[Final Audit Report  Concession Management and Fee Collection Operations, St. Croix National Park, National Park Service]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. V-IN-NPS-0004-2003-A

Title: Final Audit Report ï¿½Concession Management and Fee Collection
       Operations, St. Croix National Park, National Park Serviceï¿½

  

Date:  December 30, 2003

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Memorandum


To:  Joel Tutein, Superintendent ï¿½ St. Croix National Park

From:  William J. Dolan, Jr., Regional Audit Manager, Eastern Region

Subject:  Final Audit Report ï¿½Concession Management and Fee Collection Operations, St. Croix National Park, National Park Serviceï¿½ (No. V-IN-NPS-0004-2003-A)

The attached report presents the results of our audit of concession management and fee collection operations at the St.ï¿½Croix National Park.  The objective of our audit was to determine whether the St. Croix National Park followed prescribed procedures for these operations. 

The legislation, as amended, creating the Office of Inspector General, (5 U.S.C. app. 3) requires that we report to Congress semiannually on all reports issued, actions taken to implement our recommendations, and recommendations that have not been implemented.  Therefore, this report will be added to the next semiannual report.  In addition, the Office of Inspector General provides audit reports to Congress.

Because the four recommendations contained in this report are considered to be resolved and implemented, no response is required.


Attachment

INTRODUCTION

The St. Croix National Park was established in 1952 and now includes three park areas: the  Christiansted National Historic Site, the Buck Island Reef National Monument, and the Salt River Bay National Historic Park and Ecological Preserve.

The Christiansted National Historic Site was established to preserve the historic 18th and 19th Century century structures and grounds within its boundaries and to demonstrate the Danish economy and way of life at the time.  Five of six historic buildings in the area are managed by the St. Croix National ParkThe St. Croix National Park manages five of the seven historic buildings in the area:  Fort Christiansvaern, the Steeple Building, the Danish West India & Guinea Company Warehouse, the Customs House, and the Scale House.

The Buck Island Reef National Monument was established in 1961 to protect the shoals, rocks, and coral reef formations adjoining Buck Island. Lying to the north of St. Croix, Buck Island includes 176 acres of land and 18,839 acres of water and coral reef systems.

The Salt River Bay National Historic Park and Ecological Preserve was established in 1992 to protect and enhance the natural and cultural resources of the area where Christopher Columbus landed during his 1493 voyageexpedition.  According to the 1999 Memorandum of Understanding between the Governor of the Virgin Islands and the Secretary of the Interior, the Secretary and the Governor are to work cooperatively to draft a memorandum of understanding that would implement joint planning and management of Salt River.

From 1952 through 1989, the St. Croix National Park was managed by staff stationed on St. Croix.  After Hurricane Hugo in 1989, management was shifted to the Virgin Islands National Park, which was then headquartered on St. Thomas.  In 1996, a St.ï¿½Croix Park Superintendent was hired and, in 1999, management was reverted to the St. Croix National Park.  The Parkï¿½s organizational chart shows 42ï¿½staff positions, but at the time of our review, there only 17 employees, who  were assigned to such functions as  maintenance, law enforcement, fee collection, interpretation, natural and cultural resource management, and administration.

Park expenditures totaled $1.7ï¿½million in fiscal year (FY)ï¿½2001 and $1.8ï¿½million in FY 2002.  The Park collected $46,207 in fees ($27,804 from franchise fees, $15,670 from entrance fees, and $2,733 from parking fees) for FY 2001 and $64,849 in fees ($21,577 from franchise fees, $20,669 from entrance fees, and $22,603 from parking fees) in FY 2002.

Six concessionaires (see Appendix 3) operated at the Buck Island Reef National Monument on the basis of contracts (two concessionaires) or commercial use permits (four concessionaires). The concessionaires provided water taxi services to Buck Island for the purposes of snorkeling, hiking, picnicking, and sightseeing.  Concessionaires were required to pay the Park a monthly fee equal to 2ï¿½percent of their gross receipts from concession operations.  

The St. Croix National Park collected fees from customers who parked in a Park-owned lot adjacent to Fort Christiansvaern and visitor entrance fees for access to Fort Christiansvaern and the Steeple Building.  
Park expenditures totaled $1.7ï¿½million in fiscal yearï¿½2001 and $1.8ï¿½million in fiscal year 2002.  Revenue collections totaled $46,207 ($27,804 from franchise fees, $15,670 from entrance fees, and $2,733 from parking fees) in fiscal year 2001 and $64,849 ($21,577 from franchise fees, $20,669 from entrance fees, and $22,603 from parking fees) in fiscal year 2002.

