Audit of the Office of Community 


Oriented Policing Services 


2009 COPS Hiring Recovery Program 


Grant Awarded to the 


Paducah Police Department 


Paducah, Kentucky 


Audit Division GR-SO-1S-003 December 2014 

 

 

 

 

 

 

 

 

OFFICE OF COMMUNITY ORIENTED POLICING SERVICES
 

2009 COPS HIRING RECOVERY PROGRAM GRANT AWARDED
 

TO THE PADUCAH POLICE DEPARTMENT
 

PADUCAH, KENTUCKY
 

EXECUTIVE SUMMARY
 

The U.S. Department of Justice Office of the Inspector General, Audit 

Division, has completed an audit of the Office of Community Oriented Policing 

Services (COPS) Hiring Recovery Program (CHRP) grant number 2009-RK-WX-0377 

awarded to the Paducah, Kentucky, Police Department (Paducah PD). This grant, 

which ended on December 31, 2013, provided $607,194 in funding to the 

Paducah PD to hire three sworn officers. The CHRP grants were designed to 

provide funding directly to law enforcement agencies having primary law 

enforcement authority to create and preserve jobs and to increase their community 

policing capacity and crime-prevention efforts. The grants were to provide 

100-percent funding for approved entry-level salaries and fringe benefits for 

3 years for newly hired, full-time sworn officers (including filling existing unfunded 

vacancies), or to rehire officers who had been laid off or were scheduled to be laid 

off on a future date as a result of local budget cuts. According to the 2009 CHRP 

Grant Owner’s Manual, grantees may not reduce the number of their locally funded 

sworn officer positions during the life of the award as a direct result of receiving 

CHRP funding to pay for additional officers. The COPS Office commonly refers to 

this number of locally funded sworn officer positions that grantees must maintain 

throughout the life of the grant as the “baseline.” 

The objectives of the audit were to: (1) determine whether key CHRP grant 

application data were accurate and adequately supported the award in 

consideration of the COPS Office's award methodology, and (2) assess performance 

in the key areas of grant management that are applicable and appropriate for the 

grant under review. These areas included: (1) internal control environment, 

(2) CHRP application statistics, (3) compliance with grant requirements, (4) budget 

management and control, (5) drawdowns, (6) grant expenditures, (7) grant 

reporting, and (8) program performance and accomplishments. 

We found that the Paducah PD’s internal control environment included 

adequate separation of duties and controlled access to accounting systems. We 

also determined that the Paducah PD provided sufficient evidence to demonstrate 

that it maintained the COPS Office’s authorized baseline of sworn officer positions 

during the award period and that it appropriately retained the grant-funded officer 

positions. In addition, we noted that required reports were generally filed in a 

timely manner. As of April 2, 2014, the grantee had drawn down $552,288 of the 

total $607,194 awarded and had recorded expenditures of $552,288 in its grant 

accounting records. 

However, we were unable to fully account for the $54,906 difference between 

the amount awarded and the reimbursed grant costs because the Paducah PD’s 
 

 

 

 

 

 

 

grant accounting records lacked the necessary details. Despite not being able to 

specifically account for the $54,906 difference between the award amount and 

reimbursed grant costs, we identified the primary factors that contributed to the 

difference. First, we determined that although the costs associated with vacation 

and sick leave were incorporated into an officer’s annual salary, the Paducah PD 

separately enumerated vacation and sick leave as fringe benefits in its grant 

application, which were then reflected as authorized fringe benefit costs in the 

COPS Office’s Final Funding Memorandum. Because vacation and sick leave had 

already been factored into an officer’s annual salary amount, these costs were 

duplicated in the award amount because they were also listed separately as fringe 

benefits. Based upon our review of the Paducah PD’s grant records, we determined 

that the Paducah PD did not charge the grant for vacation and sick leave over and 

above salary paid to the officers and that a large portion of the unexpended award 

funds are attributable to this issue. Second, we determined that the Paducah PD 

overstated its estimated Year 3 officer salary rate because this figure was not 

definitively known at the time of the application. Third, we believe that in the later 

years of the grant there may have been instances in which the Paducah PD charged 

the grant for salary rates that were less than the amounts authorized in the COPS 

