management Letter
Page 3
Recommendations
(Continued)
System level passwords should be changed periodically, as ninety days is the suggested standard.
The minimum length of a password should be at least six characters. All users should be assigned a
password.
In addition, passwords should be chosen so that they are not easily associated with the user to which
they were assigned. City management should routinely review system accounts to assess the
reasonableness and need for these accounts.
Authorized access control options (e.g., password change intervals, disabling accounts, authorized
privileges, etc.) should be reviewed and assigned on an as-needed basis only.
3.

IT Security – UNIX Passwords
System level users should be granted access to the accounts and functions they require to perform
their job. To help ensure this, passwords are used to authenticate the identity of the user attempting
to gain access to the system. To prevent the integrity of these passwords from being compromised,
passwords should be changed periodically and have a minimum length required.
The Unix passwords for the Financial, Payroll and Tax applications are not set to industry standards.
These weaknesses increase the possibility that these passwords could be compromised and
attempts could be made to gain unauthorized access to the system.
System level passwords should be changed periodically, as ninety days is the suggested standard.
The minimum length of a password should be at least six characters.
In addition, passwords should be chosen so that they are not easily associated with the user to which
they were assigned. City management should routinely review system accounts to assess the
reasonableness and need for these accounts.
Authorized access control options (e.g., password change intervals, disabling accounts, authorized
privileges, etc.) should be reviewed and assigned on an as-needed basis only.

4.

Collaborative Settlement Agreement – Collection of Class Counsel Fees
The Collaborative Settlement Agreement (CSA) Operative Settlement Terms Section
Paragraph 34 states in part any class counsel fees associated with representation of the Current
Employees Class will be ultimately paid back to the Cincinnati Retirement System (CRS) Fund by
members of that class from their pension benefits over time in a fair manner consistent with the terms
of the Class Notice."
In October, 2015 CRS assets were used to pay fees in the amount of $4.6 million to the attorneys
representing the Current Employee Class. The Board and CRS staff are unaware of any progress by
the various City and plaintiff attorneys to finalize a collection approach. There are currently 530
Current Employee Class members who are retired, and according to the CSA, are eligible to have a
portion of their pension benefit withheld to offset the attorney fees paid by CRS on their behalf.
Failure to collect the attorney fees is resulting in less funding for plan assets. We recommend the City
finalize an agreement with the Current Employees Class as per the CSA to recoup attorney fees paid
on behalf of the Current Employees Class.

 City of Cincinnati
Hamilton County
Management Letter
Page 4
Recommendations
(Continued)
5.

Park Board Trust Fund Endowment Expenditures
The City maintains four endowment funds to account for bequests left to the Park Board for specific
purposes. The Park Board should ensure that purchases made from endowment funds are consistent
with the purpose of the endowment.
The Park Board made certain expenditures from the endowment funds that were not related to the
purpose of the bequest. The following trust had expenditures which were in conflict with the purpose
of the endowment:


Meyer Trust, this trust is for park beautification however $5,000 was paid to KGL Media Group
for $5,000 for advertising.



Miles Edward Trust, this trust is for park beautification however $6,000 was paid to the Hamm
Consulting Group for consulting services.

Expenditures not related to the endowment funds should be made from City’s general fund or special
revenue funds restricted for Park activity. An adjustment of $11,000 is required from the General
Fund or special revenue funds restricted for Park activity to return $5,000 to the Meyer Trust Fund
and $6,000 to the Miles Edward Trust Fund.
Failure to properly document the purpose of each expenditure and ensure that the expenditure is in
accordance with the related bequest could result in Park Board spending bequests for other than
their intended purpose.
We recommend the Park Board establish policies and procedures related to credit card purchases,
travel/meal reimbursement and required documentation, timely payment of credit cards, and the use
of gift cards (including the reporting of gift cards to Park Board staff as taxable income). We
recommend that the Park Board document the purpose of each endowment expenditure and ensure
each endowment expenditure is in accordance with the bequest.
6.

