§ 39.055 MATERIALITY THRESHOLD FOR REPORTING IRREGULAR VARIANCES, LOSSES, SHORTAGES, AND THEFT.
   (A)   Materiality thresholds. Any irregular variances, losses, shortages, and thefts of county funds or property shall be deemed material, for purposes of this section, and for purposes of the State Examiner Directive 2015-06 (hereafter generally labeled “Variances”), based upon the following criteria:
      (1)   A singular variance involving non-cash or non-cash equivalent assets of Elkhart County exceeding $500 in value;
      (2)   A recurring, related variance relative to non-cash or non-cash equivalent assets of Elkhart County, involving two or more related or similar circumstances, occurring within a 30 day period or less, exceeding $1,000 in value;
      (3)   A singular variance involving cash or cash equivalent funds of Elkhart County exceeding $100 in value; and/or
      (4)   Two more variances involving cash or cash equivalent funds of Elkhart County in a 30 day period exceeding $200 in value.
   (B)   Designation of position to whom variances shall be reported. All elected officials, and all department heads established under the policies and standards of the Commissioners of Elkhart County Government, shall report a variance, meeting the criteria of division (A) above, to the Elkhart County Administrator. The reporting (“Report”) shall be in writing, shall be delivered within seven days of the determination of the variance, and shall provide to the County Administrator the requisite knowledge and information by which the County Administrator may evaluate the variance, and posture the County Administrator to follow the steps and procedures upon receiving of a report as contemplated by division (C) below.
   (C)   Responsibilities of County Administrator with regard to variances as herein defined. Upon the receipt of a report consistent with division (B) above, with regard to variances defined at division (A) above, the County Administrator shall proceed as follows:
      (1)   Log in each report into a spreadsheet that is permanently maintained by Elkhart County Government;
      (2)   Confirm the dollar amount value of the variance referenced in the report;
      (3)   Evaluate the report against the variance dollar thresholds established at division (A) above, and send a letter to the State Board of accounts when the report, after evaluation, exceeds the applicable threshold of materiality;
      (4)   Investigate the cause of the variance giving rise to the report;
      (5)   Implement corrective actions or internal control procedures to correct the cause(s) of the variance set forth within the report; and
      (6)   Maintain copies of relevant documentation, resolution of incidents, and any report to the State Board of Accounts by the County Administrator, in a centralized data folder.
   (D)   Acknowledgment of I.C. 5-11-1-27(1). 
      (1)   Indiana Code 5-11-1-27(1) requires that a public officer, to include a public officer of Elkhart County Government, who has actual knowledge of or reasonable cause to believe that there has been a misappropriation of public funds or assets of an applicable public office shall immediately send written notice of the misappropriation to the State Board of Accounts and the Prosecuting Attorney for Elkhart County Government, including:
         (a)   Information obtained as a result of a police report;
         (b)   An internal audit finding; or
         (c)   Another source indicating that a misappropriation has occurred.
      (2)   The standards applicable to I.C. 5-11-1-27(1) are not altered or diminished by the standards within this policy, as it is acknowledged herein that there may be a difference in circumstances, and a difference in severity of a matter requiring a report under this policy, and a misappropriation contemplated by I.C. 5-11-1-27(1).
(Ord. 2016-136, passed 2-1-2016)