Authorities, Boards, and Commissions
Updated: Aug 20
Published without Office of City Council Responses
Start Date: 9/23/25
Pre-Audit Report
Purpose
This pre-audit report highlights key risks in how the City of Tulsa's 46 Authorities, Boards, and Commissions (ABCs) operate and interact with City government. These bodies play an essential role in advising policymakers, managing public resources, and delivering services that reflect community priorities.
This report is an early step in the audit process. The Audit Manager will use it to scope and narrow the upcoming audit plan, focusing on the areas of highest risk and greatest opportunity for improvement. It is not a list of audit findings, but rather the issues most worth testing in the full audit.
Methodology
This pre-audit report was created based on information gathered from:
Interviews with City Councilors and representatives from the Mayor's Office
Three focus groups with ABC staff liaisons
Interviews and focus groups with ABC leadership (chairs/vice chairs) and one newly appointed member
Surveys of ABC leadership and newly appointed members
Resident feedback via the City Auditor web form
A review of peer-city ABC audits for comparison
Top Risks
Top Questions to Consider when Determining Audit Scope:
Are responsibilities for handling Open Records Act requests clearly defined and consistently followed?
Is confusion around who's supposed to handle public records requests causing delays and mistakes that lead to complaints?
Cited most often by: ABC Liaisons, ABC Leadership, Residents, Mayor's Office
Are communication practices creating risks around recordkeeping and public transparency?
Is volunteers' use of their own personal devices and channels creating gaps in documenting and possible legal exposure?
Cited most often by: City Councilors, ABC Leadership, ABC Liaisons
Do existing rules around participation create barriers for residents who want to serve or attend meetings?
Do state or city rules that limit remote participation and prevent compensation make it harder for people to serve on boards or attend meetings?
Cited most often by: Mayor's Office, ABC Leadership, ABC Liaisons, Residents
Are meeting minutes and packets being stored and published in a way that ensures long-term transparency and accessibility?
Does not posting and properly storing meeting minutes and packets in one easy-to-find place make it harder for the public to see what boards are doing?
Cited most often by: ABC Leadership, ABC Liaisons, Residents
Are recording and streaming practices consistent and accessible to the public?
Does inconsistent recording and streaming of public meetings make it harder for residents to follow decisions and trust the process?
Cited most often by: ABC Liaisons, Residents, ABC Leadership
Is it difficult for the public to find ABC information, meeting materials, and archives?
Are residents having trouble finding board pages, meeting materials, and archives online because the website is hard to navigate and links are inconsistent or broken?
Cited most often by: Residents, ABC Liaisons
Are language access, accessibility supports, and meeting schedules inclusive enough for our residents to participate?
Do limited translation and accessibility options, along with standard daytime meeting hours, make it hard for some people to participate?
Cited most often by: Residents, New Members, ABC Liaisons
Are new ABC members being adequately prepared for their new roles consistently?
Does not having a single, comprehensive orientation for new members make it confusing to understand roles, rules, and boundaries?
Cited most often by: New Members, ABC Leadership, ABC Liaisons
Are conflict-of-interest rules and recusal practices clearly defined and documented across ABCs?
Does not having clear conflict-of-interest rules and consistent recording of recusals make it hard to ensure decisions are fair and unbiased?
Cited most often by: ABC Leadership, New Members, City Councilors
Are potential conflicts of interest effectively screened and logged during member appointments and reappointments?
Does not screening conflicts of interest consistently when members are appointed or reappointed make it harder to keep decisions fair and unbiased?
Cited most often by: ABC Leadership, ABC Liaisons, New Members
Is ABC onboarding consistent and well-coordinated across boards to ensure new members receive the information they need?
Does having no single owner for onboarding and disorganized paperwork make it harder for new members to get started and participate effectively?
Cited most often by: New Members, ABC Liaisons, ABC Leadership
Do ABC agendas clearly distinguish informational items from actions items to help prevent confusion?
Does having meeting agendas without clearly defined action vs. information lead to surprise votes and leave the public unsure about what's actually being decided?
Cited most often by: ABC Leadership, ABC Liaisons
Do leadership selection and rotation practices support effective governance?
Does not rotating board members limit fresh ideas and make governance less resilient?
Cited most often by: ABC Leadership
Are ABCs maintaining appropriate oversight roles?
Are boards using meetings to handle day-to-day complaints in ways that blur the line between oversight and management?