Park Board Crowe Horwath Findings
The City of Cincinnati initiated a contract with the accounting firm of Crowe Horwath LLP wherein the
firm would provide financial analysis and advisory services relative to the Park Board, Parks
Department and Parks Foundation. Crowe Horwath issued a July 26, 2016 report that included the
following recommendations: the Park Board obtain a Memorandum of Understanding between the
Board, City and Foundation; the Park Board prepare a comprehensive budget of all sources of
anticipated revenues and expenditures; and the Park Board utilize a double entry accounting system
to track its activities and balances.
During the 2018 fiscal year:


The Park Board did not maintain a comprehensive budget of all sources of anticipated revenues
and expenditures. The Park Board prepared, approved, and monitored a budget for the Park
Board and the City of Cincinnati prepared a separate budget for certain Park activity accounted
for in the City funds.



The Park Board did not utilize a double entry accounting system to track its activities and
balances.

 City of Cincinnati
Hamilton County
Management Letter
Page 5
Recommendations
(Continued)
Failure to prepare a combined budget leaves the Park Board and City of Cincinnati without a complete
picture of Cincinnati Park activity and could result in inefficiencies, increased costs, and lack of proper
monitoring by the Park Board and Cincinnati City Council. Failure to use a double entry accounting
system increases the risk that errors, theft and fraud could occur and not be detected in a timely
manner.
We recommend the Park Board, Parks Department and Parks Foundation review and implement the
recommendations in the July 26, 2016 Crowe Horwath report.
7.

Lack of SOC 1 Report and Security Review
Entities opt to use outside service organizations to process transactions as part of the entity’s
information system. Service organizations provide services ranging from performing a specific task
under the direction of an entity to replacing entire business units or functions of the entity. When the
operating activity is not directly administered by the entity, such as when utilizing a service
organization, it is critical that appropriate monitoring controls are designed and implemented to
reasonably ensure the service organization has adequate controls to achieve management’s goals
and objectives and complies with applicable laws and regulations. SOC-1 audits are performed over
these service organizations to provide information about their internal controls and the operating
effectiveness of the controls to management and to auditors who rely on the SOC-1 report results for
the audit of the entity’s financial statements and IT systems.
The City Retirement System contracted with Levi, Ray, and Shoup (LRS) for a software hosting
agreement including hosting, backup, technical assistance, system enhancement, and system
updates of the Pension Gold application. The Retirement System also relied on the service
organization’s backup procedures and disaster recovery plan. LRS did have a SOC-2, Type 1,
however, a SOC-1 audit or internal security review was not completed for the Pension Gold
applications that would provide the Retirement System with information about the operating
effectiveness of the internal control over data processed at the service organization.
Without a SOC-1 audit, the Retirement System may not have sufficient information to reasonably
ensure controls are in place to ensure the integrity of the data processed, maintained, and reported
by the LRS software applications.
Future request for proposals and/or vendor contracts should include provisions for a SOC- 1 audit.
The Retirement System should also take measures to ensure that the SOC-1 audit is completed for
the LRS applications to provide the Retirement System and its auditors with a description of the
system, internal controls, operating effectiveness of the controls, and an opinion of the overall
processing environment.

8.

City Retirement – Disaster Recovery
In order to ensure minimal disruption to the services it provides, the Retirement System should
maintain a disaster recovery plan that identifies procedures to perform which permit the Retirement
System to continue processing information in the event of a disaster.
The Retirement System did not have a documented disaster recovery plan, and instead relied solely
on its hosting agreement with its third party software vendor pertaining to disaster recovery planning.
A SOC-1 audit or internal security review was not completed for the Pension Gold software
applications that would provide the Retirement System with information about the effectiveness of
the internal control over data processed at the service organization, including measures for disaster
recovery, including periodic testing of backups.

 City of Cincinnati
Hamilton County
Management Letter
Page 6
Recommendations
(Continued)
Without an adequately documented disaster recovery plan with contingency arrangements for an
alternate processing site, the Retirement System may experience considerable and untimely delay
in restoring its data processing function following a real disaster.
The Retirement System should document a disaster recovery plan. Upon its completion the plan
should be tested as possible and updated periodically to ensure its applicability to the Retirement
System’s data processing function.
9.

