performance audit of city treasurer’s delinquent accounts ... · transmitted herewith is an audit...

31
Office of the City Auditor, City of San Diego Audit Report October 2011 Performance Audit of City Treasurer’s Delinquent Accounts Program Opportunities Exist to Increase Collection of Past Due Receivables OCA-11-007

Upload: others

Post on 03-Jun-2020

3 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Office of the City Auditor City of San Diego

Audit Report

October 2011 Performance Audit of City TreasurerrsquosDelinquent Accounts Program

Opportunities Exist to Increase Collection of Past Due Receivables

OCA-11-007

This Page Intentionally Left Blank

OCA-11-007

October 25 2010

Honorable Mayor City Council and Audit Committee Members City of San Diego California

Transmitted herewith is an audit report on the City Treasurerrsquos Delinquent Accounts Program This report is in accordance with City Charter Section 392 The Results in Brief is presented on page 1 The Administrationrsquos response to our audit recommendations can be found after page 23 of the report This is the second and final report related to the Delinquent Accounts Program The first report was issued in December 2009 and focused on past due accounts of the Development Services Department

If you need any further information please let me know We would like to thank City Treasurer staff for their assistance and cooperation during this audit All of their valuable time and efforts spent on providing us information is greatly appreciated The audit staff responsible for this audit report is DeeDee Alari Claudia Orsi Kyle Elser and Chris Constantin

Respectfully submitted

Eduardo Luna City Auditor

cc Jan Goldsmith City Attorney Jay M Goldstone Chief Operating Officer Wally Hill Assistant Chief Operating Officer Mary Lewis Chief Financial Officer Andrea Tevlin Independent Budget Analyst Gail Granewich City Treasurer

OFFICE OF THE CITY AUDITOR 1010 SECOND AVENUE SUITE 1400 SAN DIEGO CA 92101

PHONE (619) 533-3165 FAX (619) 533-3036

This Page Intentionally Left Blank

Table of Contents

Results in Brief 1

Introduction 2

Background 2

Objective Scope and Methodology 7

Audit Results 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections 10

The City Lacks an Authoritative and Effective Invoicing and Referral Policy 14

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual 15

Conclusion 17

Recommendations 18

Appendix A ndash Definition of Audit Recommendation Priorities 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables 20

Appendix C ndash Best Practices and Tools Used by the Program 23

OCA-11-007

Results in Brief

Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million1 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables2 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We made seven recommendations to help improve the rate of collections of delinquent accounts and to standardize the Cityrsquos billing referral and the collection processes

1 The total account receivable amount as of February 2010 shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos 2 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 1

Introduction

In accordance with the City Auditorrsquos workplan we have completed an Audit of the City Treasurerrsquos Delinquent Accounts Program We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives We limited our work to those areas specified in the ldquoAudit Objective Scope and Methodologyrdquo section of this report

The City Auditorrsquos Office thanks the City Treasurer Department for giving their time information insight and cooperation during the audit process

Background The Office of the City Treasurer is responsible for receipt and custody of all citywide revenue including banking investment tax administration collection and the accounting for these funds These funds total approximately $2 billion annually The Departmentrsquos mission is To receive safeguard and efficiently manage public funds while providing the highest level of customer service

The Office of the City Treasurer is a Mayoral department under the Chief Operating Officer and the Chief Financial Officer Figure 1 represents the organizational structure of the City of San Diegorsquos Financial Operations

OCA-11-007 Page 2

Figure 1 City of San Diego Financial Operations

Mayor

Chief OperatingOfficer

Chief Financial Officer

City Treasurer

Source City of San Diego Organizational Chart April 2010

San Diego City Charter Section 45 and San Diego Municipal Code sect221707 authorizes the City Treasurer to demand and receive payment of past due accounts and to charge fees and interest on those accounts In 1983 the City of San Diego (City) created a centralized city-wide collections programmdashthe Delinquent Accounts Program The City Treasurerrsquos Revenue Collections Division administers the Delinquent Accounts Program (the Program) which is responsible for the administration and collection of delinquent accounts referred to the City Treasurer by other City departments and agencies The Program also represents the City in small claims court actions on delinquent accounts Figure 2 represents the organizational structure of the Delinquent Accounts Program within the Office of the City Treasurer

OCA-11-007 Page 3

Figure 2 City Treasurer Delinquent Accounts Program3

City Treasurer

TreasuryOperationsDivision Revenue Collections

Division

Parking MeterOperations Delinquent Accounts

Program

Collection Unit 100 Collection Unit 200 Collection Unit 300 Legal Unit

Parking Administration

Investments Division

Information Systems amp

Applications

Source City of San Diego Organizational Chart April 2010

Delinquent accounts or past due receivables are referred to the Program by other city departments and from other divisions within City Treasurer Referrals come from almost all City departments that invoice or collect money including the Police Department Fire Department Real Estate Assets Department Development Services Department Library and the Park and Recreation Department ndash as well as referrals from other divisions and units of the Office of the City Treasurer Examples of the types of accounts referred include business and rental unit tax parking tickets library fines water and sewer bills and police and fire fees and permits City departments are required to make referrals of past due accounts to the Delinquent Accounts Program within 30 days of the invoice due date4

The Delinquent Accounts Program uses a variety of collection procedures and tools ndash including credit reporting legal action and State tax refund interception to obtain payment from debtors The process varies based on the type and value of the debt however Figure 3 represents the general Collection Process

3 This organizational chart represents the detail for the Delinquent Accounts Program only and does not depict the detail of other divisions within City Treasurer nor other programs within Revenue Collection4 Administrative Regulation (AR) 6330 (March 1 2001) governs Accounts Receivable ndash Invoice Processing and Collection

OCA-11-007 Page 4

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 2: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

This Page Intentionally Left Blank

OCA-11-007

October 25 2010

Honorable Mayor City Council and Audit Committee Members City of San Diego California

Transmitted herewith is an audit report on the City Treasurerrsquos Delinquent Accounts Program This report is in accordance with City Charter Section 392 The Results in Brief is presented on page 1 The Administrationrsquos response to our audit recommendations can be found after page 23 of the report This is the second and final report related to the Delinquent Accounts Program The first report was issued in December 2009 and focused on past due accounts of the Development Services Department

If you need any further information please let me know We would like to thank City Treasurer staff for their assistance and cooperation during this audit All of their valuable time and efforts spent on providing us information is greatly appreciated The audit staff responsible for this audit report is DeeDee Alari Claudia Orsi Kyle Elser and Chris Constantin

Respectfully submitted

Eduardo Luna City Auditor

cc Jan Goldsmith City Attorney Jay M Goldstone Chief Operating Officer Wally Hill Assistant Chief Operating Officer Mary Lewis Chief Financial Officer Andrea Tevlin Independent Budget Analyst Gail Granewich City Treasurer

OFFICE OF THE CITY AUDITOR 1010 SECOND AVENUE SUITE 1400 SAN DIEGO CA 92101

PHONE (619) 533-3165 FAX (619) 533-3036

This Page Intentionally Left Blank

Table of Contents

Results in Brief 1

Introduction 2

Background 2

Objective Scope and Methodology 7

Audit Results 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections 10

The City Lacks an Authoritative and Effective Invoicing and Referral Policy 14

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual 15

Conclusion 17

Recommendations 18

Appendix A ndash Definition of Audit Recommendation Priorities 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables 20

Appendix C ndash Best Practices and Tools Used by the Program 23

OCA-11-007

Results in Brief

Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million1 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables2 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We made seven recommendations to help improve the rate of collections of delinquent accounts and to standardize the Cityrsquos billing referral and the collection processes

1 The total account receivable amount as of February 2010 shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos 2 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 1

Introduction

In accordance with the City Auditorrsquos workplan we have completed an Audit of the City Treasurerrsquos Delinquent Accounts Program We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives We limited our work to those areas specified in the ldquoAudit Objective Scope and Methodologyrdquo section of this report

The City Auditorrsquos Office thanks the City Treasurer Department for giving their time information insight and cooperation during the audit process

Background The Office of the City Treasurer is responsible for receipt and custody of all citywide revenue including banking investment tax administration collection and the accounting for these funds These funds total approximately $2 billion annually The Departmentrsquos mission is To receive safeguard and efficiently manage public funds while providing the highest level of customer service

The Office of the City Treasurer is a Mayoral department under the Chief Operating Officer and the Chief Financial Officer Figure 1 represents the organizational structure of the City of San Diegorsquos Financial Operations

OCA-11-007 Page 2

Figure 1 City of San Diego Financial Operations

Mayor

Chief OperatingOfficer

Chief Financial Officer

City Treasurer

Source City of San Diego Organizational Chart April 2010

San Diego City Charter Section 45 and San Diego Municipal Code sect221707 authorizes the City Treasurer to demand and receive payment of past due accounts and to charge fees and interest on those accounts In 1983 the City of San Diego (City) created a centralized city-wide collections programmdashthe Delinquent Accounts Program The City Treasurerrsquos Revenue Collections Division administers the Delinquent Accounts Program (the Program) which is responsible for the administration and collection of delinquent accounts referred to the City Treasurer by other City departments and agencies The Program also represents the City in small claims court actions on delinquent accounts Figure 2 represents the organizational structure of the Delinquent Accounts Program within the Office of the City Treasurer