The objective of the audit was to determine whether the St.ï¿½Croix National Park followed prescribed procedures for its concession management and fee collection operations.  A separate report will be issued on our review of concession management and fee collection operations of the Virgin Islands National Park on St.ï¿½John.

The scope of audit included a review of concession management and fee collection activities and transactions that occurred during fiscal years 2001 and 2002, and other periods as appropriate.  To accomplish the audit objective, we interviewed Park personnel and reviewed concession management files and documents, daily shift and reconciliation reports for entrance fees, and activity reports for parking lot fees.

Our audit was conducted in accordance with the ï¿½Government Auditing Standards,ï¿½ issued by the Comptroller General of the United States.  Accordingly, we included such tests of records and other auditing procedures that were considered necessary under the circumstances.  The ï¿½Standardsï¿½ require that we obtain sufficient, competent, and relevant evidence to afford a reasonable basis for our findings and conclusions.

As part of our audit, we evaluated the internal controls related to concession management and fee collection operations to the extent we considered necessary to accomplish the audit objective.  Internal control weaknesses in these areas are discussed in the Results of Audit section of this report.  The recommendations, if implemented, should improve the internal controls in these areas.

We also evaluated the validity of Government Performance and Results Act (GPRA) performance measures for the St. Croix Park and found them to be appropriate and reasonable.  The Parkï¿½s annual performance report for FY 2001 stated that 5 of 6 performance goals for the Christiansted Historical Site, 8 of 10 goals for the Buck Island Monument, and the 1 goal of the Salt River Bay Preserve had been met or exceeded.  The performance report for FY 2002 was not available at the time of our review.

During the past five 5 years, the Office of Inspector General has not issued any audit reports on National Park Service operations in the Virgin Islands.  However, the March 1995 report ï¿½Selected Administrative Functions, Virgin Islands National Park, National Park Serviceï¿½ (No.ï¿½95I647) disclosed deficiencies related to concession operations, property management, and the deposit of collections  (see Appendix 1).

RESULTS OF AUDIT

The St. Croix National Park did not administer its concession operations in accordance with Park Service Guidelines.  Specifically, we found that the Park did not maintain complete and accurate records to ensure concessionaire compliance with financial and performance requirements and did not deposit franchise fees timely.  National Park Service Guideline 48, the Parks Concession Management Plan, and the terms of concessionairesï¿½ contracts and permits establish requirements for documents that must be maintained in the Parkï¿½s files on each concessionaire and for timely deposit of franchise fees.  We attribute the lack of compliance to the fact that the Park had not assigned a specific employee to be responsible for the concession management operations.  Without complete and accurate records, the Park cannot ensure that the concessionaires pay the appropriate franchise fees or determine their compliance with all insurance and safety requirements.  Also, The St. Croix National Park collected fees from customers who parked in a Park-owned lot adjacent to Fort Christiansvaern and from visitor entrance fees for access to Fort Christiansvaern and the Steeple Building.  However, Park officials did not ensure that implement adequate internal controls or develop formal policies or procedures for fee collections. were implemented to safeguard fee collections.

The St. Croix National Park needed to make improvements in its administration of concession management and fee collection operations.  Specifically, we found that the Park did not:

Maintain complete and accurate files for concessionaires that operated within the Park under contracts or commercial use permits.

Deposit concession franchise fee collections in a timely manner, thus losing interest income of at least $475.

Have adequate controls over parking lot fees, resulting in a cash shortage of at least $422.

Ensure that Park personnel followed established procedures regarding the collection of park entrance fees. 

Six concessionaires operated at the Buck Islands Reef National Monument on the basis of contracts (two operators) or commercial use permits (four operators).  The concessionaires provided water taxi service to Buck Island for the purpose of snorkeling, hiking, picnicking, and sightseeing.  Concessionaires were required to pay the Park a monthly fee equal to 2ï¿½percent of their gross receipts from concession operations.  

National Park Service Guideline 48, the Parks Concession Management Plan, and the terms contained in the individual contracts and permits require that the Park obtain and keep specific records.  Based on our review of the concessionaire files, we found that the Park did not ensure concessionaire compliance, and the files did not contain the following essential documents. The St. Croix National Park did not ensure that concession documentation requirements contained in National Park Service Guidelineï¿½48, the Parkï¿½s Concession Management Plan, and contract and permit terms were met.   