Employee Separation
Proper computer security requires that user accounts be disabled or removed from the system upon
employee separation.
Departments were responsible for notifying the Enterprise Technology Solutions (ETS) staff upon
employee separation as the City did not have an automated process for identifying separated staff.
ETS utilized a termination checklist for removing access rights to systems and applications. The form
was required by ETS, while other departments are encouraged to use the termination checklist. Upon
employee separation, ETS reviewed application software and network access rights to identify
access assigned to the former employee for necessary removal of rights.
Four ETS staff separated employment. For two of the four forms, most parts of the checklist were not
completed or signed off, as required.
As ETS was required to manually review access rights of separated ETS staff and ETS staff
inherently have higher access rights, documented review and termination of access rights for ETS
separated staff is crucial. Because the City employs 6,500 employees, some of which are part-time,
without an automated procedure, it is possible the ETS department will not be notified in a timely
manner regarding an employee separation.
The City should devise an automated procedure for notifying ETS upon employment separation to
help ensure access privileges of those no longer with the City are immediately removed or disabled
from the system. Until an automated process is implemented, ETS management should review and
sign-off on the completed termination checklist to help ensure it is completed.
The City should document a review of access rights for all separated staff to help reduce the likelihood
of unauthorized access. In addition, management should periodically review user accounts and their
privileges to help ensure access rights are consistent with assigned job responsibilities.

10.

Cincinnati Retirement System Benefit Payments
The Cincinnati Retirement System (CRS) was established by Cincinnati Municipal Code Chapter
203 as a defined benefit plan and provides for retirement benefits, including survivor benefits, based
on age, years of service and wages. The system has been continuously maintained since its
establishment, and has been modified from time to time in order to define and modify, as appropriate,
benefits provided to its Members. The system is overseen by a Board of Trustees, which operates
under the provisions of Article XV of the Adm. Code of the City.
Per Section 203.49 (Survivor Benefits), if a Member is survived by a spouse and a Retiree's natural
or adopted child or children including natural children of a Member conceived prior to the Member's
death, there shall be paid during the life of the surviving spouse to the surviving spouse or to the
guardian of such child or children in the event such child or children are not in the custody of the
surviving spouse for as long as only one child meets the eligibility requirements.

 City of Cincinnati
Hamilton County
Management Letter
Page 7
Recommendations
(Continued)
In fiscal year 2018, the CRS made benefit payments in the amount of $2,832 to a member's surviving
spouse and child however the child did not meet eligibility requirements. Because the child's social
security number was not maintained by the CRS pension gold system, the CRS was unaware that
the child did not meet eligibility requirements. Failure to have accurate identifying information in the
system resulted in the CRS making payment amounts based on inaccurate information and an
overpayment of $2,832. The total overpayment to the surviving spouse was $23,049 from May 2012
to March 2018. We recommend the CRS maintain identifying information for all members, surviving
spouses and eligible children.
11.

Application Level Access – Payroll
Proper computer security requires user accounts to be valid and access commensurate with their job
responsibilities. A comparison of the City staff roster to the payroll roster identified accounts that no
longer needed access to the system. This weakness increases the possibility the system could be
compromised and attempts be made to gain unauthorized access to the system. The City should
perform user confirmations at least annually requiring departments to confirm the user and their
access and informing ETS of users who do not need access to the system.

12.

Expenditure Posting
The City inaccurately posted $12,075 of General Fund expenditures to the Stormwater Management
Fund. Therefore expenses in Stormwater Management are overstated and General Fund
expenditures are understated. Failure to properly post expenditures may result in inaccurate financial
records. An adjustment of $12,075 is required to return the funds to the Stormwater Management
from the General Fund City Planning Department. We recommend the City use due care when
recording transactions associated with multiple departments or funds.

13.