OCA-11-007 Page 3

Figure 2 City Treasurer Delinquent Accounts Program3

City Treasurer

TreasuryOperationsDivision Revenue Collections

Division

Parking MeterOperations Delinquent Accounts

Program

Collection Unit 100 Collection Unit 200 Collection Unit 300 Legal Unit

Parking Administration

Investments Division

Information Systems amp

Applications

Source City of San Diego Organizational Chart April 2010

Delinquent accounts or past due receivables are referred to the Program by other city departments and from other divisions within City Treasurer Referrals come from almost all City departments that invoice or collect money including the Police Department Fire Department Real Estate Assets Department Development Services Department Library and the Park and Recreation Department ndash as well as referrals from other divisions and units of the Office of the City Treasurer Examples of the types of accounts referred include business and rental unit tax parking tickets library fines water and sewer bills and police and fire fees and permits City departments are required to make referrals of past due accounts to the Delinquent Accounts Program within 30 days of the invoice due date4

The Delinquent Accounts Program uses a variety of collection procedures and tools ndash including credit reporting legal action and State tax refund interception to obtain payment from debtors The process varies based on the type and value of the debt however Figure 3 represents the general Collection Process

3 This organizational chart represents the detail for the Delinquent Accounts Program only and does not depict the detail of other divisions within City Treasurer nor other programs within Revenue Collection4 Administrative Regulation (AR) 6330 (March 1 2001) governs Accounts Receivable ndash Invoice Processing and Collection

OCA-11-007 Page 4

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 3: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

OCA-11-007

October 25 2010

Honorable Mayor City Council and Audit Committee Members City of San Diego California

Transmitted herewith is an audit report on the City Treasurerrsquos Delinquent Accounts Program This report is in accordance with City Charter Section 392 The Results in Brief is presented on page 1 The Administrationrsquos response to our audit recommendations can be found after page 23 of the report This is the second and final report related to the Delinquent Accounts Program The first report was issued in December 2009 and focused on past due accounts of the Development Services Department

If you need any further information please let me know We would like to thank City Treasurer staff for their assistance and cooperation during this audit All of their valuable time and efforts spent on providing us information is greatly appreciated The audit staff responsible for this audit report is DeeDee Alari Claudia Orsi Kyle Elser and Chris Constantin

Respectfully submitted

Eduardo Luna City Auditor

cc Jan Goldsmith City Attorney Jay M Goldstone Chief Operating Officer Wally Hill Assistant Chief Operating Officer Mary Lewis Chief Financial Officer Andrea Tevlin Independent Budget Analyst Gail Granewich City Treasurer

OFFICE OF THE CITY AUDITOR 1010 SECOND AVENUE SUITE 1400 SAN DIEGO CA 92101

PHONE (619) 533-3165 FAX (619) 533-3036

This Page Intentionally Left Blank

Table of Contents

Results in Brief 1

Introduction 2

Background 2

Objective Scope and Methodology 7

Audit Results 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections 10

The City Lacks an Authoritative and Effective Invoicing and Referral Policy 14

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual 15

Conclusion 17

Recommendations 18

Appendix A ndash Definition of Audit Recommendation Priorities 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables 20

Appendix C ndash Best Practices and Tools Used by the Program 23

OCA-11-007

Results in Brief

Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million1 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables2 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We made seven recommendations to help improve the rate of collections of delinquent accounts and to standardize the Cityrsquos billing referral and the collection processes

1 The total account receivable amount as of February 2010 shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos 2 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 1

Introduction

In accordance with the City Auditorrsquos workplan we have completed an Audit of the City Treasurerrsquos Delinquent Accounts Program We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives We limited our work to those areas specified in the ldquoAudit Objective Scope and Methodologyrdquo section of this report

The City Auditorrsquos Office thanks the City Treasurer Department for giving their time information insight and cooperation during the audit process

Background The Office of the City Treasurer is responsible for receipt and custody of all citywide revenue including banking investment tax administration collection and the accounting for these funds These funds total approximately $2 billion annually The Departmentrsquos mission is To receive safeguard and efficiently manage public funds while providing the highest level of customer service

The Office of the City Treasurer is a Mayoral department under the Chief Operating Officer and the Chief Financial Officer Figure 1 represents the organizational structure of the City of San Diegorsquos Financial Operations

OCA-11-007 Page 2

Figure 1 City of San Diego Financial Operations

Mayor

Chief OperatingOfficer

Chief Financial Officer

City Treasurer

Source City of San Diego Organizational Chart April 2010

San Diego City Charter Section 45 and San Diego Municipal Code sect221707 authorizes the City Treasurer to demand and receive payment of past due accounts and to charge fees and interest on those accounts In 1983 the City of San Diego (City) created a centralized city-wide collections programmdashthe Delinquent Accounts Program The City Treasurerrsquos Revenue Collections Division administers the Delinquent Accounts Program (the Program) which is responsible for the administration and collection of delinquent accounts referred to the City Treasurer by other City departments and agencies The Program also represents the City in small claims court actions on delinquent accounts Figure 2 represents the organizational structure of the Delinquent Accounts Program within the Office of the City Treasurer

OCA-11-007 Page 3

Figure 2 City Treasurer Delinquent Accounts Program3

City Treasurer

TreasuryOperationsDivision Revenue Collections

Division

Parking MeterOperations Delinquent Accounts

Program

Collection Unit 100 Collection Unit 200 Collection Unit 300 Legal Unit

Parking Administration

Investments Division

Information Systems amp

Applications

Source City of San Diego Organizational Chart April 2010

Delinquent accounts or past due receivables are referred to the Program by other city departments and from other divisions within City Treasurer Referrals come from almost all City departments that invoice or collect money including the Police Department Fire Department Real Estate Assets Department Development Services Department Library and the Park and Recreation Department ndash as well as referrals from other divisions and units of the Office of the City Treasurer Examples of the types of accounts referred include business and rental unit tax parking tickets library fines water and sewer bills and police and fire fees and permits City departments are required to make referrals of past due accounts to the Delinquent Accounts Program within 30 days of the invoice due date4

The Delinquent Accounts Program uses a variety of collection procedures and tools ndash including credit reporting legal action and State tax refund interception to obtain payment from debtors The process varies based on the type and value of the debt however Figure 3 represents the general Collection Process

3 This organizational chart represents the detail for the Delinquent Accounts Program only and does not depict the detail of other divisions within City Treasurer nor other programs within Revenue Collection4 Administrative Regulation (AR) 6330 (March 1 2001) governs Accounts Receivable ndash Invoice Processing and Collection

OCA-11-007 Page 4

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 4: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

This Page Intentionally Left Blank

Table of Contents

Results in Brief 1

Introduction 2

Background 2

Objective Scope and Methodology 7

Audit Results 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections 10

The City Lacks an Authoritative and Effective Invoicing and Referral Policy 14

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual 15

Conclusion 17

Recommendations 18

Appendix A ndash Definition of Audit Recommendation Priorities 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables 20

Appendix C ndash Best Practices and Tools Used by the Program 23

OCA-11-007

Results in Brief

Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million1 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables2 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We made seven recommendations to help improve the rate of collections of delinquent accounts and to standardize the Cityrsquos billing referral and the collection processes

1 The total account receivable amount as of February 2010 shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos 2 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 1

Introduction

In accordance with the City Auditorrsquos workplan we have completed an Audit of the City Treasurerrsquos Delinquent Accounts Program We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives We limited our work to those areas specified in the ldquoAudit Objective Scope and Methodologyrdquo section of this report

The City Auditorrsquos Office thanks the City Treasurer Department for giving their time information insight and cooperation during the audit process

Background The Office of the City Treasurer is responsible for receipt and custody of all citywide revenue including banking investment tax administration collection and the accounting for these funds These funds total approximately $2 billion annually The Departmentrsquos mission is To receive safeguard and efficiently manage public funds while providing the highest level of customer service

The Office of the City Treasurer is a Mayoral department under the Chief Operating Officer and the Chief Financial Officer Figure 1 represents the organizational structure of the City of San Diegorsquos Financial Operations

OCA-11-007 Page 2

Figure 1 City of San Diego Financial Operations

Mayor

Chief OperatingOfficer

Chief Financial Officer

City Treasurer

Source City of San Diego Organizational Chart April 2010

San Diego City Charter Section 45 and San Diego Municipal Code sect221707 authorizes the City Treasurer to demand and receive payment of past due accounts and to charge fees and interest on those accounts In 1983 the City of San Diego (City) created a centralized city-wide collections programmdashthe Delinquent Accounts Program The City Treasurerrsquos Revenue Collections Division administers the Delinquent Accounts Program (the Program) which is responsible for the administration and collection of delinquent accounts referred to the City Treasurer by other City departments and agencies The Program also represents the City in small claims court actions on delinquent accounts Figure 2 represents the organizational structure of the Delinquent Accounts Program within the Office of the City Treasurer