Cited most often by: ABC Leadership
Is there a clear and accessible way for residents to submit and track concerns related to ABCs?
Does not having a clear way for residents to submit or track complaints about boards reduce public trust?
Cited most often by: ABC Leadership, Residents
Do agreements and reporting structures with partner-managed entities provide sufficient oversight and transparency?
Does not having clear agreements, regular reporting, and public access to records make partner-managed entities less transparent?
Cited most often by: ABC Leadership, Mayor's Office
Are governance and operation boundaries between the City and its trusts clearly maintained to reduce legal exposure?
If the City's trusts aren't clearly run as separate from the City itself, could a lawsuit treat them like part of the City (effectively removing legal limits on how much money could be owed in damages)?
Cited most often by: ABC Leadership
Are appointment and vacancy-filling processes timely, transparent, and effective in maintaining ABC functionality?
Are delays and unclear rules for filling board vacancies weakening public trust and leaving some boards unable to meet or make legitimate decisions?
Cited most often by: City Councilors, ABC Leadership, Mayor's Office
Do ABCs have clear goals and performance measures to assess whether they are achieving intended outcomes?
Are boards and commissions operating without clear goals or progress measures, making it hard to tell whether their work is actually making a difference?
Cited most often by: ABC Leadership, City Councilors
Are staff liaison practices consistent enough to support effective ABC operations and recordkeeping?
Are differences in how staff liaisons manage meetings and records—especially when roles change—causing inconsistency and lost knowledge across boards and commissions?
Cited most often by: ABC Liaisons, ABC Leadership
Conclusion
The top ABC risks converge around transparency infrastructure, clarity of legal and ethical boundaries, onboarding and continuity practices, and public accessibility. Addressing these areas will enhance accountability, reduce compliance risk, and strengthen public trust in how Tulsa's boards and commissions serve the community.
Why the Office of the City Auditor (OCA) did this project
Authorities, Boards, and Commissions (ABCs) was selected for auditing in the community based 2026 Fiscal Year Audit Plan which included input from the City Council, City of Tulsa (City) employees, and citizens.
Project Scope
This review focuses on the four highest risks as determined in the Risk Refinement Report for the ABCs Audit and is limited to ABCs that have Mayoral and/or Council appointed seats as indicated on the City’s website.*
Record custodianship requirements and procedures
Transparency and availability of meeting minutes and documents
Orientation and onboarding of ABC members and liaisons
Ethics/Conflict of interest disclosures
Project Procedures
Review best practices and State and City regulations.
Survey ABC liaisons and interview City subject matter experts.
Verify public access to agenda packets and minutes.
Confirm evidence of ethics/conflict-of-interest disclosures.
Key Observations
ABC liaison, retention custodian, and open record custodian roles are not well defined and understood by the City or its ABCs.
The processes for accessing ABC records is unclear.
There is not a single point of responsibility for onboarding/orientation training for ABC members and liaisons.
The Mayor’s Office and Ethics Advisory Committee (EAC) are currently creating an ethics training presentation for ABCs.
Audit objectives
Determine if responsibilities and requirements for ABC record custodianship are defined, being met, and record requests are being filled in a timely manner.
Determine if public availability requirements for ABC minutes and agenda packets are being met in a way that best supports transparency.
Determine if onboarding and orientation for ABCs cover roles, are sufficient to ensure compliance with the Oklahoma Open Meetings Act, and ethics/conflict-of-interest disclosures.
Determine if there is clear guidance for ethics/conflicts-of-interest disclosures and how disclosures are tracked.
Observations
1 | Responsibilities & Requirements for Open Record Processes | |||||
Responsibilities and requirements for record custodianship of Authority, Boards, and Commissions (ABCs) are not being met and are not adequate.
The City Clerk’s Office manages the lists of Record Custodians, including Retention Custodians (RCs) and Open Records Custodians (ORCs). When we inquired about the written documentation of the RCs and ORCs for ABCs we were provided with lists for the respective custodians of Departments. The RCs and ORCs for ABCs are not identified on either list. The only written requirements we found for liaisons came from the City Clerk’s Office. It was a handout entitled “Agenda Posting Requirements and Tips” included in a 2024 training session for ABC liaisons. This information is also shared with ABC liaisons annually via email. | ||||||
There is confusion regarding the roles of ABC Liaison, Open Record Custodian, and Retention Custodian. The role of ABC liaison has not been clearly defined. The City Clerk’s Office manages the City’s ABC management system (ABCA) which allows them to maintain a current list of people with the responsibility for filing annual schedules, meeting notices and agendas with the City Clerk’s Office. These people are referred to as “liaisons”. Culturally, we have observed evidence of confusion regarding the roles of ABC liaisons and record custodians.
