Sensitive Payments Audit Summary - FY 2025
Why the Office of the City Auditor (OCA) did this project
Sensitive Payments are transactions that carry the possibility for city officials, executive management, and certain employees to receive inappropriate benefit due to their position of influence.
Project Scope
Examine internal controls and test transactions for activities pertaining to travel, official entertainment, unvouchered expenditures, contracting and consulting, speaking honoraria, ethics and conflicts of interest rules, and executive perquisites for fiscal year 2025.
Project Procedures
Following the U.S. Government Accountability Office (GAO) “Guide for Evaluating and Testing Controls Over Sensitive Payments,” we conducted the following procedures:
Determine the adequacy of internal controls over sensitive payments.
Assess compliance with applicable laws, ordinances, policies and procedures regarding sensitive payments.
Verify that executive expenses are properly authorized and approved.
Verify that executive expenses are accurately and promptly recorded and reported.
Evaluate corrective action taken on prior year sensitive payment findings.
Key Observations
Overall, internal controls for Sensitive Payments are effective. Some improvements are needed to reduce the risk of fraud and prevent errors and irregularities in executive travel and reimbursements.
There is no department currently owning responsibility for training on travel expense rules, procedures, approvals, and documentation. As a result, past findings have not been addressed in a timely manner and travel expense errors continue to occur.
Audit Objective
Review internal controls related to compensation, travel, official entertainment funds, unvouchered expenditures, contracting and consulting, speaking honoraria, gifts and donations, executive perquisites, ethics and conflict of interest, follow up on prior audit findings, and policy evaluation.
Methodology and Results
Travel
We reviewed transactions by department heads and elected officials during the period July 1, 2024 to June 30, 2025. Using data analytics, we reviewed MUNIS Employee Self Service (ESS) activity for compliance issues, errors, and other risk-related indicators.
The data analytic review produced multiple opportunities for improving processes, compliance, and efficiencies in ESS workflow configurations. (See Observation)
Official Entertainment Funds
Through inquiry and observation, we confirmed the City of Tulsa does not have official entertainment funds.
Unvouchered Expenditures
Through inquiry and observation, we confirmed the City of Tulsa does not support unvouchered expenditures.
Contracting and Consulting
We verified the City has proper procedures in place for providing written disclosures of conflicts of interest, giving information at orientation and on the website for review. Employees were compared to vendor information and no crossovers were found.
Speaking Honoraria, Gifts and Donations
We selected a sample of non-travel related donations received during fiscal years 2025 and reviewed them to determine compliance with City of Tulsa Policies and Procedures, Executive Orders and Ordinances. (See Observation for findings regarding travel donations.) No exceptions were noted in our review of non-travel related gifts and donations, and there were no speaking honoraria reported during the scope period.
Executive Perquisites
Executive perquisites are benefits provided to executives above and beyond benefits provided to all other employees. Through inquiry and observation, we confirmed the City of Tulsa does not provide executive perquisites.
Follow-up on Prior Observations
We evaluated recommendations from previous Sensitive Payments Reviews to determine whether corrective action was completed. Three prior Sensitive Payments Review observations required follow-up.
Recommendation | Status | Notes | |
|---|---|---|---|
1 | Update and centralize travel-related policies and guidance. | IN PROGRESS | HR is currently updating policies. |
2 | Provide additional procedural guidance for executive travel and reimbursements emphasizing the importance of the review and approval process. | IN PROGRESS | Finance has placed the document on how to complete an estimate travel claim on Service Desk Plus but will be moving it to ESS for easier finding. |
3 | Policies do not fully reflect ordinance requirements. | IN PROGRESS | HR is currently updating policies. |
4 | Provide training on how to input travel claims, train travel coordinators on travel policies. Place specific instructions and definitions in a dropdown menu. | IN PROGRESS | Munis has been updated to provide additional information on each section of the travel claim. Document on how to enter an Estimate Claim has been placed in Service Desk Plus but will be moved to ESS. No other training has been provided. |
There continues to be a need for updated travel policies and procedural guidance. (See Observation).
Observation
There is no department currently owning responsibility for training on travel expense rules, procedures, approvals, and documentation. As a result, past findings have not been addressed in a timely manner and travel expense errors continue to occur.
WORKFLOW |
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TRAVEL EXPENSE POLICIES |
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EXPENSES SUBMITTED AGAINST POLICY |
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TRAVEL DONATIONS |
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Recommendation
Mayor should create a working group to determine the best method for developing consolidated operating procedures that include clear responsibility for informing employees on travel policies and procedures and ensuring adherence and compliance. Mayor should hold working group accountable for making recommendations for updating travel related policies, ordinances, and training, and addressing past audit recommendations.
Response
City Administrator agrees with the recommendation and will work with his team to implement.