Police earned overtime on the same day vacation or comp time leave was taken / No limit on
comp time accrual
In response to a March 2016 City of Cincinnati Internal Audit Report, the Police Department was
directed to conduct semi-annual audits of overtime and related policies, including the Department’s
policy on comp time accrual. On February 15, 2018, a Cincinnati Police lieutenant colonel presented
to the Police Chief the results of a semi-annual audit covering pay periods 1 through 26 of 2017.
We reviewed overtime and leave records of the 25 officers who were the subject from the February
2018 overtime semi-annual audit report and identified 20 officers that incurred overtime on the same
day they also used vacation or comp time. The amounts of overtime earned annually for these 20
officers ranged from $155 to $13,460, with the average annual amount earned being $2,506. The
number of days that overtime was earned on the same day vacation or comp time was also used
ranged from 1 to 60, with the average number of days being 11.85.

 City of Cincinnati
Hamilton County
Management Letter
Page 8
Recommendations
(Continued)

Police Personnel
Captain Bridget Bardua
Captain David Fink
Captain Aaron Jones
Captain Lisa Davis
Captain James Gramke
Captain Michael Neville
Lieutenant Mark Burns
Lieutenant Andrew Mitchell
Lieutenant Joseph Borger
Lieutenant Brian Norris
Sergeant Jason Volkerding
Sergeant Jason Scott
Sergeant Ronald Hale
Sergeant Timothy Lanter
Sergeant Colin Vaughn
Sergeant Brian Meyer
Sergeant Joshua Bricker
Officer Brian Wheeler
Officer Daniel R. Ogilvie
Officer Nicholas Hageman
Total

# of Vacation Days 
or Comp Time was 
taken and Overtime 
was earned
28
2
6
1
1
2
5
2
1
6
60
11
26
9
18
24
18
3
1
9
233

 Overtime earned 
on same day leave 
taken 
$   
     5,284.65
$   
    261.62
$   
    575.56
$   
    156.97
$   
    183.13
$   
    549.39
$   
    834.47
$   
    793.08
$   
    225.53
$   
     1,150.21
$   
   13,459.95
$   
     2,566.39
$   
     4,044.01
$   
     2,585.83
$   
     4,987.63
$   
     5,852.15
$   
     5,215.25
$   
    233.08
$   
    155.39
$   
     1,010.03
$   
   50,124.32

The City lacked clear policies related to earning overtime on the same day that vacation or comp
time leave was taken. While there are legitimate reasons for officers being called to duty on the
same day they have already taken leave, the City had no policy to provide clear guidance on the
approval and documentation of the reason for the overtime required. The lack of policy increases
the risk that officers could manipulate their schedules to obtain payment for overtime that is not
required.
We also noted that the City had no policy regarding how much comp time an officer can accrue
before either using the comp time or receiving a payout at the current wage for the accrued comp
time. We identified 21 officers in a sample of 25 that had accrued comp time ranging in hours from
2 to 677 hours and in value from $90 to $26,325. The average accrued comp time of the 20 officers
was 143 hours and $6,483 in value. Lack of policies regarding the accumulation of comp time could
result in a significant liability and related payout when officers retire and receive payouts for large
comp time balances at their current wage at retirement.
We recommend that the City establish policies to provide guidance on approval and documentation
of the reason overtime is incurred on the same day that vacation or comp time leave is also taken.
We also recommend that the City establish policies to establish limits on the amount of comp time
that individuals can accumulate and be paid upon separation at their current wage at retirement.

 City of Cincinnati
Hamilton County
Management Letter
Page 9
Recommendations
(Continued)
14.

Accuracy of Police Department Semi-Annual Audit Report
In response to a March 2016 City of Cincinnati Internal Audit Report, the Police Department was
directed to conduct semi-annual audits of overtime and related policies. On February 15, 2018, a
Cincinnati Police Lieutenant Colonel presented to the Police Chief the results of a semi-annual
audit which covered pay periods 1-26 of 2017. We identified inaccuracies between the amounts
reported in the semi-audit and the City’s actual payroll report for 22 of the 25 officers reported.
Amounts paid for overtime were overstated in the semi-annual audit by 6.4% and hours of
overtime were overstated by 7.1% as follows:

Police Personnel
Captain Bridget Bardua
Captain David Fink
Captain Aaron Jones
Captain Lisa Davis
Captain James Gramke
Captain Michael Neville
Captain Martin Mack
Lieutenant David Johnston
Lieutenant Mark Burns
Lieutenant Christine Briede
Lieutenant Andrew Mitchell
Lieutenant David Schofield
Lieutenant Joseph Borger
Lieutenant Brian Norris
Lieutenant Donald Luck
Sergeant Jason Volkerding
Sergeant Jason Scott
Sergeant Ronald Hale
Sergeant Timothy Lanter
Sergeant Colin Vaughn
Sergeant Brian Meyer
Sergeant Joshua Bricker
Total

 Total Overtime paid   Total Overtime paid 
per People Soft 
per Semi‐Annual 
(City) Pay Reports 
Audit Report 
$                 82,723.13 $                 72,606.42
$                 63,278.48 $                 51,054.45
$                 60,900.39 $                 59,750.58
$                 44,736.42 $                 46,384.60
$                 38,006.83 $                 25,927.50
$                 36,338.53 $                 32,673.28
$                 32,338.53 $                 28,313.44
$                 40,656.55 $                 40,487.40
$                 34,702.52 $  
   34,634.86
$                 31,393.98 $                 24,188.25
$                 28,163.24 $                 25,114.34
$                 27,358.09 $                 31,573.27
$                 26,184.20 $                 17,659.11
$                 23,085.40 $                 23,559.01
$                 18,592.81 $                 18,755.19
$              126,225.67 $              108,782.95
$                 92,215.14 $                 85,915.81
$                 83,245.36 $                 86,434.92
$                 68,699.40 $                 72,208.95
$                 59,014.77 $                 60,987.59
$                 54,325.86 $                 56,425.63
$                 49,242.65 $                 50,509.27
$           1,121,427.95 $           1,053,946.82

$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   

Variance
  10,116.71
  12,224.03
    1,149.81
   (1,648.18)
  12,079.33
    3,665.25
    4,025.09
   169.15
     67.66
    7,205.73
    3,048.90
   (4,215.18)
    8,525.09
  (473.61)
  (162.38)
  17,442.72
    6,299.33
   (3,189.56)
   (3,509.55)
   (1,972.82)
   (2,099.77)
   (1,266.62)
  67,481.13

 City of Cincinnati
Hamilton County
Management Letter
Page 10
Recommendations
(Continued)

Police Personnel
Captain Bridget Bardua
Captain David Fink
Captain Aaron Jones
Captain Lisa Davis
Captain James Gramke
Captain Michael Neville
Captain Martin Mack
Lieutenant David Johnston
Lieutenant Mark Burns
Lieutenant Christine Briede
Lieutenant Andrew Mitchell
Lieutenant David Schofield
Lieutenant Joseph Borger
Lieutenant Brian Norris
Lieutenant Donald Luck
Sergeant Jason Volkerding
Sergeant Jason Scott
Sergeant Ronald Hale
Sergeant Timothy Lanter
Sergeant Colin Vaughn
Sergeant Brian Meyer
Sergeant Joshua Bricker
Total

 Total Hours 
Overtime per 
Semi‐Annual 
Audit Report 
  1,054.00
   806.25
   775.95
   570.00
   484.25
   463.00
   419.00
   600.90
   512.90
   464.00
   416.25
   404.35
   387.00
   341.20
   275.00
  2,164.10
  1,581.00
  1,478.65
  1,177.83
  1,011.79
   931.40
   844.25
   17,163.07

 Total Hours 
Overtime per 
People Soft 
(City) Pay 
Reports 
   925.10
   650.50
   761.30
   591.00
   330.50
   416.30
   360.80
   598.40
   511.90
   357.50
   380.00
   466.65
   261.00
   348.20
   277.40
  1,865.10
  1,473.00
  1,481.90
  1,237.80
  1,075.55
   967.40
   890.80
   16,228.10

Variance
   128.90
   155.75
  14.65
  (21.00)
   153.75
  46.70
  58.20
   2.50
   1.00
   106.50
  36.25
  (62.30)
   126.00
  (7.00)
  (2.40)
   299.00
   108.00
  (3.25)
  (59.97)
  (63.76)
  (36.00)
  (46.55)
   934.97