OCA-11-007 Page 3

Figure 2 City Treasurer Delinquent Accounts Program3

City Treasurer

TreasuryOperationsDivision Revenue Collections

Division

Parking MeterOperations Delinquent Accounts

Program

Collection Unit 100 Collection Unit 200 Collection Unit 300 Legal Unit

Parking Administration

Investments Division

Information Systems amp

Applications

Source City of San Diego Organizational Chart April 2010

Delinquent accounts or past due receivables are referred to the Program by other city departments and from other divisions within City Treasurer Referrals come from almost all City departments that invoice or collect money including the Police Department Fire Department Real Estate Assets Department Development Services Department Library and the Park and Recreation Department ndash as well as referrals from other divisions and units of the Office of the City Treasurer Examples of the types of accounts referred include business and rental unit tax parking tickets library fines water and sewer bills and police and fire fees and permits City departments are required to make referrals of past due accounts to the Delinquent Accounts Program within 30 days of the invoice due date4

The Delinquent Accounts Program uses a variety of collection procedures and tools ndash including credit reporting legal action and State tax refund interception to obtain payment from debtors The process varies based on the type and value of the debt however Figure 3 represents the general Collection Process

3 This organizational chart represents the detail for the Delinquent Accounts Program only and does not depict the detail of other divisions within City Treasurer nor other programs within Revenue Collection4 Administrative Regulation (AR) 6330 (March 1 2001) governs Accounts Receivable ndash Invoice Processing and Collection

OCA-11-007 Page 4

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 5: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Table of Contents

Results in Brief 1

Introduction 2

Background 2

Objective Scope and Methodology 7

Audit Results 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections 10

The City Lacks an Authoritative and Effective Invoicing and Referral Policy 14

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual 15

Conclusion 17

Recommendations 18

Appendix A ndash Definition of Audit Recommendation Priorities 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables 20

Appendix C ndash Best Practices and Tools Used by the Program 23

OCA-11-007

Results in Brief

Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million1 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables2 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We made seven recommendations to help improve the rate of collections of delinquent accounts and to standardize the Cityrsquos billing referral and the collection processes

1 The total account receivable amount as of February 2010 shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos 2 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 1

Introduction

In accordance with the City Auditorrsquos workplan we have completed an Audit of the City Treasurerrsquos Delinquent Accounts Program We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives We limited our work to those areas specified in the ldquoAudit Objective Scope and Methodologyrdquo section of this report

The City Auditorrsquos Office thanks the City Treasurer Department for giving their time information insight and cooperation during the audit process

Background The Office of the City Treasurer is responsible for receipt and custody of all citywide revenue including banking investment tax administration collection and the accounting for these funds These funds total approximately $2 billion annually The Departmentrsquos mission is To receive safeguard and efficiently manage public funds while providing the highest level of customer service

The Office of the City Treasurer is a Mayoral department under the Chief Operating Officer and the Chief Financial Officer Figure 1 represents the organizational structure of the City of San Diegorsquos Financial Operations

OCA-11-007 Page 2

Figure 1 City of San Diego Financial Operations

Mayor

Chief OperatingOfficer

Chief Financial Officer

City Treasurer

Source City of San Diego Organizational Chart April 2010

San Diego City Charter Section 45 and San Diego Municipal Code sect221707 authorizes the City Treasurer to demand and receive payment of past due accounts and to charge fees and interest on those accounts In 1983 the City of San Diego (City) created a centralized city-wide collections programmdashthe Delinquent Accounts Program The City Treasurerrsquos Revenue Collections Division administers the Delinquent Accounts Program (the Program) which is responsible for the administration and collection of delinquent accounts referred to the City Treasurer by other City departments and agencies The Program also represents the City in small claims court actions on delinquent accounts Figure 2 represents the organizational structure of the Delinquent Accounts Program within the Office of the City Treasurer

OCA-11-007 Page 3

Figure 2 City Treasurer Delinquent Accounts Program3

City Treasurer

TreasuryOperationsDivision Revenue Collections

Division

Parking MeterOperations Delinquent Accounts

Program

Collection Unit 100 Collection Unit 200 Collection Unit 300 Legal Unit

Parking Administration

Investments Division

Information Systems amp

Applications

Source City of San Diego Organizational Chart April 2010

Delinquent accounts or past due receivables are referred to the Program by other city departments and from other divisions within City Treasurer Referrals come from almost all City departments that invoice or collect money including the Police Department Fire Department Real Estate Assets Department Development Services Department Library and the Park and Recreation Department ndash as well as referrals from other divisions and units of the Office of the City Treasurer Examples of the types of accounts referred include business and rental unit tax parking tickets library fines water and sewer bills and police and fire fees and permits City departments are required to make referrals of past due accounts to the Delinquent Accounts Program within 30 days of the invoice due date4

The Delinquent Accounts Program uses a variety of collection procedures and tools ndash including credit reporting legal action and State tax refund interception to obtain payment from debtors The process varies based on the type and value of the debt however Figure 3 represents the general Collection Process

3 This organizational chart represents the detail for the Delinquent Accounts Program only and does not depict the detail of other divisions within City Treasurer nor other programs within Revenue Collection4 Administrative Regulation (AR) 6330 (March 1 2001) governs Accounts Receivable ndash Invoice Processing and Collection

OCA-11-007 Page 4

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 6: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Results in Brief

Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million1 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables2 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We made seven recommendations to help improve the rate of collections of delinquent accounts and to standardize the Cityrsquos billing referral and the collection processes

1 The total account receivable amount as of February 2010 shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos 2 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 1

Introduction

In accordance with the City Auditorrsquos workplan we have completed an Audit of the City Treasurerrsquos Delinquent Accounts Program We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives We limited our work to those areas specified in the ldquoAudit Objective Scope and Methodologyrdquo section of this report

The City Auditorrsquos Office thanks the City Treasurer Department for giving their time information insight and cooperation during the audit process

Background The Office of the City Treasurer is responsible for receipt and custody of all citywide revenue including banking investment tax administration collection and the accounting for these funds These funds total approximately $2 billion annually The Departmentrsquos mission is To receive safeguard and efficiently manage public funds while providing the highest level of customer service

The Office of the City Treasurer is a Mayoral department under the Chief Operating Officer and the Chief Financial Officer Figure 1 represents the organizational structure of the City of San Diegorsquos Financial Operations

OCA-11-007 Page 2

Figure 1 City of San Diego Financial Operations

Mayor

Chief OperatingOfficer

Chief Financial Officer

City Treasurer

Source City of San Diego Organizational Chart April 2010

San Diego City Charter Section 45 and San Diego Municipal Code sect221707 authorizes the City Treasurer to demand and receive payment of past due accounts and to charge fees and interest on those accounts In 1983 the City of San Diego (City) created a centralized city-wide collections programmdashthe Delinquent Accounts Program The City Treasurerrsquos Revenue Collections Division administers the Delinquent Accounts Program (the Program) which is responsible for the administration and collection of delinquent accounts referred to the City Treasurer by other City departments and agencies The Program also represents the City in small claims court actions on delinquent accounts Figure 2 represents the organizational structure of the Delinquent Accounts Program within the Office of the City Treasurer

OCA-11-007 Page 3

Figure 2 City Treasurer Delinquent Accounts Program3

City Treasurer

TreasuryOperationsDivision Revenue Collections

Division

Parking MeterOperations Delinquent Accounts

Program

Collection Unit 100 Collection Unit 200 Collection Unit 300 Legal Unit

Parking Administration

Investments Division

Information Systems amp

Applications

Source City of San Diego Organizational Chart April 2010

Delinquent accounts or past due receivables are referred to the Program by other city departments and from other divisions within City Treasurer Referrals come from almost all City departments that invoice or collect money including the Police Department Fire Department Real Estate Assets Department Development Services Department Library and the Park and Recreation Department ndash as well as referrals from other divisions and units of the Office of the City Treasurer Examples of the types of accounts referred include business and rental unit tax parking tickets library fines water and sewer bills and police and fire fees and permits City departments are required to make referrals of past due accounts to the Delinquent Accounts Program within 30 days of the invoice due date4

The Delinquent Accounts Program uses a variety of collection procedures and tools ndash including credit reporting legal action and State tax refund interception to obtain payment from debtors The process varies based on the type and value of the debt however Figure 3 represents the general Collection Process

3 This organizational chart represents the detail for the Delinquent Accounts Program only and does not depict the detail of other divisions within City Treasurer nor other programs within Revenue Collection4 Administrative Regulation (AR) 6330 (March 1 2001) governs Accounts Receivable ndash Invoice Processing and Collection

OCA-11-007 Page 4

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 7: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Introduction

