Skip to content
Search Canton

Canton, Massachusetts · Saved source text

FY15 Management Letter

Budgets & Finance · Fiscal year 2015 · Record 8632e12c63674b1a43

Open original municipal record ↗Open interactive reader

Saved text from 8 source pages. Transcription and OCR may contain errors; verify figures and wording against the original. Retrieved 2026-10-15.

Source page 1

TOWN OF CANTON, MASSACHUSETTS

     MANAGEMENT LETTER

    YEAR ENDED JUNE 30, 2015

Source page 2

Table of Contents


Transmittal letter...……………………………………………………. ...................1

Overview .................................................................................................................. .2

Informational Items……………………………………………………………….3 - 5

Findings and Comments……………………………………………………………6

Source page 3

Board of Selectmen
   Town of Canton
   Canton, Massachusetts

   In planning and performing our audit of the financial statements of the governmental
   activities, business-type activities, each major fund, and the aggregate remaining fund
   information of the Town of Canton, Massachusetts, (the “Town”) as of and for the year
   ended June 30, 2015, in accordance with auditing standards generally accepted in the
   United States of America, we considered the Town’s internal control over financial
   reporting (internal control) as a basis for designing our auditing procedures for the
   purpose of expressing our opinions on the financial statements, but not for the purpose of
   expressing an opinion on the effectiveness of the Town’s internal control. Accordingly,
   we do not express an opinion on the effectiveness of the Town’s internal control.

   A deficiency in internal control exists when the design or operation of a control does not
   allow management or employees, in the normal course of performing their assigned
   functions, to prevent or detect and correct misstatements on a timely basis. A material
   weakness is a deficiency, or a combination of deficiencies, in internal control such that
   there is a reasonable possibility that a material misstatement of the entity’s financial
   statements will not be prevented, or detected and corrected on a timely basis.

   Our consideration of internal control over financial reporting was for the limited purpose
   described in the first paragraph of this section and was not designed to identify all
   deficiencies in internal control over financial reporting that might be deficiencies,
   significant deficiencies, or material weaknesses. We did not identify any deficiencies in
   internal control over financial reporting that we consider to be material weaknesses, as
   defined above.

   This communication is intended solely for the information and use of management, the
   Board of Selectman, and others within the organization, and is not intended to be and
   should not be used by anyone other than these specified parties.




   Roselli, Clark & Associates
   Certified Public Accountants
   Woburn, Massachusetts
   November 4, 2015




Town of Canton, Massachusetts                1 of 6                           Management Letter

Source page 4

I. OVERVIEW

       Fiscal year 2015 was another financially positive year for communities in Massachusetts.
       Many experienced increases to their reserve balances as average balances statewide increased
       to approximately 8% of general fund expenditures. In addition, unemployment rates have
       been reduced to pre-recession levels and a favorable mortgage market has bolstered home
       sales which have been robust over the past 2 years.

       The Town ended the year with approximately $11.4 million in unassigned fund balance. This
       represented a $1.6 million increase over the prior year and was the fifth straight year that the
       unassigned fund balanced increased by 10% over the prior year. The increase was primarily
       due to positive budgetary results of $3.4 million and a $0.7 million increase in stabilization
       funds, offset by use of free cash of $2.5 million. In addition, the Town added over $0.5
       million to its OPEB Trust, reflecting its commitment to begin to fund this long-term
       obligation.

       These results exemplified the consistency the Town maintains in managing its reserves. More
       specifically, unassigned fund balances have not been below $5.1 million during any of the
       past 10 years. In doing so the Town has kept a reserve ratio trending over 10% while still
       being able to (1) balance its budget on an annual basis, (2) maintain significant unused levy
       capacity, and (3) attend to its capital needs.

       A common budgetary flexibility test used by the rating bureaus when conducting a credit
       evaluation is called a reserve ratio. The ratio is calculated by adding general fund assigned
       and unassigned fund balances presented in the financial statements and dividing this by the
       general fund expenditures. 15% is considered tier one and 8% - 15% is considered tier two.
       The Town’s ratio is 14.9% which places the Town just shy of tier one and is considered
       healthy. This metric represents 10% of the overall credit profile.

       Other metrics such as the Town’s demographics, proximity to Boston and first class
       Management Team were critical components of the S&P evaluation and decision to rate
       Canton AAA investment grade several years ago. The Town’s consistency and delivery
       since, has allowed the Town to maintain this top investment grade.

       The Town’s bond rating is important. Maximizing the Town’s bond rating, will minimize the
       cost of future borrowing for the Town, and the Town has been successful in this endeavor.

       We are encouraged by this effort and support the Town’s efforts to continue this trend into
       the future. Also, on a positive note, the Town continues to improve upon its internal control
       process; in part this is done through the corrective action suggested through annual
       management letters.