Office’s Final Funding Memorandum due to changes in grant-funded personnel. The 

Paducah PD has filed its final grant reports and has stated that it has no further 

expenses to be reimbursed. As a result, we recommend that the $54,906 in 

remaining grant funds be de-obligated and that these funds be put to better use. 

Finally, we found that the Paducah PD did not have formal, written 

procedures for ensuring that requests for grant reimbursements were based only 

upon allowable costs, as well as formal, written procedures that the required grant 

reports were accurately prepared and appropriately reviewed prior to submission. 

Our report contains five recommendations to address the preceding issues, 

which are discussed in detail in the Findings and Recommendations section of the 

report. Our audit objectives, scope, and methodology are discussed in Appendix 1. 

ii 
 

 

 

 

 

 

 

 

 

 

AUDIT OF THE
 

OFFICE OF COMMUNITY ORIENTED POLICING SERVICES
 

2009 COPS HIRING RECOVERY PROGRAM GRANT AWARDED
 

TO THE PADUCAH POLICE DEPARTMENT
 

PADUCAH, KENTUCKY
 

TABLE OF CONTENTS
 

INTRODUCTION ...............................................................................1
 

Office of Community Oriented Policing Services .................................1
 

American Recovery and Reinvestment Act ........................................2
 

COPS Hiring Recovery Program........................................................2
 

The City of Paducah, Kentucky ........................................................3
 

Our Audit Approach........................................................................3
 

FINDINGS AND RECOMMENDATIONS.......................................................4
 

Accounting and Internal Control Environment....................................4
 

CHRP Application Statistics .............................................................5
 

Compliance with Grant Requirements ...............................................7
 

Budget Management and Control.....................................................8
 

Drawdowns................................................................................. 10
 

Grant Expenditures ...................................................................... 11
 

Grant Reporting........................................................................... 11
 

Program Performance and Accomplishments ................................... 14
 

View of Responsible Officials ......................................................... 15
 

Recommendations ....................................................................... 15
 

APPENDIX 1: Objectives, Scope, and Methodology ................................. 16
 

APPENDIX 2: Schedule of Dollar-Related Findings .................................. 18
 

APPENDIX 3: Auditee Response to the Draft Audit Report ....................... 19
 

APPENDIX 4: Office of Community Oriented Policing Services
 

Response to the Draft Audit Report................................ 21
 

APPENDIX 5: Office of the Inspector General Analysis and Summary
 

of Actions Necessary to Close the Report........................ 26
 
AUDIT OF THE 


OFFICE OF COMMUNITY ORIENTED POLICING SERVICES 


2009 COPS HIRING RECOVERY PROGRAM GRANT AWARDED 


TO THE PADUCAH POLICE DEPARTMENT 


PADUCAH,KENTUCKY 


INTRODUCTION 


The u.s. Department of Justice Office of t he Inspector General, Audit 

Division, has completed an audit of t he Office of Community Oriented Policing 

Services (COPS Office) Hiring Recovery Program (CHRP) grant number 

2009-RK-WX-0377 awarded to the Paducah, Kentucky, Police Department 

(Paducah PD).! This grant provided $607, 194 in funding to the Paducah PD to hire 

three additional sworn officers. 

Table 1 

CHRP Grant Awarded to the Paducah PO 

GRANT AWARD AWARD AMOUNT 

Total: $607, 194 

The objectives of the audit were to : ( 1) determine whether key CHRP grant 

application data were accurate and adequately supported the award in 

consideration of the COPS Office's award methodology, and (2) assess performance 

in the key areas of grant management that are applicable and appropriate for the 

grant under review. These areas included : ( 1) internal control environment, 

(2) CHRP application statistics, (3) compliance with grant requirements, (4) budget 

management and control, (5) drawdowns, (6) grant expenditures, (7) grant 

reporting, and (8) prog ram performance and accomplishments. 