Also, certain officers received significant amounts of actual overtime payments, with one officer
receiving over $108,000. While this overtime was approved and within Police Department policy,
the significant amount of overtime received by certain officers indicates that the Department may
need to reassess the current procedures for assigning overtime so certain individuals are not
burdened with a disproportionate amount of overtime, and other individuals have an opportunity to
work overtime if they are willing.
Inaccurate internal audit reports reduce management’s ability to monitor overtime hours and
accurately identify issues to be addressed. We recommend due care be used when performing
and reporting the semi-annual overtime audit. We also recommend that the Police Department
reassess the current process of assigning overtime.

 City of Cincinnati
Hamilton County
Management Letter
Page 11
Recommendations
(Continued)
15.

Inaccurate and Incomplete Overtime Forms
The City of Cincinnati Police Department Procedure Manual Section 12.825 Compensatory
Time and Paid Overtime states, in part: …personnel working overtime must complete and submit
a Form 68P, Overtime and Court Appearance Report by the end of the next working day after the
overtime work has been completed. Authorization must be given prior to the employee working the
overtime. Authorization of the pre-approval of overtime will be documented in the “Overtime preapproved by” block on the Form 68P in the form of a signature or name of the unit or name of the
supervisor authorizing the overtime. The Form 68P is then completed by filling out the “Duty hours”,
“Overtime hours” and “Reason” block. After the Form 68P is completed a supervisor must sign the
“Verified by” line after verifying the accuracy and completeness overtime documented on the form.
The completed Form 68P is approved by the employee’s supervisor and submitted to the payroll
timekeeper for entering into the PeopleSoft payroll system. Payment to the employee is based on
information submitted into the payroll system.
The Auditor of State obtained from the City’s PeopleSoft Pay Reports the amount of overtime paid to
the 25 officers reviewed in the semi-annual overtime audit to test the accuracy and completeness of
supporting 68P forms. The City provided 4,020 Form 68Ps for the fiscal year 2018 audit related to
overtime for the 25 officers. We compared the payroll amounts per PeopleSoft Pay Reports to
supporting documentation provided for audit. The overtime calculated from the forms was less than
the overtime actually paid for certain personnel indicating that the City did not provide all overtime
forms for personnel in the sample because the timekeepers required an approved Form 68P to make
the initial entry for overtime worked. The overtime calculated from the forms was more than the
overtime actually paid for certain personnel, indicating that that some of the overtime forms did not
contain accurate information:

 City of Cincinnati
Hamilton County
Management Letter
Page 12
Recommendations
(Continued)

Police Personnel
Captain Bridget Bardua
Captain David Fink
Captain Aaron Jones
Captain Lisa Davis
Captain James Gramke
Captain Michael Neville
Captain Martin Mack
Lieutenant David Johnston
Lieutenant Mark Burns
Lieutenant Christine Briede
Lieutenant Andrew Mitchell
Lieutenant David Schofield
Lieutenant Joseph Borger
Lieutenant Brian Norris
Lieutenant Donald Luck
Sergeant Jason Volkerding
Sergeant Jason Scott
Sergeant Ronald Hale
Sergeant Timothy Lanter
Sergeant Colin Vaughn
Sergeant Brian Meyer
Sergeant Joshua Bricker
Total

 Total Overtime Paid 
per People Soft (City) 
Pay Reports 
$   
      72,606.42
$   
      51,054.45
$   
      59,750.58
$   
      46,384.60
$   
      25,927.50
$   
      32,673.28
$   
      28,313.44
$   
      40,487.40
$   
      34,634.86
$   
      24,188.25
$   
      25,114.34
$   
      31,573.27
$   
      17,659.11
$   
      23,559.01
$   
      18,755.19
$   
    108,782.95
$   
      85,915.81
$   
      86,434.92
$   
      72,208.95
$   
      60,987.59
$   
      56,425.63
$   
      50,509.27
$               1,053,946.82