       The remainder of this report is intended to provide the Town and its management with
       recommendations for improvement in accounting and financial operations and informational
       items. The Town should review these recommendations and informational items, and, if
       determined to be cost-effective, implement these improvements.




Town of Canton, Massachusetts                    2 of 6                               Management Letter

Source page 5

II. INFORMATIONAL ITEMS

      Statement on Auditing Standards No. 115 – Audit Communications

      The American Institute of Certified Public Accountants (“AICPA”) recently issued Statement
      on Auditing Standards No. 115, Communicating Internal Control Related Matters Identified in
      an Audit (“SAS 115”). SAS 115 establishes standards and provides guidance on
      communicating matters related to an entity’s internal control over financial reporting identified
      in an audit of financial statements. In particular, SAS 115 provides guidance on evaluating the
      severity of deficiencies in internal control identified in an audit of financial statements in the
      following order:

      1.   Deficiency in internal control
      2.   Significant deficiency
      3.   Material weakness

      Deficiencies identified as significant deficiencies or material weaknesses are required to be
      communicated to those charged with governance. Deficiencies in internal control are not
      required to be communicated; however we have chosen to also report these types of
      deficiencies in this report.

      We did not deem any of the findings in this report to be categorized as either a significant
      deficiency or a material weakness.

      Municipal Data Breaches

      We alerted the Town in the prior year management letter to be aware of network security.
      This information item is being reported again as a reminder to remain vigilant as in the past
      year Massachusetts has seen significant increases in breaches in local networks and related
      thefts.

      The Town has taken a proactive approach to IT security and we recommend that the Town
      continue to place an emphasis on IT security and continually update its IT security procedures.
      An important area of emphasis is training employees in security procedures as often they are
      targeted by outsiders attempting to gain access to the Town’s system’s and sensitive data
      through email, telephone, social media, etc.

      Effect of Adoption of New Accounting Principle - Pensions

      In fiscal year 2015, the Town and virtually all municipalities in the Commonwealth adopted
      new pension accounting standards. The new pension accounting standards required, for the
      first time, that the Town present its portion of the unfunded pension liability owed to its
      current and former employees in the government-wide financial statements. At June 30, 2015,
      the net pension liability for the Town is approximately $39.2 million.

      It is important to note that the new pension accounting standards do not affect the underlying
      regional pension system or its funding schedule. All Massachusetts pension systems are
      required by Massachusetts general law to be fully funded by June 30, 2040. The Norfolk
      County Retirement System, which is the pension system the Town participates in, is currently
      60% funded based on a December 31, 2014 actuarial study and actual pension plan net assets
      as of that date.



Town of Canton, Massachusetts                     3 of 6                              Management Letter

Source page 6

The new pension accounting standards will require that the Town to become a more active
      participant in the audit of the Norfolk County Retirement System. The Town can expect to
      have its retiree and employee census data tested on a rotational basis. It is therefore important
      that the Town promptly provide the requested documentation to the Norfolk County
      Retirement System and its auditors in a timely manner so as to not delay the annual process of
      it and all other employer units of the retirement system.

      New Accounting Principle - OPEB

      The Governmental Accounting Standards Board, or GASB, has issued a new pronouncement
      related to other postemployment benefits, or OPEB, that is substantially similar to the pension
      standard described above. OPEB typically includes health and life insurance plans and other
      similar benefits provided to Town retirees exclusive of pension benefits.

      Currently, the Town reports a net OPEB obligation in its government-wide financial
      statements. However, the proposed new accounting standards will require that the net OPEB
      liability, which can be substantially larger that the net OPEB obligation, be reported in the
      government-wide financial statements. Adoption of this new accounting standard is two years
      away for the Town.

      While this proposed accounting standard will likely materially affect the Town’s government-
      wide financial statements, the Commonwealth has not passed legislation requiring
      municipalities to begin setting aside monies for this unfunded obligation like it has with
      pensions.

      The Town established an OPEB trust fund and has accumulated nearly $1.2 million in assets
      to provide for this liability. Credit rating agencies like Standard and Poor’s Financial Services
      LLC, or S&P, have begun to assign an allocation of the credit evaluation to the management of
      long-term liabilities, which includes OPEB. We recommend that the Town continue its
      commitment to funding this liability to assist in maintaining the Town’s exemplary bond
      rating.

      Changes to Single Audit Requirements

      The Office of Management and Budget, or OMB, raised the threshold for OMB A-133
      compliance audits (i.e., single audits) from $500,000 to $750,000. This new threshold is
      expected to apply to the Town in fiscal year 2016. However, the Town’s federal grant awards
      exceed the new $750,000 threshold so it should continue to require a single audit.

      Also included in the new audit requirements is a requirement that the Town’s internal control
      structure should be in compliance with recognized internal control framework such as the
      Green Book or COSO. At first pass, this requirement doesn’t seem overly complicated.
      However, past experience has shown that seemingly harmless requirements similar to these
      can cause an entity to expend significant time and monetary resources in order to comply.
      Take for instance the Sarbanes-Oxley Act in 2002, which required that a public company’s
      management assess and attest to its internal control system. Public companies of a similar size
      to the Town expended hundreds of hours of resources and tens of thousands of dollars to
      comply with this law and created a cottage industry for accountants and consultants.