Office of Community Oriented Policing Services 

The COPS Office assists law enforcement agencies in enhancing public safety 

through the implementation of community policing strategies in jurisdictions of all 

sizes across the country. The COPS Office provides funding to state, local, and 

t riba l law enforcement agencies; U.S. territories and possessions; and other public 

and private entities to hire and train community policing professionals, acquire and 

1 Although the grant was awarded to the Paducah PO, employees from other city departments 

were responsible for grant program administration and fiscal management. For ease of reporting, we 

refer to all of these individuals collectively as the "Paducah PD. " 

2 The award end da te included a no-cost extension granted by the COPS Office. The original 

grant end date was June 30 , 2012 . 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

deploy crime-fighting technologies, and develop and test innovative policing 

strategies. 

American Recovery and Reinvestment Act 

On February 17, 2009, the President signed into law the American Recovery 

and Reinvestment Act of 2009 (Recovery Act). The purposes of the Recovery Act 

were to: (1) preserve and create jobs and promote economic recovery; (2) assist 

those most impacted by the recession; (3) provide investments needed to increase 

economic efficiency by spurring technological advances in science and health; 

(4) invest in transportation, environmental protection, and other infrastructure that 

will provide long term economic benefits; and (5) stabilize state and local 

government budgets in order to minimize and avoid reductions in essential services 

and counterproductive state and local tax increases. 

The Recovery Act provided approximately $4 billion to the Department of 

Justice in grant funding to be used to enhance state, local, and tribal law 

enforcement efforts. Of these funds, $1 billion was provided to the COPS Office for 

grants to state, local, and tribal governments to hire or retain police officers. 

COPS Hiring Recovery Program 

To distribute the Recovery Act money, the COPS Office established the 

COPS Hiring Recovery Program (CHRP), a grant program for the hiring, rehiring, 

and retention of career law enforcement officers. The COPS Office created CHRP to 

provide funding to cover the approved entry-level salaries and benefits for a 3-year 

period for: (1) newly-hired, full-time sworn officer positions; (2) rehired officers 

who had been laid off; or (3) officers who were scheduled to be laid off on a future 

date. The COPS Office received more than 7,000 applications requesting funding 

for approximately 39,000 officer positions. On July 28, 2009, the COPS Office 

announced its selection of 1,046 law enforcement agencies as recipients of the 

$1 billion CHRP funding to hire, rehire, or retain a total of 4,699 officers. The 

grants were competitively awarded based on data submitted by each applicant 

related to fiscal and economic conditions, rates of crime, and community policing 

activities. 

According to the 2009 CHRP Grant Owner’s Manual, funds budgeted to pay 

for sworn officer positions, irrespective of the receipt of CHRP grant funds, may not 

be reallocated to other purposes or refunded as a result of a CHRP grant being 

awarded. Non-federal funds must remain available for and devoted to that 

purpose, with CHRP funds supplementing those non-federal funds. Therefore, grant 

funds must be used to increase the total amount of funds that would otherwise be 

made available for hiring and/or rehiring law enforcement officers (i.e., grantees 

may not reduce the number of their locally funded sworn officer positions during 

the life of the award as a direct result of receiving CHRP funding to pay for 

additional officers). The COPS Office commonly refers to this level of locally funded 

sworn officer positions that the grantees must maintain throughout the life of the 

grant as the baseline. 

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The City of Paducah, Kentucky 

According to the 2010 U.S. Census report, the city of Paducah’s population 

was 25,024. Paducah is the county seat of McCracken County, Kentucky, and is 

located on the southern side of the Ohio River, just past the confluence of the 

Tennessee and Ohio rivers. The stated mission of the Paducah PD is to enhance the 

quality of life in the city of Paducah by working in partnerships with the community 

to fairly enforce the laws, preserve the peace, reduce fear, and provide a safe 

environment for the citizens of and visitors to the city. 