In accordance with the City Auditorrsquos workplan we have completed an Audit of the City Treasurerrsquos Delinquent Accounts Program We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives We limited our work to those areas specified in the ldquoAudit Objective Scope and Methodologyrdquo section of this report

The City Auditorrsquos Office thanks the City Treasurer Department for giving their time information insight and cooperation during the audit process

Background The Office of the City Treasurer is responsible for receipt and custody of all citywide revenue including banking investment tax administration collection and the accounting for these funds These funds total approximately $2 billion annually The Departmentrsquos mission is To receive safeguard and efficiently manage public funds while providing the highest level of customer service

The Office of the City Treasurer is a Mayoral department under the Chief Operating Officer and the Chief Financial Officer Figure 1 represents the organizational structure of the City of San Diegorsquos Financial Operations

OCA-11-007 Page 2

Figure 1 City of San Diego Financial Operations

Mayor

Chief OperatingOfficer

Chief Financial Officer

City Treasurer

Source City of San Diego Organizational Chart April 2010

San Diego City Charter Section 45 and San Diego Municipal Code sect221707 authorizes the City Treasurer to demand and receive payment of past due accounts and to charge fees and interest on those accounts In 1983 the City of San Diego (City) created a centralized city-wide collections programmdashthe Delinquent Accounts Program The City Treasurerrsquos Revenue Collections Division administers the Delinquent Accounts Program (the Program) which is responsible for the administration and collection of delinquent accounts referred to the City Treasurer by other City departments and agencies The Program also represents the City in small claims court actions on delinquent accounts Figure 2 represents the organizational structure of the Delinquent Accounts Program within the Office of the City Treasurer

OCA-11-007 Page 3

Figure 2 City Treasurer Delinquent Accounts Program3

City Treasurer

TreasuryOperationsDivision Revenue Collections

Division

Parking MeterOperations Delinquent Accounts

Program

Collection Unit 100 Collection Unit 200 Collection Unit 300 Legal Unit

Parking Administration

Investments Division

Information Systems amp

Applications

Source City of San Diego Organizational Chart April 2010

Delinquent accounts or past due receivables are referred to the Program by other city departments and from other divisions within City Treasurer Referrals come from almost all City departments that invoice or collect money including the Police Department Fire Department Real Estate Assets Department Development Services Department Library and the Park and Recreation Department ndash as well as referrals from other divisions and units of the Office of the City Treasurer Examples of the types of accounts referred include business and rental unit tax parking tickets library fines water and sewer bills and police and fire fees and permits City departments are required to make referrals of past due accounts to the Delinquent Accounts Program within 30 days of the invoice due date4

The Delinquent Accounts Program uses a variety of collection procedures and tools ndash including credit reporting legal action and State tax refund interception to obtain payment from debtors The process varies based on the type and value of the debt however Figure 3 represents the general Collection Process

3 This organizational chart represents the detail for the Delinquent Accounts Program only and does not depict the detail of other divisions within City Treasurer nor other programs within Revenue Collection4 Administrative Regulation (AR) 6330 (March 1 2001) governs Accounts Receivable ndash Invoice Processing and Collection

OCA-11-007 Page 4

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 8: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Figure 1 City of San Diego Financial Operations

Mayor

Chief OperatingOfficer

Chief Financial Officer

City Treasurer

Source City of San Diego Organizational Chart April 2010

San Diego City Charter Section 45 and San Diego Municipal Code sect221707 authorizes the City Treasurer to demand and receive payment of past due accounts and to charge fees and interest on those accounts In 1983 the City of San Diego (City) created a centralized city-wide collections programmdashthe Delinquent Accounts Program The City Treasurerrsquos Revenue Collections Division administers the Delinquent Accounts Program (the Program) which is responsible for the administration and collection of delinquent accounts referred to the City Treasurer by other City departments and agencies The Program also represents the City in small claims court actions on delinquent accounts Figure 2 represents the organizational structure of the Delinquent Accounts Program within the Office of the City Treasurer

OCA-11-007 Page 3

Figure 2 City Treasurer Delinquent Accounts Program3

City Treasurer

TreasuryOperationsDivision Revenue Collections

Division

Parking MeterOperations Delinquent Accounts

Program

Collection Unit 100 Collection Unit 200 Collection Unit 300 Legal Unit

Parking Administration

Investments Division

Information Systems amp

Applications

Source City of San Diego Organizational Chart April 2010

Delinquent accounts or past due receivables are referred to the Program by other city departments and from other divisions within City Treasurer Referrals come from almost all City departments that invoice or collect money including the Police Department Fire Department Real Estate Assets Department Development Services Department Library and the Park and Recreation Department ndash as well as referrals from other divisions and units of the Office of the City Treasurer Examples of the types of accounts referred include business and rental unit tax parking tickets library fines water and sewer bills and police and fire fees and permits City departments are required to make referrals of past due accounts to the Delinquent Accounts Program within 30 days of the invoice due date4

The Delinquent Accounts Program uses a variety of collection procedures and tools ndash including credit reporting legal action and State tax refund interception to obtain payment from debtors The process varies based on the type and value of the debt however Figure 3 represents the general Collection Process

3 This organizational chart represents the detail for the Delinquent Accounts Program only and does not depict the detail of other divisions within City Treasurer nor other programs within Revenue Collection4 Administrative Regulation (AR) 6330 (March 1 2001) governs Accounts Receivable ndash Invoice Processing and Collection

OCA-11-007 Page 4

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 9: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Figure 2 City Treasurer Delinquent Accounts Program3

City Treasurer

TreasuryOperationsDivision Revenue Collections

Division

Parking MeterOperations Delinquent Accounts

Program

Collection Unit 100 Collection Unit 200 Collection Unit 300 Legal Unit

Parking Administration

Investments Division

Information Systems amp

Applications

Source City of San Diego Organizational Chart April 2010

Delinquent accounts or past due receivables are referred to the Program by other city departments and from other divisions within City Treasurer Referrals come from almost all City departments that invoice or collect money including the Police Department Fire Department Real Estate Assets Department Development Services Department Library and the Park and Recreation Department ndash as well as referrals from other divisions and units of the Office of the City Treasurer Examples of the types of accounts referred include business and rental unit tax parking tickets library fines water and sewer bills and police and fire fees and permits City departments are required to make referrals of past due accounts to the Delinquent Accounts Program within 30 days of the invoice due date4

The Delinquent Accounts Program uses a variety of collection procedures and tools ndash including credit reporting legal action and State tax refund interception to obtain payment from debtors The process varies based on the type and value of the debt however Figure 3 represents the general Collection Process

3 This organizational chart represents the detail for the Delinquent Accounts Program only and does not depict the detail of other divisions within City Treasurer nor other programs within Revenue Collection4 Administrative Regulation (AR) 6330 (March 1 2001) governs Accounts Receivable ndash Invoice Processing and Collection

OCA-11-007 Page 4

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 10: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

surers Department Collection Process

Department Billing Proces s (Administrative Regulation 6330)

Debt Incurred

initiate CoIIecllon

- AIXoum enle~ In Collection System - MaIWnv lldd ~on~lIy certified and check-l tor mai forwarding order lind pohQne normber - Mall collecUon

Day 61-63

bay 1

Initial Billing

Refer to [

Day 31

Payment Due

OayBO

I I bayet

Payment Delinquent

Over 5100 - Asslgn 0 COllection Inv sUgator bull T-phone cal~ - AddlIonllllellenl - Locale aSHts and Soda Securtty No - Slltiptrttee - Refr for ~ Action

Under $100 - A68lgn 10 Small

BaJanoa Oe$k

Day 00

nile Boanifor InterceptIOn 01 Stat lrocorn Tell RetlNn

Day 120 Day 121 lind Beyond

T reasurer Collection Process Days

Cre dit Rep o rting 1IUat COllec tion notices advise citiZens Ihat Information on COtlelttlon accounts m ay ba reported to various credi t reporting agencies Reporting o f this Information crealas consequences fOf those that do not pay timely_

Sta te f ra n c h ise Ta x Boa rd Accounts Wi th Social Security Numbers are referred to the Stale Franchise Tax Board annually for Interception o f State Income Tax Returns and Lottery Winnings The City receives more than $1 mllllon annually as a result of this collection tool

Le g a l A c tion The Collection Programmiddots Legal Section handles collection efforts on more difficul t mailers amounts owed by the Stale o f Cali fornia and other Federal and local governmenl agencies represents the City as plaintiff in Small Claim s Court and partnel$ with the Ci ty A ttorneymiddots CiY~ Enforcement Unit w hich assists the Collection Program In mattefS requiring more aggressive litigation

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

w1l11tle Collection

- AIXlouIl enl filf$(l In CoIlKUon System - M l~nv add eleoctronlcilily carolled a nd ctledlted rex- mall forwardIng order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oar 80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn to COIIecI IOll I f1YIIIstlgalOr bull T Mphone caI~ - AddllonalleUers - locole _lMIts and Soda S8cutUy No - $lupln o - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