 Total Overtime 
Amounts per AOS 
Recalculation Based on 
Forms Provided for 
Audit 
$   
     72,155.13
$   
     51,250.67
$   
     60,060.60
$   
     47,012.48
$   
     25,998.14
$   
     33,513.07
$   
     28,548.90
$   
     39,540.17
$   
     34,624.71
$   
     24,492.71
$   
     24,486.49
$   
     30,856.08
$   
     17,659.11
$   
     22,811.38
$   
     18,274.81
$   
   108,698.38
$   
     86,467.00
$   
     86,835.92
$   
     70,511.24
$   
     58,598.84
$   
     55,743.21
$   
     50,506.36
$               1,048,645.40

$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   
$   

Variance
          (451.29)
           196.22
           310.02
           627.88
             70.64
           839.79
           235.46
          (947.23)
            (10.15)
           304.46
          (627.85)
          (717.19)
      ‐
          (747.63)
          (480.38)
            (84.57)
           551.19
           401.00
      (1,697.71)
      (2,388.75)
          (682.42)
              (2.91)
      (5,301.42)

From the forms provided for audit, 97 of the 4,020 (2.41%) were missing the required information
or had not been properly approved and verified for 22 of the 25 officers in the sample. 93 of the 97
forms with missing information and/or approvals were for overtime earned for a court
appearance. Missing information included the following: some cases of final supervisor approval
signatures, in and out times for court appearances, and how many hours were worked for an
overtime detail.
We recommend that all required forms be completely filled out, properly pre-approved and
verified, signed and retained, and consistent content detailed on each form.
Cincinnati Police Department December 10, 2018 Semi-Annual audit of overtime

16.

The Inspections Section of the Cincinnati Police Department conducted a semi-annual audit of
overtime for the first 13 pay periods of calendar 2018 (December 17, 2017 through June 16, 2018)
and issued a report dated December 10, 2018. The overtime audit included various
recommendations, including, but not limited to:


Officer schedules should meet the operational demands and minimize the use of overtime.



The Department should cross-train officers to allow for overtime reduction and the even
distribution of any overtime that is required.

 City of Cincinnati
Hamilton County
Management Letter
Page 13
Recommendations
(Continued)


Officers should carefully conduct overtime audits and remind officers that they are required to
have 15 minutes of separation between duty hours and outside employment details and
document the change in work locations.



Supervisors should assign duty hours based on the needs of the department and deviations
should not occur to facilitate outside employment or maximize overtime hours.



Supervisors should be attentive to detail when approving the overtime and verifying the Form
68P is filled out completely.

The December 10, 2018 overtime audit identified instances where officers signed up for outside
employment overtime using the Department’s Coplogic program and then worked duty hours or
received paid time off that overlapped the hours of the outside employment request. Officers should
complete a form 17DC if there is a change in their work assignments; however, in the
instances identified in the overtime audit report, no form 17DC was completed. The Department
referred these findings to the respective supervisors for further review and investigation to
determine if the findings were a result of a clerical error, or if officers received compensation from
two different sources for the same period of time. The Department addressed the concerns
outlined in the overtime audit and identified corrective action recommendations to be
addressed by the Department.
These recommendations included formal reminders to
individuals regarding departmental needs, off-duty detail policies and procedures regarding the
15 minutes of separation, failing to submit required forms, and the proper completion of payroll
paperwork.
The December 10, 2018 overtime audit also identified an officer who worked 80 hours in a two
week period, but worked more than 40 hours one week and less than 40 hours in the other week.
While the officer did not receive overtime, the potential existed for the officer to claim overtime for
the week she worked over 40 hours. We recommend that the Department require full-time officers
to work 40 hours each week of an 80 hour biweekly pay period.
We recommend that the Cincinnati Police Department implement the recommendations in
the December 10, 2018 semi-annual audit of overtime.
The Auditor of State will continue to monitor the corrective action recommendations addressed
by the Supervisors for any further violations of departmental procedures and policies.
We intend this report for the information and use of the governing board and management.

Dave Yost
Auditor of State
Columbus, Ohio
December 28, 2018