In comparison to its fiscal year (FY) 2008 budget, the city of Paducah’s 

FY 2009 budget of $29,793,740 represented a decrease of $1,424,810, while the 

Paducah PD’s FY 2009 budget increased by $354,160.3 In response to projected 

revenue losses and mandated expenditure increases equal to 10 percent or more, 

the city of Paducah implemented, in April 2009, an operational efficiency plan with 

a stated purpose of proactively reducing expenditures before the city experienced 

a financial crisis. As a result, the city eliminated three unfilled law enforcement 

officer positions in FY 2009, and a fourth position was to be eliminated by attrition 

in FY 2010. The city’s April 2009 CHRP grant application noted its intent to use 

CHRP grant funds to hire three new officers.4 

Our Audit Approach 

We tested compliance with what we consider to be the most important 

conditions of the CHRP grant. The criteria we audited against are contained in the 

2009 CHRP Grant Owner’s Manual, the grant award documents, and relevant Office 

of Management and Budget (OMB) Circulars. In conducting our audit, we 

performed sample testing in the areas of: (1) drawdowns, and (2) grant 

expenditures. In addition, we reviewed the timeliness and accuracy of financial 

activity reports, progress reports, and Recovery Act reports; evaluated performance 

to grant objectives; reviewed internal controls related to the financial management 

system; reviewed the accuracy of information the grantee provided in its grant 

application; and interviewed key Paducah PD personnel. Our audit objectives, 

scope, and methodology are discussed in Appendix 1. 

3 The city of Paducah’s fiscal year end is June 30.
 

4 The fourth position lost through attrition was not filled during the grant period.
 

3
 
 

 

 

 

FINDINGS AND RECOMMENDATIONS 

We found that the Paducah PD’s internal control environment 

included adequate separation of duties and controlled access 

to its accounting system. We also determined that the 

Paducah PD provided sufficient evidence to demonstrate that 

it maintained the COPS Office’s authorized baseline of sworn 

officer positions during the award period and that it 

appropriately retained the grant-funded officer positions after 

the conclusion of the funding period. In addition, we noted 

that required reports were generally filed in a timely manner. 

However, we found several differences between the 

information reported in the Paducah PD’s grant application 

and the supporting data we obtained from various sources. 

Further, largely due to overestimates in its funding 

application, $54,906 remained unreimbursed at the close of 

the grant and could be put to better use if the funds were 

de-obligated. We also found that the Paducah PD did not 

maintain detailed accounting records that reflect individual 

grant-related costs incurred for the entire award period. In 

addition, we found that the Paducah PD did not have written 

procedures to ensure requests for grant reimbursements 

were based only upon allowable costs, as well as to ensure 

required grant reports were accurately prepared and 

appropriately reviewed prior to submission. 

We performed audit work at the city of Paducah municipal building and the 

Paducah PD located in Paducah, Kentucky, where we obtained an understanding of 

the accounting system and reviewed a sample of grant expenditures. We reviewed 

the criteria governing grant activities, including the 2009 CHRP Grant Owner’s 

Manual and relevant OMB Circulars. In addition, we reviewed grant documents, 

including the application, award, budgets, and all required reports. We also 

interviewed key Paducah PD personnel. 

Accounting and Internal Control Environment 

We reviewed the Paducah PD’s financial management system and its 

policies and procedures to assess its risk of non-compliance with laws, regulations, 

guidelines, and terms and conditions of the grant. In addition, to further assess 

risk, we obtained an understanding of the reporting process, examined the 

Paducah PD’s grant-related records and reports, and evaluated the Paducah PD’s 

grant management practices. Moreover, we interviewed key individuals who were 

involved with the grant, including the Chief and Assistant Chief of Police, the grant 

program manager, city finance personnel, and grant-funded law enforcement 

officers. 

