Alderman Patrick Toohey Clarifies Points From Previous Interview

Brentwood Alderman (Ward 4) Patrick Toohey contacted Maplewood-Brentwood Patch to talk about city government, which resulted in an article on Feb. 18.

Toohey sent a clarification of the article to Patch on Monday, asking for it to be published.

He calls his suggested system "the best possible way to demonstrate to residents that the City is functioning efficiently and correctly."

A question raised by the article, from Brentwood resident Jim Pozzo, was "whether it was legal or appropriate for an alderman to talk to the Patch to discuss "possible" recommendations from the closed meetings with the State Auditor's Office?"

Media Director at Missouri State Auditor's Office, Spence Jackson, had no comment on the question. He only said, "Our role is to audit the city. We will be presenting those results in the near future."

Toohey's comments on a monitoring system for Brentwood:

After last week’s interview there were some misconceptions about what I was proposing. Because of this, I wanted clarify my points by adding further detail to the items I mentioned regarding a monitoring system for the city of Brentwood.

I am proposing a controls-based approach which is a much different monitoring plan than what any other Aldermen have proposed. This controls-based approach is not proposing more transparency or transparency as a control. It actually doesn’t directly make any recommendations on transparency.  

In order to establish the controls based approach I am proposing, the City must first construct written narratives for all key city processes (i.e. payroll, bidding, hiring/firing, employee promotions, payables, receivables, financial reporting, etc.). These narratives would document the procedures for key processes and identify all key internal controls and rules that need to be followed.

All key controls from the narratives would then be recorded on a controls matrix (simply a listing of controls and the process they safeguard). Using this controls matrix the city's independent auditors can review the internal control structure as a whole, select a sample of controls to test, and make an opinion as to whether the city has adequate controls in place and that they are working properly.

Currently, the monitoring process I see is other Aldermen doing is putting on a badge, thinking they are the sheriff, contacting city staff at their discretion and reviewing staff's work all the way down to transaction detail until the Alderman becomes comfortable with the transaction. There are three main flaws with this methodology:

1. It doesn't promote the City to create concrete procedures. We currently have too much subjectivity in proper procedure. (How many times at Aldermen meetings are there debates about procedures, let’s get them in writing so the debates end).
2. It is time consuming and the City is not taking care of its regular business at an acceptable pace. The City pays full time professionals to manage the city because managing the city requires full time commitment in order to function at speed required by our residents. The City cannot have the work of these professionals continually slowed down because a part time Alderman wants to review their work and become comfortable with the details. In my opinion the Aldermen should just ensure controls are in place and if something seems fishy to them they should then ask to view the documentation which ensures the control is operating (keep in mind operational effectiveness of this control will be tested by an independent party).
3. This form of monitoring is subject to selection bias. Selection bias is when the monitor of the process has predisposed assumptions about the population being tested and picks a sample of transactions based on those biases. For example, an Alderman doesn't like the Park and Rec director so he/she spends an exorbitant amount of time looking at parks and Rec transactions. On the flip side this same Alderman might be a big fan of the Fire Department so just a few if any fire department transactions are looked at. This is not an acceptable method of sample selection. Additionally, I would like procedures and internal controls that Aldermen have to follow that the external firm would test. If Aldermen are responsible for enforcing internal controls, does anyone really think they are going to test controls that could get them in trouble? 

Having a third party perform controls testing eliminates these problems. The third party will require that the city have written procedures so they can understand city processes and be able to identify key controls.

Professional auditors know how to put together audit plans that allow them to test transactions in order to provide reasonable assurance without slowing down the processes being tested. Using an independent party will eliminate sample bias, as they do not have predisposed assumptions. All transactions governed by the controls will have the same chance of being selected for testing. 

Processes with strong internal controls don't make friends, don't have neighbors, and they are not out to throw others under the bus for their own political gain. They simply state that the procedures need be followed, and these are the documentation standards that need to be followed in order to ensure the procedures are followed.

In my opinion, an internal controls system tested by independent auditors is the best possible way to demonstrate to residents that the City is functioning efficiently and correctly.