0890

In leroepbQo of State lrocorn Tall Return

Day 120 Day 121 and Beyond

Treasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformatlon on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thaI do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the Stale Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as 8 result of this coliecUOrl tool

Legal A ction The Collection Programs Legal Section handles cOllectiorl efforts on more difficult mellers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the Ci ty AnQrney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive litig8tiQn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l InCol~on System bull M l~nv add eleoctronlcilily carolled and ctleltked (ex- mall forwarding order and phgne number - Mall (lO11ICllon notice

Day 61-63

Oay 1

Initial Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcolOr

- Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal S8ltutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerdfor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

C redit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

Sta te f ra n c hise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon 1001

Le g a l A c t ion The Collection Programs Legal Section hOndles collectiorl efforts on more difficult mailers amounts owed by Ihe SUIte of California and Olher Federal and local govemmenl agencies represents the Cily as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligampl iOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcilily carolled and ctledlted (ex- mall forwarding order and phgne number - Mall QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecIIOll If1YIIIstlgcnar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

Under $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T liIxBoercHor InleroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information CIlIa tes consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay 61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Ma ll QOIIIICllon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgaugtr - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens lhallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the SUIte of California and o ther Federal and local government agencies represents the City as plaintiff In Smell Claims Court and partner$ with the Ci ty A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligamptiOn

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll If1YIIIs tlgatar - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Department Collection Process

Department Billing Process (Administrative Regulatlon 6330)

Debt Incurred

bull AoCouIl 9nfiIf$(l In CoIlecUon System bull M l~nv add eleoctronlcil ily carolled and ctleltked (ex- mall forwarding order a nd phgne number - Mall QOIIIICtIon notice

Day 61-63

Oay 1

InlUal Billing

Refer to I

bay 31

Payment Due

Oa)80

I I Oay61

Payment Delinquent

Over 5100 - AssIgn 10 COIIecI IOll 1f1Ystl~ - Tphone caI~ - AddllonalleUers - locole _lMIts and Sodal 5ecutUy No - $luplno - Refer for legal Action

U nder $100 - A6s1gn 10 Small

BaJanoa Desk

08)90

T ax Boerd for In leroepbQo of State Irocorn Tp Return

Day 120 Day 121 and Beyond

T reasurer Collection Process Days

Credit Reporting Inltlal COllection notices advise ciUzens Ihallnformation on COlleCliOIl accounts may be reported to vanous credit reporting 8genc185 Reporting of this Information creates consequences for those thai do not pay timely

State franchise Tax Board Accoonls With Social Security Numbe-s are referred to the State Franchise Ta) Board annually for IntEllcepUon of Siale Income Tax Returns and LoUery Winnings The City receives more than $1 million annually as a result of this coliecuon tool

Legal A ction The Collection Programs Legal Section handles collectiorl efforts on more difficult mailers amounts owed by the State of California and o ther Federal and local government agencies represents the City as plaintiff In Small Claims Court and partner$ with the City A ttorney ClvH Enforcement Unit which assists the Collection Program In matters requiring more aggressive liligalion

Figure 3 Delinquent Accounts Program Collection Process

Source Office of the City Treasurer

OCA-11-007 Page 5

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 11: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Program staffs use the Columbia Ultimate Business System (CUBS) to track and manage delinquent accounts and collection efforts and activities All past due accounts referred to the Program are entered in CUBS The majority of referrals are received via a system interface however some referrals are received manually via hard copy A First Written Notice (Notice 1) is generated automatically by CUBS within five days of referral After 30 days CUBS will assign the past due account to a Collector These assignments appear in the Collectorrsquos Work in Progress (WIP) Account assignment and placement in WIP is automatic and is based on programming within CUBS designed to prioritize accounts

Collectors work accounts independently but are currently organized into two teams which are collectively referred to as the Collections Floor 5Each Collector has a case load of approximately 800 to 1200 WIP accounts Collectorrsquos ldquoworkrdquo the accounts through a variety of collection attempts including but not limited to telephone calls written notifications skip tracing (the process of researching someonersquos identification numbers and whereabouts) and locating assets Collectors have access to city systems and databases subscription search services (such as Accurint) other government systems and databases and the internet Collectors also spend time validating debt (verifying the debt is accurate and owed) negotiating payment bundling accounts (joining together two or more debts owed by the same debtor) and eliminating duplicates Collectors have limited authority to adjust or cancel accounts and make payment arrangements and time extensions Collection Supervisors review monthly cancellations and adjustments reports to ensure they are processed according to the Treasurerrsquos guidelines

Customers are provided a variety of payment options including in-person (cash check credit or debit card and money order) online by telephone (including wire) or by mail Payment plans and partial payments can be negotiated

For accounts that remain unpaid debts are reported to the credit reporting agencies (eg Experian) and legal action may be pursued if there are identifiable assets For debts of $5000 or less the Programrsquos Legal Unit pursues judgment in small claims court Debts over $5000 are referred to the City Attorneyrsquos Office With a legal judgment the Program can place liens on property6 intercept rental income7 and place bank or wage levies

All collection efforts are recorded in CUBS A ldquotimerrdquo starts when a Collector begins working an account in his or her WIP The Collector makes notes in CUBS on what collection efforts were made When he or she is finished working that account the timer stops This is a process captured in the daily Collector Activity Report All account modifications (eg adjustments cancellations) are also recorded Collection Supervisors review daily and monthly reports in order to monitor Collector performance These reports depict in detail each Collectorrsquos work efforts as well as down time The Programrsquos Manager utilizes a variety of CUBS reports and Excel spreadsheets to track and monitor Program referrals and recovery (collection)

5 Prior to the fiscal year 2010 reduction in force (RIF) the Program had three teams ndash Unit 100 Unit 200 and Unit 300 After the 2010 RIF Unit 300 was absorbed into Units 100 and 200 and one (of four) Collections Supervisor position was eliminated 6 In San Diego County 7 On debtor Rental Unit Tax property

OCA-11-007 Page 6

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 12: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Objective Scope and Methodology In October 2008 the City Council approved the City Auditorrsquos Fiscal Year 2009 Audit Work Plan which included a performance audit of the City Treasurerrsquos Delinquent Accounts Program (the Program) Work began on this audit in April 2009 and started with a review of the billing and collection practices of several City departments that refer past due accounts to the Program During this initial review we found significant weaknesses in the billing and collection practices of the Development Services Department (DSD) which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts

This second and final report objective focuses on assessing the effectiveness of the Delinquent Account Program of the Office of the City Treasurer and determining if opportunities exist to improve the collection of past due amounts owed to the City To accomplish this audit objective we performed a review of the Programrsquos structure practices and policies and procedures The following audit procedures were used to evaluate the Programrsquos effectiveness

bull Reviewed City laws and regulations related to accounts receivable billing and collection bull Reviewed other relevant collections and credit reporting laws and regulations bull Reviewed Program structure and its written policies and procedures bull Interviewed Division Management Program Management Program Supervisor and

personnel from the City Attorneyrsquos Office bull Surveyed and interviewed personnel from other City departments that refer past due

accounts to the Program bull Reviewed Program performance and activity reports bull Accessed the Programrsquos Columbia Ultimate Business System (CUBS) generated system

reports and tested system accounts bull Analyzed Program account data and bull Researched industry benchmarks performance measures and best practices

We reviewed data from fiscal years 2006 through 2009 unless noted otherwise We performed data reliability testing of the delinquent accounts data provided to us which we relied on in this report and searched for indicators of fraud We evaluated the internal controls related to our audit objectives Our conclusions on the effectiveness of these controls are detailed within the following audit results

The Program has administrative and cash handling functions including a front reception cashiering function This audit did not include a review of cash handling or customer service Accordingly payments received were not tested or traced to bank deposits and controls over the handling and safeguarding of payments were not reviewed or evaluated The objective was limited to the effectiveness of the Programrsquos collection efforts

Data contained in CUBS includes accounts dated back into the 1980s When analyzing total outstanding debt for example all accounts were included regardless of referral date The ldquoas ofrdquo

OCA-11-007 Page 7

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 13: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

date for outstanding debt analyses was February 28 20108 For other analyses including referral and collection trend analysis data was used for fiscal years 2005 through 2009

We conducted this performance audit in accordance with generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives

8 In March 2010 the city replaced its primary invoicing system with an SAP AR module This audit did not include a review of SAP AR implementation and newly referred accounts from SAP were not tested or reviewed

OCA-11-007 Page 8

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 14: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Audit Results Opportunities Exist to Increase Collection of Past Due Accounts Receivable

During the course of many years a significant amount of money owed to the City has accumulated from past due accounts receivable As of February 2010 unpaid past due accounts owed to the City totaled over $100 million9 This money is owed by individuals businesses and government agencies for a variety of different City services fees and penalties While almost half of this debt is five years or more past due over $377 million is less than three years old We found that the Delinquent Accounts Program (Program) follows many industry best practices and collects about 79 percent on the Cityrsquos past due receivables10 however improvements can be made to increase recovery and strengthen the Cityrsquos invoicing (billing) and past due debt referral practices Specifically our review found that the Program and Citywide collection efforts could be improved by

bull implementing additional tools to further increase collections

bull instituting an authoritative and effective invoicing and referral policy and

bull centralizing all Delinquent Account Program policies and procedures in a comprehensive operations manual