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Financial Management System 

The 2009 CHRP Grant Owner’s Manual requires recipients to establish and 

maintain accounting systems and financial records that accurately account for 

funds awarded and disbursed. To comply, grantees must track and report CHRP 

funding separately from other funding sources to ensure accurate financial 

reporting on a timely basis. In addition, these records should contain information 

showing expenditures under the grant and must be supported by items such as 

payroll records, time and attendance records, canceled checks, or similar 

documents. Furthermore, recipients must adequately safeguard grant funds and 

make sure that they are used for authorized purposes only. 

The Paducah PD maintains its accounting records in an automated system. 

Based upon our review of the financial management system and interviews with city 

finance personnel, we found that the Paducah PD’s internal control environment 

included an adequate separation of duties and that access to the accounting system 

was controlled. We also noted that the Paducah PD maintained a separate ledger 

for its CHRP grant activity, and that the ledger tracked expenditures and 

reimbursements associated with the grant. 

Single Audit 

According to OMB Circular A-133, recipients of federal funds are required to 

undergo a single audit if they expend more than $500,000 in federal funds in any 

year. Single audits are to be completed no more than 9 months after the end of 

the entity’s fiscal year. We determined that the city of Paducah, which 

encompasses the Paducah PD, was required to have a single audit performed in 

each fiscal year from 2009 through 2012. 

We reviewed the city of Paducah’s Single Audit Reports for FYs 2009, 2010, 

2011, and 2012. With the exception of the report for FY 2010, the reports did not 

disclose any weaknesses, noncompliance issues, or crosscutting findings related to 

the city of Paducah’s grant management. Although the city of Paducah’s 

independent auditors did not disclose any instances of noncompliance in the 

FY 2010 report, the auditors did identify one significant control deficiency in its 

audit of the city of Paducah’s financial statements. Specifically, the city of 

Paducah’s auditors found that the payroll clerk was responsible for processing 

payroll and transmitting direct deposits to employees. The city of Paducah’s 

auditors recommended that, at a minimum, someone independent of the payroll 

function should review the direct deposit transmissions to validate the employees 

being paid and to check the accuracy of the wages transmitted. During our audit, 

we confirmed that the city of Paducah had implemented the corrective action 

recommended by its auditors. 

CHRP Application Statistics 

To select CHRP grantees, the COPS Office developed a methodology that 

scored and ranked applicants based on data related to their fiscal and economic 

5
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

conditions, rates of crime, and community policing activities. In general, the 

applicants experiencing more fiscal and economic distress, exhibiting higher crime 

rates, and demonstrating well-established community policing plans received 

higher scores and were more likely to receive a grant. While the COPS Office 

performed some limited data validity checks, the COPS Office relied heavily on the 

accuracy of the data submitted by grant applicants. 

In the CHRP Application Guide, the COPS Office reminded applicant agencies 

to provide accurate agency information as this information may be used, along with 

other data collected, to determine funding eligibility. In our May 2010 report of the 

COPS Office’s grant selection process, we found that the validation process used by 

the COPS Office to ensure the accuracy of the crime data submitted by applicants 

was inadequate.5 As a result, some agencies may have received grant funds based 

on inaccurate applications. However, we were unable to determine the number of 

applications that included inaccurate data. 

We requested documentation from the Paducah PD to support the 

information it submitted to the COPS Office in its 2009 CHRP grant application. The 

Paducah PD’s current grant program manager explained that she could not 

substantiate or provide support for the information contained in the application 

because the grant application was prepared by a grant program manager who was 

no longer with the city of Paducah, and that the former grant program manager did 

not leave any documentation to support the contents of the application. As a 

result, we could not fully assess the accuracy of the Paducah PD’s grant application. 