For FY 2001, supporting documentation was unavailable for 25 of 61 franchise fee payments made by concessionaires; for FY 2002, supporting documentation was unavailable for 22 of 72 payments made by concessionaires.  The concessionaireï¿½s file revealed that the business had been operating two vessels since prior to 1989.

None of the concessionaire files contained the required documentation indicating that Park personnel evaluated concessionaire business practices during the 2-year period prior to contract or permit renewalGuidelineï¿½48, Chapter 4, requires that evaluations be conducted of each concessionaireï¿½s operations during the 2-year period prior to renewal of their contracts or permits.  However, we found that the concessionaire files did not have documentation to show that the businesses had been evaluated by Park personnel prior to renewal of their contracts or permits. . Additionally, the files for two concessionaires did not contain letters or other documentation to show that the contracts or permits had been extended.

Three of the six concessionaire files did not contain the required documentation indicating that Park personnel periodically evaluated the safety of concessionaire boats that operate on a yearly basisGuideline 48, Chapter __., These requires that a minimum of three periodic evaluations be conducted of concessionaires who operate on a yearly basis.  The number of evaluations may be reduced by one, if the concessionaire received a prior year annual rating of ï¿½fourï¿½ or above.  However, for three of the six concessionaires, we were unable to determine if these evaluations had been performed because there was no documentation in the concessionaire files.  The periodic evaluations are especially important because Coast Guard inspections of these concessionairesï¿½ vessels are only performed on an annual basis.

Two of the six concessionaire files did not contain the required                                                                                                                                                     documentation of insurance.	Guideline 48, Chapter 23, requires that concessionaires maintain liability insurance to provide reasonable assurance to cover bona fide claims for bodily injury, death, or property damage; protect the U.S. Government against potential liability claims; and provide for rapid repairs or replacement of essential visitor facilities.  The individual contracts and permits stipulate that each concessionaire maintain watercraft liability insurance ranging from $500,000 to $2 million and name the Park as an additional insurer. However, documentation of insurance was not found in the concessionaire files for two concessionaires: a contract concessionaire, which operated six vessels, with required liability of $2 million per occurrence with a $3 million annual aggregate; and a permit concessionaire, which operated one vessel, with required liability of $500,000 per occurrence with a $1 million annual aggregate. 

Three of the six concessionaire files did not contain appropriate Coast Guard certification documentation for vessel inspection. In addition, five of the concessionaire files did not contain documentation of crew member certification in lifesaving, first aid, and cardiopulmonary resuscitation techniques.1

One of the six concessionaire files did not contain Despite our followup inquiries over a 4week period, the required permit to operate in Park waters. The individual contracts and permits stipulate that watercraft liability insurance ranging from $500,000 to $2 million, and naming the Park as an additional insurer, be maintained by each concessionaire.  However, for two concessionaires (one with a contract and one with a permit), documentation of insurance was not found in the concessionaire files.  For the contract concessionaire, which operated six vessels, the required liability insurance amount was $2 million per occurrence with a $3 million annual aggregate.  For the permit concessionaire, which operated one vessel, the required liability amount was $500,000 per occurrence with a $1 million annual aggregate.

Only one of the six concessionaire files documented full compliance with Park requirements for adequate financial records.  One concessionaire file did not contain annual financial reports for either fiscal yearsFYs 2001 or 2002. The four remaining concessionaire files only contained annual financial reports for one year or the other.  On an ï¿½as neededï¿½ basis, a Concession Manager from the National Park Service Regional Office in Atlanta visited the St.ï¿½Croix National Park to offer assistance with concessions.  

Although a National Park Service official stated that the Concessions Program Center in Denver reviews the annual financial reports, we believe that copies of the financial reports should also be maintained in the Parkï¿½s concessionaire files because local Park officials are ultimately responsible for ensuring that the Parkï¿½s concessionaires comply with applicable documentation requirements.

In July 2003, subsequent to the completion of our field review, we contacted the Concessions Manager in Atlanta and requested her assistance in obtaining the compliance documentation missing at the time of our review.  She reviewed her files and also directed St.ï¿½Croix Park officials to obtain and provide the missing documentation.  However, Park officials were only able to provide us with one missing annual financial report for one concessionaire.  Therefore, there is no assurance that concessionaires have fully complied with important safety-related requirements, such as safety checks of their vessels, lifesaving certification of crew members, and liability insurance coverage.

