The purpose of this policy is to establish local procedures and specifications for public officials to abide by in reporting misappropriations of public funds pursuant to I.C. 5-11-1-27. This materiality policy becomes effective March 1, 2016. The terms of this policy are as follows:
(A) Requirement to report misappropriation.
(1) I.C. 5-11-1-27(1) requires public officials who have actual knowledge of or reasonable cause to believe that there has been a misappropriation of public funds to immediately send written notice of the misappropriation to the State Board of Accounts and prosecuting attorney.
(2) The public officials of the city shall comply with this requirement and follow the procedures set out herein in doing so.
(B) Threshold dollar amounts for reporting (materiality requirement).
(1) The following are the minimum amounts of misappropriations that are material for the purpose of reporting to the State Board of Accounts.
(2) For incidents involving cash: Any single incidence of misappropriation greater than $100 cash shall be reported pursuant to the terms of this policy.
(3) For incidents involving non-cash assets: Any single incidence of misappropriation greater than $500 of non-cash assets shall be reported pursuant to the terms of this policy.
(4) For multiple incidents: Multiple incidents of suspected misappropriation within any six month period that total greater than $100 in cash and/or $500 in non-cash assets shall be reported pursuant to the terms of this policy.
(C) Process of handling reports.
(1) Any public employee with actual knowledge of or a reasonable cause to believe that a misappropriation of public funds has occurred shall immediately notify the Clerk- Treasurer and provide all relevant details known to that public employee of the potential misappropriation.
(2) The Clerk-Treasurer shall be the designated public official of the city who receives, records, and reports misappropriation to the State Board of Accounts. The Clerk-Treasurer shall maintain an annual file containing a log of all reports made to him or her of misappropriation and any documentation provided evidencing said reports. A spreadsheet shall be kept and totaled with each report of misappropriation to determine if further action is necessary.
(3) Upon the receipt of any report of misappropriation or variance, the Clerk-Treasurer shall undertake a review of the report to determine if it satisfies the materiality requirements set out above, is not a loss caused by genuine accident, and is not the result of an inadvertent error or misplacement that is identified timely and promptly corrected with no loss to the city. Upon determination that a misappropriation of a material variance has occurred, the Clerk-Treasurer shall immediately notify two entities in writing: the State Board of Accounts, which requirement may be satisfied by filing a report in the proper location on the Indiana State Board of Accounts website.
(4) The Clerk-Treasurer shall maintain copies of any records in connection to the monitoring and reporting of misappropriations, including records for any reported incident that is not determined to be material pursuant to the terms of this policy. The Clerk-Treasurer shall implement internal control procedures to correct the cause(s) of misappropriations where possible and document the resolution of all reports, whether material or of lesser amount.
(Ord. 2016-1, passed 2-8-2016)