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Treasurers should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission We have provided more detailed information on the outstanding debt balance ndash including an analysis by type of debt age of accounts and outstanding balance over time ndash in Appendix B of this report

9 The total account receivable amount shown in this report does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies and transient occupancy tax According to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt was not included in our analysis of accounts referred to Treasurerrsquos

10 The Auditorrsquos collection rate calculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The calculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million

OCA-11-007 Page 9

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 15: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections

We found that the Program has a collection rate higher than the industry standard and has incorporated many best practices Using referral and collection data for the fiscal years 2005 through 2009 we determined that the Program had a recovery rate of 79 percent11 This rate is higher than the rate of an outside collection agency (15-25 percent) and is greater than other governments that have in-house collections programs (averaging 49-65 percent) or that outsource their collection programs (averaging 39-49 percent) An analysis of Collector performance for fiscal years 2006 through 2009 showed that each Collector brings in approximately $500000 annually to the city12 We have provided a list of the best practices followed by the Program in Appendix C of this report

Even with a 79 percent recovery rate the outstanding amount of delinquent accounts owed to the City is over $100 million As seen in following Figure 4 the majority of the total outstanding debt is considered inactive by the Delinquent Account Program and is therefore not included in active collection efforts

11 The Auditorrsquos recalculation divided principal collected by principal referred (less principal cancelled) for all active accounts from 2005 to 2009 The recalculation did not include the Revenue Audit deficiency referral from Online Travel Companies in December 2008 totaling $307 million12 This is the gross amount collected The cost of employing a Collector was not verified but is estimated by the department to be approximately $80000 including fringe benefits

OCA-11-007 Page 10

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 16: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Figure 4 ndash Total Outstanding Debt by Status Code as of February 2010

Cancelled Other $1435740 $1921909 2 2

Active $28978913 28

Inactive $69702674 68

Source Auditor analysis of Treasurerrsquos CUBS data

The Treasurer codes accounts as inactive primarily for these four reasons

Inactive Status Description Total Amount Suspended ndash No response to collection efforts $48 million Unable to locate debtor $82 million Out of State $73 million Statute of limitations expired $58 million

Old debt is maintained in the Treasurerrsquos collection system indefinitely while the debt is written off the Cityrsquos financial statements This gives the Treasurer the ability to still collect future debt payments which periodically come into the City many years after the debt is incurred and written off the financial statements

Statutes of limitation limit the time period in which the City can pursue litigation to collect on old debt but there is no time limit to collect the debt via other means While the City does periodically collects old debts the City Treasurer could do more to attempt to collect on these stagnate accounts Industry research indicates there are additional collection tools available to

OCA-11-007 Page 11

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 17: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

increase recovery According to The Compendium of Local Government Collection Powers and Practices in the United States and Canada13 the City of San Diego could pursue the following

Third-Party Collection Agency Third-party collection agencies should not be the primary means to pursue the collection of the Cityrsquos past due receivables but they could be used to supplement collection efforts In-house collection is a proven best practice and in-house collection rates far exceed those of third-party collection agencies This is due in part to the myriad of tools available to public in-house collection agencies that are not available to third-party collection agencies However the City may benefit from increased recovery by outsourcing inactive accounts which are no longer being actively pursued by the Program (totaling over $69 million) to a private collection agency

Public List of Top Debtors Making public a list of the most egregious debtors is an effective tool to increase recovery In a July 2009 press release the City of Los Angeles announced that nearly $3 million was collected within four months of publishing that cityrsquos first public list in early 2009 Careful legal review must precede making public debtor information however a public list once approved can be an effective tool to increase recovery

Federal Offset Program The Treasury (federal) Offset Program (TOP) is a centralized offset program administered by the Financial Management Service bureau of the United States Department of Treasury TOP intercepts federal payments to payees who owe money to participating agencies that have submitted debt information This is similar to the Delinquent Accounts Programrsquos agreement with the State of Californiarsquos Franchise Tax Board (FTB) ndash FTB intercepts state tax refunds and lottery winnings from tax payers who owe a debt to the City of San Diego TOP is a similar program but nationwide Currently TOP does not partner with municipalities like the City of San Diego but serves federal agencies and some state level agencies through reciprocal agreements however there is a movement towards inclusion of local debt The objective of this movement led by Arlington County Treasurer Frank OrsquoLeary is to allow states participating in the federal program (TOP) to submit debt owed to localities within the state Since the state of California does participate in TOP the City of San Diego should actively pursue the inclusion of municipal debt in TOP to increase recovery

In addition to the three suggested collection tools explained above Program supervisors indicated recovery could improve with increased access to City and other databases and systems Specifically Program supervisors mentioned gaining access to

1 PACERgov14

2 The State of California Employment Development Department (EDD)

Furthermore a customerrsquos social security number (SSN) used to be visible in the City of San Diegorsquos water utilities billing system but Program staff indicated the SSN is now truncated

13 Published by the Arlington County Treasurer 2007 14 Public Access to Court Electronic Records ndash federal bankruptcy records

OCA-11-007 Page 12

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 18: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Although the Water Department does provide the social security number for customersrsquo accounts referred to the Delinquent Accounts Program having access to all customersrsquo SSN could be utilized to locate debtors

To improve the rate of collections of delinquent accounts we recommend that the Program take the following actions

Recommendation 1

The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

Recommendation 2

The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

Recommendation 3

The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

Recommendation 4

The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

Recommendation 5

The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

OCA-11-007 Page 13

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 19: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

The City Lacks an Authoritative and Effective Invoicing and Referral Policy

There are no authoritative and updated guidelines on how City departments should invoice customers and refer past due accounts to the Delinquent Accounts Program Currently each City department bills customers according to outdated Citywide guidelines15 and in some cases according to internal department instructions In addition City departments set the dollar thresholds for referral to the Delinquent Accounts Program and the referral thresholds are not approved by the City Treasurer During our review of three City departments we found that departments handle billings payments collections and referrals to the City Treasurer differently For example the Water Department refers delinquent accounts to the City Treasurer when they are 75 days overdue the Real Estate Assets Department refers accounts after they are 90 days overdue and the Development Services Department had past due accounts that were never referred

Best business practices inform us that timeliness in the referral of delinquent accounts following departmental collection efforts is critical and should be within 30 days16 Current City policy requires that City departments refer delinquent accounts within 30 days of the original invoice due date

The Program relies on the originating (referring) department to accurately bill customers in a timely manner and to properly refer past due accounts However the current citywide guideline on billing is approximately nine years old and is no longer applicable under the new SAP Accounts Receivable system Additionally the current citywide protocol does not provide strict enough guidelines on customer billing and past due account referral Consequently as discussed above we found several instances in which City departments referred their delinquent accounts considerably late

This lack of standardization negatively affects the timeliness and accuracy of referrals which ultimately affects an accountrsquos collectability When delinquent accounts are transferred late the best chance to recover the debt has already passed In addition as seen in our December 2009 audit report on the Development Services Departmentrsquos Deposit Accounts an effect of poor billing practices is a large amount of past due debt is not referred to the Program for collection A standardized process which requires all City departments to follow the City Treasurer approved billing practices would ensure that timeliness and accurate referrals occur more consistently To increase standardization and improve inter-departmental communication and cooperation the Program should draft citywide guidelines on billing and collection to replace the current Administrative Regulation

To develop formalize and implement City-wide risk mitigation processes we recommend that the Program take the following action

15 Administrative Regulation (AR) 6330 March 2001 16 ldquo2009 Top Collection Markets Surveyrdquo Commissioned by ACA International ndash The Association of Credit and Collection Professionals

OCA-11-007 Page 14

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 20: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Recommendation 6

The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual

The Delinquent Accounts Program does not have a comprehensive centralized set of policies and procedures or a Program Operations Manual The Programrsquos written policies and procedures are contained in a series of memorandums and training program materials A variety of subjects are addressed such as the Programrsquos Credit Reporting Policy Cancellation of Accounts Referred for Collection and Work in Program (WIP) Lists Memorandum effective dates vary and although core subject areas appear to be addressed the Program staff could benefit from a comprehensive operations manual and centralized set of Program policies and procedures

A comprehensive policy manual containing all procedures processes and policies is an effective tool that maximizes government program operations The State of Washington Department of Revenuersquos Field Compliance Manual is a good example of a comprehensive document which serves as a training tool and reference book for department staff It contains the goals values and mission all policies (eg Conflict of Interest Ethics Confidentiality) all collections procedures (eg contacting by telephone account verification skip tracing) all available collection resources and tools and reference to all applicable laws and regulations (eg credit reporting and other debtor rights)