We also found that records supporting the franchise fee amounts were not consistently maintained in the concessionaire files. We believe that Access to franchise fee collection information is vital, which should include records that show each concessionaireï¿½s monthly activities, gross revenues, number of passengers, and excursion cost per passenger to ensure that the correct franchise fees were paid.  

We believe that the St. Croix National Park Superintendent should appoint a Park employee to be responsible for oversight of concession management operations.  The individual should then contact all concessionaires to obtain missing compliance documentation and establish policies and procedures to ensure that concessionaires adhere to compliance and documentation requirements and that the Parkï¿½s concessionaire files are current and complete.

Guideline 48, Chapter 24, requires that concessionaires pay a franchise fee of 2ï¿½percent of their gross receipts within 15ï¿½days after the end of each month.  We found that the six concessionaires  generallyconcessionaires generally paid franchise fees by the required deadlines.  However, Park personnel heldheld the franchise fees an average of approximately 63 2ï¿½days before fiscal year and an average of 63ï¿½days during fiscal year 2002 forwarding the funds forwarding them for deposit in a Federal Reserve Bank in Florida.  For example:

On December 5, 2000, a concessionaire paid franchise fees of $1,406.90 for the month of November 2000; however,.  Although the payment was made 10 days before the Decemberï¿½15, 2000 due date, the Park held did not forward the concessionaireï¿½s check for deposit until Mayï¿½5, 2001, or 5 months, before forwarding it to Florida for deposit.

On April 10, 2002, a concessionaire paid franchise fees of $424.40 for the month of March 2002.  Although the payment was made 5 days before the April 15, 2002 due date; however, the Park hel didd not forward the concessionaireï¿½s check for deposit until Januaryï¿½13, 2003, or 9ï¿½months, before forwarding it to Florida for deposit.

Using the prime rate in effect for each month, Wwe conservatively estimated that potential interest income totaling $475 was lost during fiscal yearsFYs 2001 and 2002 because of the untimely deposit of franchise fee collections.

We also found that records supporting the franchise fee amounts were not always maintained in the concessionaire files.  For fiscal year 2001, supporting documentation was available for only 36 of 61 franchise fee payments made by concessionaires.  Likewise, for fiscal year 2002, supporting documentation was available only for 50 of 72 payments made by concessionaires.  Supporting documentation should include records that show each concessionaireï¿½s monthly activities, gross revenues, number of passengers, and excursion cost per passenger.  Access to this information was vital to ensuring that the correct franchise fees were being paid.

We believe that We believe that the Park employee designated to oversee concession management operations should ensure that (1) the amount of franchise fee payments received from concessionaires is fully supported and accurately represents 2 percent of concessionairesï¿½ gross receipts, and that (2) the Park deposits franchise fee collections to the Federal Reserve Bank in a timely manner.

At the September 17, 2003, exit conference for the audit, Park officials stated that they were in the process of issuing a vacancy announcement for a Concession Management Specialist to oversee concession operations at the St. Croix National Park.  In the interim, concession management duties were temporarily assigned to existing staff and, as a result, efforts were being made to obtain the documentation that was missing from the concessionaire files and fee collections were being deposited timely.

The St. Croix National Park collected fees from customers who parked in a Park-owned lot adjacent to Fort Christiansvaern and from visitor entrance fees for access to Fort Christiansvaern and the Steeple Building.  However, Park officials did not ensure that implement adequate internal controls or develop formal policies or procedures for employees to collect parking lot and entrance fees. were implemented to safeguard fee collections.  As a result, we noted several internal control weaknesses that made fee collections susceptible to misappropriation.  Park officials allowed certain users of the parking lot to bypass the payment of the normal fee by initialing the tickets issued by the entrance machine and validating them as ï¿½nonpaying.ï¿½  However, the Park did not maintain a permanent record of which prenumbered tickets were validated as ï¿½nonpaying,ï¿½ the date, the name of the visitor, or the name of the approving Park official.  Additionally, the Park discarded the used parking tickets that were removed from the exit machine.  Therefore, there was no method to ensure that Park employees did not improperly validate tickets as ï¿½nonpayingï¿½ and then keep the cash collected from customers.  We noted that during a 24day test period, 45 ï¿½nonpayingï¿½ tickets valued at $180 were issued.  Based on our discussion with the Fee Collection Supervisor, the Park has begun to retain the used parking tickets for documentation purposes.