There is also confusion among liaisons concerning roles. Analysis of liaison survey responses indicated that the role of liaisons concerning record custodianship is varied and some liaisons do not know who the retention custodian or the open record custodian is for their ABC. We were unable to confirm all roles for some liaisons. The summary analysis of the roles ABC liaisons serve in is shown in the Liaison Role Analysis Summary table below. | ||||||
LIAISON ROLE ANALYSIS SUMMARY | ||||||
Liaison Roles | # Serving in Role | # Not Serving in Role | # Don't Know Who Serves in Role | # Roles Unconfirmed | ||
Retention Custodian (RC) | 15 | 3 | 2 | 4 | ||
Open Record Custodian (ORC) | 10 | 14 | 3 | 1 | ||
RC and ORC (included in role counts above) | 7 | 3 | 1 | 1 | ||
Liaison (only) | 3 | N/A | N/A | 3 | ||
Information for submitting an ABC Open Record Request is not published and accessible.
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RECOMMENDATION | ||||||
The open record and retention custodians for ABCs should be documented in writing as required by Executive Order 2025-08 and the information should be maintained by the City Clerk’s Office. ABC liaison requirements and responsibilities should be clearly defined, so the people in those roles and the organization understand the boundaries of the role. City of Tulsa website should be updated to clarify how an ABC record request should be submitted. | ||||||
MANAGEMENT RESPONSE | ||||||
The City is in compliance with Executive Order 2025-08. The ABCs under the City’s purview are assigned a records custodian and retention custodian from the department or entity that staffs and works most closely with the ABC. Those custodians are listed and held on file with the City Clerk, but that list is not required to be public facing. The "in-writing" provision in Executive Order 2025-08 (Section 3.A) was intended to be an instruction to officially designate Records Custodians and Retention Custodians to assist in the City Clerk's work and implementation of Justfoia. The switch to Justfoia created a centralized, internal process for all City records requests and does not require the posting of individual custodians. While the responsibilities of liaisons are covered in the various ordinances and laws that help to establish these bodies, the Mayor’s Office will work on a single document to share with existing and incoming ABC liaisons. ABC Records requests should be submitted through the preferred method of the City Clerk, Justfoia. We can have our communications team add a statement and link to the ABC page. | ||||||
2 | Meeting Packets & Minutes Availability |
Tulsa Revised Ordinance, Title 3, Chapter 1, Section 120.A imposes requirements for ABCs of the City to file agendas and minutes with the Tulsa City-County Library. The ordinance was enacted in 1994 with the intent of enhancing transparency. Through the City’s website we validated the ABCs are meeting the filing requirements in accordance with Oklahoma Open Meetings Act (OMA), Okla. Statutes (OS) Title 25 Sections 301-314. An inquiry with the Tulsa City-County library revealed that only 9 of the 49 ABCs in the audit scope meet the filing requirements of TRO, Title 3, Chapter 1, Section 120.A. According to the City Attorney, the consequences of failing to file are minimal:
As a separate legal entity, Tulsa City-County Library has no obligation to retain the agendas and minutes of the City’s ABCs. | |
ABCs currently meet or exceed the Open Meetings Act requirements for filing annual meeting schedules and agendas, and for making meeting packets and minutes available. We researched online accessibility of ABC minutes meeting packets for seven comparable cities. The City provides similar online access to ABC agendas, minutes, and meeting materials compared to cities similar in size and function to us. All ABC annual meeting schedules and agendas are available on the City of Tulsa’s website, but searching for meeting materials and minutes is a challenge.