The Delinquent Accounts Program does have training materials to assist Collectors in using the CUBS system and the Program does have written policies on many key subject matters however the Program has not developed a centralized comprehensive manual As a new policy is implemented Department or Program Management would draft a memo to address the new policy and the memo would be disseminated to Collection Investigators The type and timing of collection efforts (eg calls and letters) are not included in the current written policies procedures or training materials New employees rely on the vast experience of the Collection Supervisors to learn the best practices of collection and primarily get on the job training regarding the tools to use and the timelines to follow

Without a comprehensive operations manual providing a centralized location for all Program policies and procedures vital information could be lost if and when current Program management leaves The Programrsquos continued success could be jeopardized by the loss of knowledge and know-how particularly if the information is not formalized and centralized in a resource available to existing and future Collection Investigators To ensure all Program policies procedures and training materials are understood and adhered to by all staff and to

OCA-11-007 Page 15

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 21: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

provide a comprehensive resource for the Program and the public the Program should establish a comprehensive Program Operations Manual

To develop formalize and implement a standardize collection process we recommend the Program take the following action

Recommendation 7

The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 16

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 22: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Conclusion ldquoAn effective revenue collection program is a major goal of any local government The benefits of an effective program are significant including improved revenue flow more accurate cash forecasting improved cash management and greater budgetary control In order to achieve these objectives the City must be proactive in exploring all opportunities for efficiencies that include streamlining current processes strengthening inter-departmental relationships and establishing efficient policies and procedures to maximize revenue collectionsrdquo17

The management of past due accounts is and should be a small part of the Cityrsquos entire revenue collection process An efficient revenue collection program consists of billing and invoicing properly appropriately accounting for cash receipts managing accounts receivable efficiently and effectively and referring delinquent accounts for collections in a timely manner During 2009 we reviewed the billing and collection practices of several City departments that refer past due accounts to the Program Our review identified problems with the City billing and referral practices In fact we found significant weaknesses in the billing and collection practices of DSD which required immediate reporting Our first report was issued in December 2009 and focused on DSDrsquos Deposit Accounts18

This second and final report focuses on the effectiveness of the Delinquent Accounts Program of the Office of the City Treasurer Our review indicates that the Delinquent Accounts Program achieves good collections results however opportunities exist to improve the collection of past due amounts owed to the City Such opportunities include using third-party collection agency to supplement its in-house collection efforts and publishing the list of top debtors on the Cityrsquos public website

We found that the past due account referral process must be strengthened through standardization and improved inter-departmental communication and coordination One of the most critical factors in the recovery of a past due account is timely and accurate referral A standardized process which requires all City departments to follow Treasurer approved billing practices would help to ensure accurate and timely referrals and would improve the chance of collecting delinquent accounts The Office of the City Treasurer should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures training materials and resources as well as the Programrsquos purpose values and mission

17 ldquoCitywide Guidelines to Maximize Revenue Collectionrdquo City of Los Angeles Office of Finance and Revenue Management Division Citywide Billing and Collection Program June 200918 Performance Audit of the City Treasurerrsquos Delinquent Accounts Program Development Services Department Deposit Accounts issued December 2 2009

OCA-11-007 Page 17

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 23: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Recommendations

To improve the rate of collections of delinquent accounts we recommend that the Delinquent Accounts Program take the following actions

1 The Delinquent Accounts Program should assess the benefit of using a third-party collection agency to supplement its in-house collection efforts and report the results of the assessment to the Chief Financial Officer in order to take the appropriate action (Priority 2)

2 The Delinquent Accounts Program in consultation with the City Attorney should publish a list of top debtors on the Cityrsquos public website and update the list at a set interval such as monthly or quarterly to the extent allowable by law (Priority 2)

3 The Delinquent Accounts Program should actively pursue inclusion in the federal offset program (Priority 3)

4 The Delinquent Accounts Program should determine if additional government databases are accessible including but not limited to State of California Employment Development Department and court bankruptcy records (Priority 3)

5 The Delinquent Accounts Program should assess if there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systems containing customer information such as the customer data within the Water Utilities billing system (Priority 3)

To develop formalize and implement City-wide risk mitigation processes we recommend that the Delinquent Accounts Program take the following action

6 The Delinquent Accounts Program should draft process narratives on billing and collection to replace Administrative Regulation 6330 This newly crafted regulation should standardize the billing and referral of delinquent accounts across City departments and should state that departures from these standards need to be approved by the City Treasurer (Priority 3)

To develop formalize and implement a standardized collection process we recommend the Program take the following action

7 The Delinquent Account Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as well as the Delinquent Account Programrsquos purpose values and mission (Priority 3)

OCA-11-007 Page 18

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 24: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Appendix A ndash Definition of Audit Recommendation Priorities

The Office of the City Auditor maintains a classification scheme applicable to audit recommendations and the appropriate corrective actions as follows

Priority Class19

Description20 Implementation Action21

1 Fraud or serious violations are being committed significant fiscal or equivalent non-fiscal losses are occurring

Immediate

2 A potential for incurring significant fiscal andor equivalent non-fiscal losses exist

Six months

3 Operation or administrative process will be improved Six months to one year

19 The City Auditor is responsible for assigning audit recommendation priority class numbers A recommendation which clearly fits the description for more than one priority class shall be assigned the higher number20 For an audit recommendation to be considered related to a significant fiscal loss it will usually be necessary for an actual loss of $50000 or more to be involved or for a potential loss (including unrealized revenue increases) of $100000 to be involved Equivalent non-fiscal losses would include but not be limited to omission or commission of acts by or on behalf of the City which would be likely to expose the City to adverse criticism in the eyes of its residents 21 The implementation time frame indicated for each priority class is intended as a guideline for establishing implementation target dates While prioritizing recommendations is the responsibility of the City Auditor determining implementation dates is the responsibility of the City Administration

OCA-11-007 Page 19

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 25: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Appendix B ndash Information on the Cityrsquos Past Due Receivables

As of February 2010 past due debt owed to the City for a variety of services provided totaled over $100 million22 There are over 685000 debts that make up the outstanding balance due to the City The largest volume (over 539000 or 79 percent) is parking citations These citations total approximately $46 million or 45 percent of the outstanding balance due Figure 5 below depicts the outstanding debt by type as of February 2010 first by amount then by volume (or count)

Figure 5 ndash Outstanding Debt by Type as of February 2010

Source Auditor analysis of Treasurerrsquos CUBS data Excluding $307 million which would be part of City General

The category type ldquoCity Generalrdquo includes a wide variety of revenue types including referrals from the Police Department Fire Department Development Services Department Park and Recreation Department City Treasurer and other users of the City-wide billing system ARIS Individual debt amounts vary dramatically An analysis of debtors who owe $10000 or more revealed that fewer than 400 debtors (less than 06 percent) owe more than 19 percent of the outstanding balance due or approximately $198 million 23

It should be noted that the collection system CUBS contains accounts that date from the 1992 Debts are not deleted from the system therefore the outstanding debt depicted in this report

22 This total does not include a large Revenue Audit deficiency of $307 million referred in December 2008 related to online travel companies (OTC) and transient occupancy tax Accordingly to the Revenue Audit Division Manager the results of the audit are being disputed and a final determination on the amount due (if any) has not been made This large debt was an unusual referral and skews totals and trends therefore this debt will not be included in Audit Result charts

23 This does not include the OTC debts

Outstanding Debt Dollar Value Percentage by Type

Parking

4 16

City General 30

14 Utilities

Library

Rental Tax 45 Business Tax

Outstanding Debt Volume Count Percentage by Type

4 0 4

City General

Parking

Utilities

Library

Rental Tax

Business Tax 79

7 6

OCA-11-007 Page 20

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 26: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

includes decades of referrals Although there are a variety of statutes of limitation depending on the type of debt which limit the time period the City can pursue litigation there is no time limit to collect the debt via other means Therefore the Program keeps all debts in CUBS regardless of age in hopes of successful collection in the future Consequently total debt outstanding has been increasing steadily over time Figure 6 below depicts the aging of the outstanding debt as of February 2010 after adjusting for the OTC audit deficiency (which would increase the 1 to 3 year category by $307 million) As the chart shows approximately half the outstanding debt is over 5 years old

Figure 6 ndash Aging of Outstanding Debt as of February 2010

$49928186

$19634122 $18109111 $14367816

Less Than 1 Year 1 to 3 Years 3 to 5 Years Over 5 Years

Source Auditor analysis of Treasurerrsquos CUBS data Excluding OTC audit deficiency which would increase the 1 to 3 year category by $307 million

Figure 7 below depicts total outstanding debt (excluding OTC debt) owed to the City as of June 30 for fiscal years 2006 through 2009 It shows that the outstanding debt increased from $73446710 in July 2005 to $96865522 in June 2009 Figure 8 below shows the outstanding debt by month for fiscal years 2006 through 2009

OCA-11-007 Page 21

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 27: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Figure 7 ndash Total Past Due Receivables Owed to the City as of June 30 2006 to 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for fiscal years 2008 and 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