Park officials did not regularly reconcile the internally-generated reports produced by the cash register used for parking fee collections to the actual amount of cash in the register at the end of each day.  Additionally, due to problems with the programming of the register and possible user error, the internally-generated reports were not always accurate and sometimes were not produced at all.  For example, the reports were not produced for 7ï¿½days during the period of January 29 to February 19, 2002, and for 5ï¿½days during the period of April 11 to 25, 2002.  As a result of our discussion with the Fee Collection Supervisor, the Park has asked the cash register company to review and correct the programming of the register.  In the interim, however, there was no consistent control over or reconciliation of daily parking fee collections.

Also, our review of the available collection and deposit records for a sample of 11 deposit batches during the period of August 3, 2001, through January 21, 2003, disclosed cash shortages (deposits less than collections) totaling $426.

The Park should develop and implement formal policies and procedures to ensure that adequate internal controls exist over the collection and deposit of parking fees.  These controls should include procedures to limit the authorization of ï¿½nonpayingï¿½ tickets by specifically designated officials, require daily reconciliations of cash collections to the cash register reports and the used parking tickets, and require the retention of used parking tickets until any reconciliation discrepancies have been reviewed and satisfactorily explained.

The Park charges an entrance fee of $3 per adult for visits to both Fort Christiansvaern and the Steeple Building.  Free entry is allowed to children and to adult visitors who possess or purchase one of several types of multi-use passes (Golden Age Pass, Annual Park Pass, Golden Access Permit, Golden Eagle Permit).  Visitors pay the appropriate fee at the Visitorsï¿½ Center and are given a cash registergenerated receipt by the Park cashier.  This receipt must be used to gain access to the Steeple Building.  The cash register2 maintains an internal report of all transactions.  This internal report should correspond to the User Shift report manually prepared by each cashier and to the actual cash on hand. 

Formal policies for collection of entrance fees were contained in a document called ï¿½Fee Collection Guidelines for Christiansted National Historic Site,ï¿½ which conforms to National Park Service Guideline 22.  Despite these policies, we found evidence that internal controls over entrance fee collections needed improvement. Specifically, we found that: 

The only verification of daily collections was to compare the amount of cash in the register to the internal register report at the end of each day.  However, the internal reports generated by the Parkï¿½s cash register were incorrect and unreliable for verifying the amount of daily cash collections.  

The cash register could print duplicate receipts without recording this fact in an internal report. As a result, duplicate copies of receipts could be given to other visitors, thereby allowing the misappropriation of collected fees.  Based on our review, the Fee Collection Supervisor stated that she would acquire a new cash register for entrance fee collections.

The Park was not making weekly deposits of entrance fee collections, as required by the guidelines.  Instead, Park personnel took an average of 12ï¿½days during FY 2001 and 18ï¿½days during FY 2002 to mail deposits to the Federal Reserve Bank in Florida.  The only verification of daily collections was to compare the amount of cash in the register to the internal register report at the end of each day.  

The Park did not perform unannounced spot checks of cash collections at least once every two weeks. Only one spot check was conducted during FYs 2001 and 2002. A Park official said that he did not perform unannounced spot checks because he had too many other things to do.

The Fee Collection Guidelines were compiled to establish internal controls and to prevent and detect fee collection irregularities. Noncompliance with the procedures resulted from inadequate supervision of the collection process and provided the opportunity for manipulation of the process.  In addition, the Park should replace the malfunctioning cash registers to ensure that internal reports are accurate and usable. 

At the September 17, 2003, exit conference for the audit, Park officials stated that an order had been placed for new cash registers for the parking and entrance fee collections; improved controls had been implemented for ï¿½non-payingï¿½ tickets for the parking lot, including the maintenance of a log of such ï¿½non-payingï¿½ tickets; and reconciliations of collections and deposits were being performed on a daily basis.

RECOMMENDATIONS

We recommend that the Superintendent of the St. Croix National Park:

1.  Appoint an employee of the St. Croix National Park to be responsible for oversight of the concession management operations.  This individual should ensure that concessionaire files contain all required documentation (as discussed in the Results of Audit section), the amount of franchise fee payments received from concessionaires is fully supported and accurately represents 2ï¿½percent of concessionairesï¿½ gross receipts, and deposits of franchise fee collections are made to the Federal Reserve Bank in a timely manner.