      Adopting a formal internal control framework is new to municipalities and will likely require a
      good deal of evaluation, documentation, remediation and ongoing monitoring. We



Town of Canton, Massachusetts                     4 of 6                              Management Letter

Source page 7

recom m end that the Town com m ence this process by taking a com m on sense approach and
tackle the areas in w hich the Town ism ost susceptible to an intemal controldeficiency. 0 ver
a period of tim e, the Town should com plete the fom al adoption of an intemal control

fram ew ork.

The follow ing 17 principles of effective intemal controlw ere extracted from the publication
by the C om m ittee of Sponsoring O rganizations of the T readw ay Comm ission,orCOSO,
Internal Control — Integrated Framework. The entire intemal contol fram ew ork and

im plem entation guides can be found online.

Internal Control Component

Control environment                        1. Demonstrate commitment to integrity and
ethical values

Ensure that board exercises oversight
responsibility

. Establish structures, reporting lines, authorities
and responsibilities

. Demonstrate commitment to a competent
workforce

. Hold people accountable

Risk assessment                               . Specify appropriate objectives
. Identify and analyze risks
. Evaluate fraud risks

. Identify and analyze changes that could
significantly affect internal controls

Control activities                                 . Select and develop control activities that
mitigate risks

. Select and develop technology controls

Deploy control activities through policies and
procedures

Information and communication           . Use relevant, quality information to support the
intemal control function

. Communicate internal control information
intemally

. Communicate internal control information
externally

Monitoring                                        . Perform ongoing or periodic evaluations of
intemal controls (or a combination of the two)

. Communicate internal control deficiencies

Town of Canton, Massachusetts                      5 of 6                                      Management Letter

[Original embedded text, retained for comparison]
recommend that the Town commence this process by taking a common sense approach and
      tackle the areas in which the Town is most susceptible to an internal control deficiency. Over
      a period of time, the Town should complete the formal adoption of an internal control
      framework.

      The following 17 principles of effective internal control were extracted from the publication
      by the Committee of Sponsoring Organizations of the Treadway Commission, or COSO,
      Internal Control – Integrated Framework. The entire internal control framework and
      implementation guides can be found online.




Town of Canton, Massachusetts                    5 of 6                              Management Letter

Source page 8

III. FINDINGS AND RECOMMENDATIONS

      Employee Reimbursement Policy (repeated from prior year)

       In response to prior auditor comments regarding a policy for employee reimbursements, the
       Town drafted a policy for such activity. We understand that this policy has yet to be adopted
       and suggest the Town follow-through with these final steps to help remove any risk
       associated with this activity.

       Planning Board Escrow Deposits (repeated from prior year)

       Prior year audits have highlighted several issues with respect to the Planning Board
       Accounts. These include payment of services when funds are not available and maintaining
       deficit account balances which are the results of a lack of monitoring developers’ available
       balances. While progress is ongoing we noted the same conditions existed during fiscal year
       2015.

       Pre-School and Kindergarten Revolving Funds

       The School Department operates a tuition based pre-school and full-day kindergarten
       program for which it collects annual tuitions of over $150,000 and $400,000, respectively.
       Overall, the School Business Office has developed internal controls that are sufficient to
       account for and safeguard these revenues. We did note that during the year there is a lack of
       communication regarding participants that move out of the program. The program directors
       should notify the Business Office immediately when a student is removed from the program.
       Furthermore, each program director should provide a roster of participants on a quarterly
       basis so that the Business Office can ensure that all participants are properly accounted for.
       We also noted that the Business Office waits until after year-end to reconcile the tuition
       payment records to the Town’s MUNIS general ledger. This reconciliation should occur
       periodically during the fiscal year to resolve any revenue mispostings in a timely manner.

       Building Department

       Revenues for the Building Department are largely from the issuances of building, electrical,
       plumbing and gas permits, which were approximately $1,100,000 for fiscal year 2015. Due
       to the large volume of receipts that are processed through the Department it is imperative that
       strong internal controls are in place and enforced. We sampled ten permits issued by the
       Department during the year and found that the required forms were completed and filed, the
       appropriate fee was calculated and charged, and the payments were deposited timely and
       agreed to the posting in the general ledger. We did note that the Department does not verify
       that the funds turned over agree to what is posted in MUNIS. We recommend that the
       Department reconcile the amounts turned over to the monthly revenue reports distributed by
       the Town Accountant. To facilitate this reconciliation, the Town Accountant may need to
       provide a detail of the monthly activity in addition to the monthly summary reporting.




Town of Canton, Massachusetts                    6 of 6                              Management Letter