However, we attempted to use other means to test the accuracy of the application, 

including interviewing Paducah PD staff, reviewing city of Paducah Annual Reports, 

and reviewing information reported on federal and state agency websites. 

Through this review, we identified numerous errors in the application that the 

Paducah PD officials could not explain. For example, the grantee underreported the 

total jurisdictional general fund balances and total jurisdictional locally generated 

revenues for FYs 2007, 2008, and 2009, as well as the total jurisdictional operating 

budget figures for FY 2008. The total jurisdictional operating figures for FY 2009 

were overreported. Further, we found that the Paducah PD may have 

misinterpreted the application questions pertaining to reductions in employees 

because the application indicated that a full 100 percent of the Paducah PD’s sworn 

law enforcement positions had been reduced due to official policies. This would be 

a 96-percent overstatement of the reductions because the Paducah PD actually 

experienced a 4-percent reduction by reducing its FY 2009 budgeted sworn level of 

79 by 3 positions. We also determined that many of the crime rate statistics 

reported in the grant application were lower than the number reported in the 

Uniform Crime Report statistics contained on the Federal Bureau of Investigation’s 

website. 

5 U.S. Department of Justice Office of the Inspector General, A Review of the Selection 

Process for the COPS Hiring Recovery Program, Audit Report 10-25 (May 2010). 

6
 
 

 

 

 

 

 

 

 

 

 

 

 

 

Because the application information was used to determine the grantee’s 

eligibility to receive the grant, we examined the effect that the inaccurate data 

submitted in the grant application had on the Paducah PD being awarded this grant. 

Using the COPS Office’s scoring methodology, our analysis showed that the 

Paducah PD would have scored fewer points using the correct data rather than the 

data contained in the original application. However, after applying the COPS 

Office’s methodology and thresholds, it appears that this reduction in points would 

not have affected the Paducah PD’s receipt of the grant. Therefore, we do not 

question the award of the CHRP grant to the Paducah PD. 

Because the data that applicants submit are relied upon to award substantial 

grants, we believe it is vital that grantees ensure that the data and information 

submitted to awarding agencies are accurate. Although in this case we believe the 

Paducah PD’s inaccurate application data did not affect its suitability of receiving 

the award, future inaccurate data may have a substantial effect on award decisions. 

As a result, we recommend that the Paducah PD establish procedures to ensure it 

submits accurate information on future DOJ grant applications. 

Compliance with Grant Requirements 

Excluding the hiring and reporting requirements, no specific performance 

measurements were detailed in the award special conditions. To ensure job growth 

or job preservation, the Recovery Act stipulated that funds from the grant should 

be used to supplement existing funding and not supplant, or replace, funding 

already appropriated for the same purpose. During our audit, we completed an 

analysis of the number of jobs that the Paducah PD preserved with Recovery Act 

funding through the grant by examining the potential for supplanting. 

The Paducah PD’s approved budget for FY 2009 included funding for 

79 full-time sworn officer positions. According to the grant fiscal manager, as of 

February 2009 the Paducah PD had 76 sworn officers on-board, while 3 sworn 

officer positions were vacant. However, as previously discussed, the city of 

Paducah implemented an operational efficiency plan in April 2009 that eliminated 

the three vacant officer positions and indicated that in FY 2010 a fourth officer 

position would be eliminated through attrition. Taking into consideration the 

operational efficiency plan, the budgeted number of locally funded sworn officer 

positions was 76, which was consistent with the figure reported in the grant 

application dated April 10, 2009. The Paducah PD also reported in its grant 

application that it had 76 full-time sworn officers on-board, which was consistent 

with other documentation provided by the Paducah PD. The Paducah PD, in turn, 

requested CHRP funding to hire three new, full-time officers to fill the three vacant 

officer positions that were being eliminated as part of the city of Paducah’s 

operational efficiency plan.6 

6 Although the Paducah PD eliminated a fourth position during FY 2010 (as called for in the 

city of Paducah’s April 2009 operational efficiency plan), we did not include the elimination of this 

position in our calculation of the Paducah PD’s baseline because the position was not factored into the 

grant application, and the elimination of one position from the baseline does not have a significant 

effect on the calculation of the Paducah PD’s allowable vacancy rate. 