2.  Develop and implement formal policies and procedures to ensure that adequate internal controls exist over the collection and deposit of parking fees.  These controls should include procedures to limit the authority to issue ï¿½nonpayingï¿½ tickets to specifically designated officials, require daily reconciliations of cash collections to the cash register reports and the used parking tickets, and require the retention of used parking tickets until any reconciliation discrepancies have been reviewed and satisfactorily explained.

3.  Direct the Fee Collection Supervisor and other collection personnel to comply with the collection and deposit requirements contained in the Fee Collection Guidelines for entrance fees. 

4.  Address the problems related to the accuracy of the internal reports generated by the cash registers used for parking lot and entrance fees, either by having the cash registers reprogrammed to correct the problems or by acquiring new cash registers.

We received a November 14, 2003, response (Appendixï¿½4) to the draft report from the Superintendent of the St. Croix National Park.  The response concurred with the recommendations and indicated that corrective actions had been or were being taken.  Therefore, we consider Recommendations 1 through 4 to be resolved and implemented (Appendix 5).

APPENDIX 1 ï¿½ PRIOR AUDIT COVERAGE

The March 1995 report ï¿½Selected Administrative Functions, Virgin Islands National Park, National Park Serviceï¿½ (No.ï¿½95I647) stated that the Park did not (1) ensure that franchise fee reconsiderations were conducted and implemented in a timely manner, (2) assess reasonable fees for the use by concessionaires of government buildings, (3) obtain reimbursement  for refuse collection and other services provided to concessionaires, and (4) consistently authorize commercial boating operations in the Park.  In addition, concessionaires had not reimbursed the Park for $57,000 in expenses related to providing refuse collection, sewage treatment, and water system maintenance. Regarding other administrative functions, the Park did not dispose of unserviceable equipment valued at $48,000 in a timely manner and held collections of up to $22,000 for several months before deposit.  Based on the Park Superintendentï¿½s response to the draft report, the reportï¿½s three recommendations were considered resolved.

APPENDIX 2 ï¿½ MONETARY IMPACT

Unrealized
ï¿½Revenuesï¿½ 

           $475
           ï¿½ï¿½426
           $901

__________
All amounts represent Federal funds.

APPENDIX 3 ï¿½ APPROVED CONCESSIONAIRES

Mile Mark, Inc.
Teroro, Inc.

Carl Punzenberger
Diva, Inc.
Llewelyn, Inc.
Southern Seas, Inc.

Draft Audit Report Response V-IN-NPS-0004-2003-A

Findings:

The St. Croix National Park did not administer its concession operations in accordance with Park Service Guidelines.  Specifically, we found that the Park did not maintain complete and accurate records to ensure concessionaire compliance with financial and performance requirements and did not deposit franchise fees timely.  National Park Service Guideline 48, the Parks Concession Management Plan, and the terms of concessionaireï¿½s contracts and permits establish requirements for documents that must be maintained in the Parkï¿½s files on each concessionaire and for timely deposit of franchise fees.  Specifically, we found that:

Concessionaire files did not always contain required documentation to support (1) the amount of franchise fee payments received, (2) evaluations of concessionaire operations, (3) safety inspections of concessionaire vessels, (4) existence of adequate insurance coverage, (5) crew member safety certifications, and (6) annual financial reports.

Franchise fee collections were deposited an average of 2ï¿½months after the date of collection, with some deposits being delayed as long as 9ï¿½months.

We attribute the lack of compliance to the fact that the Park had not assigned a specific employee to be responsible for the concession management operations.  Without complete and accurate records, the Park can not ensure that the concessionaires pay the appropriate franchise fees or determine their compliance with all insurance and safety requirements.  

Corrective Action Taken By the Park Superintendent:

1) The superintendent has taken on the responsibility of oversight of the concession management operation.  As such, I have modified the parkï¿½s organizational chart to include a new position of Concession Management Specialist Gs-12.  This position was classified and approved last fiscal year, and will be advertised within the next few weeks.  The individual selected for this position will be responsible for the entire concession management program as described in NPS-48.  In the interim, until the position is filled we plan to have the Lead Visitor Use Assistant conduct the deposit of franchise fee payment to the Federal Reserve Bank in a timely manner with the Administrative Officer serving as back up.  Also worthy of mention is that we are currently working in establishing an approved TGA in St. Croix in order to facilitate deposits.  