2006 2007 2008 2009

Figure 8 ndash Total Past Due Receivables Owed to the City by month 2006 to 2009

$60000000

$65000000

$70000000

$75000000

$80000000

$85000000

$90000000

$95000000

$100000000

July

Aug

ust

Sept

embe

r

Oct

ober

Nov

embe

r

Dec

embe

r

Janu

ary

Febr

uary

Mar

ch

Apr

il

May

June

2006 2007 2008 2009

Source Auditor generated using CUBS Summary Aging of Outstanding Referrals by Fund by Account Reports Excluding $307 million for the months of December 2008 through June 2009

OCA-11-007 Page 22

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 28: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Appendix C ndash Best Practices and Tools Used by the Program

Industry research showed the Program follows many industry best practices including bull using a centralized in-house team as the primary means of collection bull benchmarking and goal setting and tracking collector performance

using a collections-specific system for tracking and monitoring debts and maximizing automation and use of technology

bull providing a variety of payment options and payment methods bull assigning accounts to specific collectors and maintain reasonable case loads and bull monitoring Program performance through a variety of reports including account aging

Additionally the Program utilizes collection tools available to public sector treasurers such as bull disruption of City service bull credit reporting bull penalties and interest bull skip tracing tools including but not limited to

o access to many City systems containing customer data o subscription services such as Lexis Nexus o access to the Department of Motor Vehicles database o access to the San Diego County fictitious filing database and Assessorrsquos Office

(property) database o access to the State of California Contractors State Licensing Board database and o general internet access

bull partnership with the State of California Franchise Tax Board to intercept State tax refunds and lottery winnings

bull property liens on Rental Unit Tax property bull vehicle impound and bull legal action

If legal action results in a judgment for the City the Program has these additional tools it uses to increase recovery bull intercept rental income on Rental Unit Tax Property bull lien on property owned in San Diego County and bull bank and wage levies

OCA-11-007 Page 23

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 29: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

rlI(llJllI0j l~ UM t~II~J 1Q AI) 1~r JI ~udO~ddl JO~P~IlIlc I pll lUI

9111~4IIpr J I( 1pOJ 1~(jfUnh J)1I(~ p1rgt1)~ J lO~t1IIIlt1 () ooQOOll JO In

I~ n ~ IJ 1 I P 9 I q (In d(J J I J ) u1I (~ ( J I- ( ~ I 1 ( I ~ I 41( ( II (j 1 U 1 l I 1P i1 I Y OJ J ( tJJ

iL AVl I p1Qf I AI )-11~ jQ1(1Il p-J( Id- uf)IlaquoI) l~lP pv1 l~l(~ ~Il plJ~ WprJ

l~I1~lddl 1i1 1J)1 11~ lt~QoJdd IqliJ( I~ I lVdllllp QI )J~O AwGu tlt~ 11(J I(J~

11-1171 II 7JljLl AJJ 11 JO nLJdO U middot)O~lflIOIJJQnA Ijl~f na Af1UI 4 lud Ir1

i NrfJ)d IoIltq J(q~I(~ 11 0 01 lJtJ~ (~ AI~o)1I 1) middotI(Imiddot~JI-( p) Q 11 II~I (1 IPyall IIJO npoundqill ild IIY1 1( 0 fPI([1 v)V 1) 1 1(I~fflt1 NIUVr middotIUulltlJJ 1 yl UlQII1JCJ u middotIUI1JjQIJ 17lt1IUJrIUJbl1middot1J -11 491JVLUIfJ01J~

( IO O~ I~dy q IUIP ulI~I--l)J 1 1 1l

middotU bUIII)lIJ)IQOII)1I l)~)(IMbP ~l J raquo) 1 7~ IW UhnJl1 H IJI bull J i[ I)IIQ Y

IUJIu V (1(] ~l ~i r 1lH~ ~l)~IH IlP~ Jlsectl9( OIJ 1 Iv(lol) y l q~o~ 4) 1middot111 eft J)Hl1 ~

1lltJI70jl91 ~I14-PJ~1 JQ 11Qt(1 f7Yn 11) rlll IQ7)I(J 1 1l~-l~ pV p~j lt) I0Jd

I IJ7TIQi rJf~middotJI lJolthiilpny llt1 u~ 9))1 AQJIIPll o~tllllCf) )1(1 - If I(f1t~ J~ 111 I I b~LUJQjJ1IlI~ ~JiotJ 11J11Q-7-0f 1lllIl-lPG )1( JOy Q J1 11 I nn II (l(fI~IJV)

fI1JJNIJ I)Il )hjO J~l IIOQ DI( ~ ry middot(rdlltlJ-l1gt1J ~I~ 1)1 ( HHjl~~

(( NJf)tdJ )lfIIJ4 0J olJ ) )ftl t( uPV ( I~fyjO I1IllV I~~IJ I~I 01 u)uro rl1 IVI jP

Jlt~J1 1( 1)IIt1 pltJ IJ~Jli J11IIQ 1f)41middot~ tl IJJI-((ill I -A3n QI)((I7 ~Jd~l~1

P jl~(I 11 I)~IJ~ ll1 J)ln P(ttJl(f (JlIJ~oi lIIr J(JUif)I(Q JYL ~ 1~lt pCPIJIII)) tl

NO~I pllUJU~J LJ(J tj Ip f (I Q P~p(ld raquo) f

JJr ldrll ))I~)HI) Jv~Ql(O t-Jl (UOrilfJ f1middotyl ovrJld pllr wIId (lO)r IIjI61I(I(]

JlVgtJll Nt) olor ampgtCcgtnQ a)VfY AJ~J p 0 l)JQltin v I 1LJ1~IltIUGu J~tJ

Ot

O)31 G tJV S 10 j I) 3 H 1

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 30: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

Eduardo Luna City Auditor October 22 2010 Page 2 of3

rdative to specific debts applicable for publication Discussions with the City Anomeys Office will occur by April 302011

Recommendation 3 The Delinquent Accounts Program should active~v pursue inclusion in the federal offet program (Priority 3)

Response Agree with recommendation The Delinquent Accounts Program will obtain mfonnation on program participation and if feasible will seek to implement by the end of the first quarter of Fiscal Year 2012

Recommendation 4 The Delinquent Accounts Program should determine (f additional government databases are accessihle including hut not limited to State of Calffornia Employmenr Development Department alld court hankruptcy records (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this determination by the end of Fiscal Year 2011

Recommendation 5 The Delinquent Accounts Program should assess f there are other City Departments with customer data available that could be used to enhance collection efforts This assessment should ensure the Program has maximized its access to all available City databases and systlms containing customer hfonnation such as the customer data within the Water Utilities hifling system (Priority 3)

Response Agree with the recommendation The Delinquent Accounts Program will make this assessment by the end of Fiscal Year 2011

Recommendation 6 The Delinquent Accounts Program should draft process nUIlaties on billing and collection to replace Administrative Regulation 6330 This newfv crafted regulation should standardize the bifling and referral of delinquent accounts across City departments and should state that departures from these standards need to he approved hy the City Treasurer (Priority 3)

Response Agree with the recommendation The Office of the City Treasurer IS currently reviewing Administrative Regulation 6330 for the purpose of updating procedures and documentation that have become outdated andor replaced by the new SAP Accounts Receivable system Process narratlves will be drafted by the end of the first quarter of Fiscal Year 2012

Recomme[]darioD 7 The Delinquent Accounts Program should establish a comprehensive Program Operations Manual that incorporates all existing policies and procedures newly developed policies procedures training materials and resources as r~ell as tfle Delinquent Accollnt Programs purpose vollies and mission (Priority 3)

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program
Page 31: Performance Audit of City Treasurer’s Delinquent Accounts ... · Transmitted herewith is an audit report on the City Treasurer’s Delinquent Accounts Program. This report is in

EduilrdD LUrlii Ciy Auditor OClcblf 2 20 I 0 Page 30f3

Response Agrct wilh the recommend ation A comprenensive probTarn opcrallOns manual will be developed by the cnd of the first quarter nfFt~cJI Yllsr202

cc Jill M Goldslone Chief Operatin~ Officer MuT) Lewif Chief Financwt Officer Wflly Hii Deputy ChlcfOperatlng Orficer DeaDee Alan Re~nle Ccliec(on Manager Oi8nPl MU1quiz Delinqucnr AccQunts ManagEr Kyle Eser Audir Mzmlger

  • Results in Brief
  • Introduction
  • Background
  • Audit Results
    • The Delinquent Accounts Program Achieves High Rates of Debt Recovery but Additional Collection Tools Can Be Utilized to Further Increase Collections
    • The City Lacks an Authoritative and Effective Invoicing and Referral Policy
    • The Delinquent Accounts Program Needs to Centralize all Policies and Procedures in a Comprehensive Operations Manual
      • Conclusion
      • Recommendations
      • Appendix A ndash Definition of Audit Recommendation Priorities
      • Appendix B ndash Information on the Cityrsquos Past Due Receivables
      • Appendix C ndash Best Practices and Tools Used by the Program