Cities that provide central access to agendas, minutes, and/or meeting materials utilize specialized software. The City’s in-house developed ABCA system cannot be leveraged to centralize meeting materials and minutes availability without additional software development. | |
RECOMMENDATION | |
City Council should repeal or amend Tulsa Revised Ordinance, Title 3, Chapter 1, Section 120.A | |
MANAGEMENT RESPONSE | |
Pending Further research is required before an official response can be provided. The recommendations will remain open until a formal response is received and an action plan is established. The report will be updated to include responses once received. | |
3 | Orientation & Onboarding Training |
We inquired with the City Attorney, City Clerk, City Council and Mayor’s Office, and determined that there is no centralized orientation training provided to ABC members or liaisons, and no responsible party designated with the task of ensuring such training is provided. Of the ABC liaisons responding to our survey, 77% provide some kind of onboarding guidance and 23% do not. If orientation is provided it is typically done by the ABC through methods such as in-person meetings and written information packets. Once appointees are seated as members of an ABC governed by Oklahoma Trust Statutes, (Title 60), the City has no legal authority to impose training requirements on them. | |
RECOMMENDATION | |
It is best practice for cities to provide onboarding and periodic refresher training for members of ABCs to keep members informed on state laws regarding open meetings and public records, provide guidance on conflict-of-interest rules, and prepare them for specific duties. Issues noted under Observations 1, 2, and 4 could be reduced through proper onboarding/orientation training. We recommend the following:
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MANAGEMENT RESPONSE | |
The Mayor's Office will work to create templates for each ABC liaison to complete with information from their specific ABC but given the hyper-specific roles and missions of each ABC, the general orientation process should remain with the ABC once a member is confirmed by Council. The Mayor's Office is not the final stop on appointments, and due to the varying and multi-layered process for appointments, and to maximize staff time, general ethics training will be provided after final appointments from the Council. | |
4 | Ethics/Conflict-of-interest (COI) Disclosures | |||||
The City does not provide clear guidance to ABCs for disclosing conflicts of interest, which includes recusal statements and minute notation. We surveyed liaisons of 49 ABCs. Most responded there was written guidance for ABC members regarding ethical conduct or disclosures for COIs, but 4 said there was not. Our research concerning ethics/COI disclosures among ABCs within the audit scope indicates that their tracking practices are widely varied, potentially insufficient, and may not conform to best practices.
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CONFIRMED AP VENDOR FIELD MATCH | ||||||
Total # Appointees with 1 or more "Yes” Field Match | Vendor Name | Vendor Address | Vendor Phone | Appointees with City Clerk COI Filing | ||
63 | 11 | 48 | 28 | 9 | ||
POSSIBLE AP VENDOR FIELD MATCH | ||||||
Total # Appointees with 1 or more "Yes” Field Match | Vendor Name | Vendor Address | Vendor Phone | Appointees with City Clerk COI Filing | ||
27 | 2 | 25 | 0 | 7 | ||
The above data points and the discovery that only 18% of the ABC members with a potential match to the vendor system have disclosures on file with the City Clerk, demonstrate the need to strengthen best practice guidance for ABCs. | ||||||
The Mayor’s Office reported that it has initiated a project with the Ethics Advisory Committee (EAC) to develop baseline ethics training for new ABC appointees.
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RECOMMENDATION | ||||||
Best practices for COI disclosures include:
We recommend that the Mayor’s Office continue its project in conjunction with the Ethics Advisory Committee to create an ethics training presentation for ABCs. The ethics training presentation could be included as part of an overall orientation training session that is provided to all ABC appointees and liaisons, discussed above in Observation 3. | ||||||
MANAGEMENT RESPONSE | ||||||
The Mayor’s Office and Ethics Advisory Committee (EAC) will continue the project, which will include training for ABCs and mentioned in the project above (refer to observation 3). | ||||||
Appendix
Acronyms and Definitions
ABC - Authority, Board or Commission:
Internal or external ABC’s that have Mayoral and/or Council appointed seats as indicated on the City’s website, including advisory authorities, boards and commissions (City Charter, Article XII, Section 4) and public trusts (State Statutes, Title 60, Section 178).
COI – Conflict-of-Interest:
Financial or organizational interest (State Statutes, Title 60 Section 178.8, City Charter, Article XII and Ethics Code, TRO Title 12, Chapter 6)
ORC – Open Record Custodian:
Persons who are authorized to release the public records of an ABC (Executive Order 2025-08)
RC – Record Retention Custodian:
Persons who are charged with maintaining records of the ABC. (Executive Order 2025-08)
*The Office of the City Auditor provides staffing for the Ethics Advisory Committee (EAC). The City Auditor is a member of the Audit Committee of the City of Tulsa (AUDIT). The Deputy City Auditor is a member of the Tulsa City-County Board of Health (TCCBOH).