APPENDIX 4
Page 4 of 5

Finding:

The St. Croix National Park did not implement adequate internal controls or develop formal policies or procedures for employees to collect parking lot and entrance fees. As a result, we noted several internal control weaknesses.  Specifically, we found that:

Park officials did not regularly reconcile the internally-generated reports produced by the cash register used for parking fee collections to the actual amount of cash in the register at the end of each day.  Additionally, due to problems with the programming of the register and possible user error, the internally-generated reports were not always accurate and sometimes were not produced at all.  As a result, our review of the available collection and deposit records for a sample of 11 deposit batches during the period of August 3, 2001, through January 21, 2003, disclosed cash shortages (deposits less than collections) totaling $426.

Internal controls over entrance fee collections also needed improvement.  For example, (1) the internal reports generated by the cash register were incorrect and unreliable, (2) the cash register could be made to print duplicate receipts, (3) collections were not being deposited timely, and (4) unannounced spot checks of cash collections were not being performed.

As a result of these conditions, the possibility existed for cash collections to be misappropriated.

Recommendation:

1.  Develop and implement formal policies and procedures to ensure that adequate internal controls exist over the collection and deposit of parking fees.  These controls should include procedures to limit the authority to issue ï¿½nonpayingï¿½ tickets to specifically designated officials, require daily reconciliations of cash collections to the cash register reports and the used parking tickets, and require the retention of used parking tickets until any reconciliation discrepancies have been reviewed and satisfactorily explained.

2.  Direct the Fee Collection Supervisor and other collection personnel to comply with the collection and deposit requirements contained in the Fee Collection Guidelines for entrance fees. 

3.ï¿½ï¿½Address the problems related to the accuracy of the internal reports generated by the cash registers used for parking lot and entrance fees, either by having the cash registers reprogrammed to correct the problems or by acquiring new cash registers.

Corrective Action Taken by the Superintendent:

1)  We are in the process of developing formal written policies and procedures in the forms of SOPï¿½s, for the internal controls over the collection and deposit of parking fees.  In the interim, we have instructed the Lead Park Ranger Gs-5, to make deposits once per week.  As superintendent, I issued a memorandum limiting the authority to division chiefs only, to authorize ï¿½no-paying tickets for persons on official business at the park.  All used tickets are being reconciled daily, and all used tickets are kept until discrepancies have been reviewed and corrected and explained in a satisfactorily manner.
2)  The Fee Collector Supervisor and all fee collectors has been advised of the collection and deposit requirements contained in NPS-22 guideline for fee collection operation.  Each employee has received instruction to follow these guideline during weekly meetings.
3)  We have purchased a new cash register that address the concerns found in the audit.  All fee collectors has received training from the manufacture representative on the operation of the new machine.

SEE BELOW:
Policy and procedures have been developed to ensure adequate internal controls over the collection and deposit of entrance fees and parking fees.  These Standard Operating Procedures are now in the final review and printing stages.  In the interim cashiers are to follow the draft version and weekly meetings are scheduled in order to verify that compliance is adhered to.  

Authority of ï¿½non-payingï¿½ tickets for persons on official business at the park has been limited to designated officials, in this case to division chiefs only.  As superintendent a memorandum limiting this authority has been made available and distributed.

All tickets for the parking lot are now secured in Ziploc bags and retained at the park for use in reconciliation.

All fee collectors have been advised of the availability of NPS-22 at the fee collection office.  All collection personnel have been requested to comply with these requirements. 

A new cash register has been purchased and has replaced the old register.  The new register was programmed to meet and currently exceeds the NPS-22 standards thus providing correct and reliable readings.  This has made it possible for the fee collectors to print internal reports on a daily basis to review and reconcile at the end of their shifts.   Together with the purchase of the new register all cashiers received a formal 4 hour training from the vendor representative thus providing hands on knowledge on its operation. 

Deposits are being conducted on a weekly basis by the Lead Visitor Use Assistant.  And unannounced audits or spot checks are being conducted to ensure accountability.  

APPENDIX 5 ï¿½ STATUS OF RECOMMENDATIONS

Finding/Recommendation
        ï¿½    Referenceï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½             

1 to 4

         Statusï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½         

Resolved and implemented.

                       ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½Actionï¿½Requiredï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½               

No further response required.

1 Requirements of the Concession Management Plan, Section II-A and II-B.
2 Separate cash registers were used for parking fee collections and entrance fee collections.