7
 
 

 

 

 

 

 

 

 

 

 

 

 

 

We found that the Paducah PD hired three new, full-time officers to fill the 

grant-funded positions. Our testing further revealed that the number of onboard 

officers did not meet the baseline number of locally funded sworn officer positions 

throughout the life of the grant. However, we concluded that these differences 

were a result of normal officer turnover, and that the Paducah PD had made a 

good faith effort to maintain the COPS Office’s approved minimum locally funded 

sworn officer baseline level throughout the entire grant period. According to the 

Chief of Police, although it can take several months to hire new officers, the 

Paducah PD immediately began the hiring process to fill the locally funded 

positions as soon as it was notified that the positions were going to be vacant. 

Retention Planning 

The 2009 CHRP Grant Owner’s Manual states that grantees are required to 

ensure that the increased officer staffing level under the grant will continue for a 

minimum of 12 months after the federal funding ends. Thus, a grantee will have 

met this requirement if the number of its locally funded sworn officer positions is 

above the COPS Office’s established baseline by at least the number of grant-funded 

officers. Paducah PD officials said that they planned to fulfill the retention 

requirement by utilizing the city’s general funds to pay for the grant-funded officer 

positions during the retention period, and that they planned to retain the positions 

beyond the required 12 months. We reviewed the city of Paducah’s adopted budget 

for FY 2014 and found that the amount budgeted for Paducah PD personnel included 

funding for the three grant-funded officer positions. Therefore, after reviewing the 

city of Paducah’s budgets and discussions with city of Paducah officials, we believe 

that the Paducah PD complied with the grant retention requirement. 

Budget Management and Control 

According to the 2009 CHRP Grant Owner’s Manual, a grantee may only be 

reimbursed for the approved cost categories reflected in the Final Funding 

Memorandum, up to the amounts specified in the Financial Clearance Memorandum. 

Moreover, any additional costs above the approved entry-level salaries and fringe 

benefits are the responsibility of the grantee. 

The Paducah PD was awarded $607,194 to pay for the entry-level salary and 

fringe benefit costs of three newly hired officers. Although the Paducah PD adhered 

to the grant requirement to spend grant funds within the approved budget 

categories, we found that the Paducah PD charged the grant for less personnel 

costs overall than were authorized in the COPS Office’s Final Funding Memorandum. 

In total, as of April 2, 2014, the Paducah PD requested reimbursement for 

$552,288 in personnel costs, which is $54,906 less than the award amount, and the 

Paducah PD did not intend to request any further reimbursements. 

We were unable to fully account for the $54,906 difference between the 

amount awarded and the reimbursed grant costs because the Paducah PD’s grant 

accounting records lacked the necessary details. According to the Paducah PD 

8
 
 

 

 

grant fiscal manager, all grant-related expenditures were initially recorded in the 

grant ledger by approved budget category each pay period. However, during the 

quarter that ended June 30, 2011, the grant fiscal manager said that she began to 

consolidate the pay period expenditures by approved budget category and recorded 

them in the grant ledger on a quarterly basis. This process made it difficult to 

determine what the Paducah PD was charging the grant on an officer-by-officer 

basis, and consequently, we were unable to compare those amounts to what was 

authorized in the COPS Office’s Final Funding Memorandum. Despite not being able 

to specifically account for the $54,906 difference between the award amount and 

reimbursed grant costs, we did identify the primary factors that contributed to the 

difference. 

We found that the COPS Office’s Final Funding Memorandum provided 

duplicate funding for vacation and sick leave fringe benefit costs that were already 

included in the base salary amounts. According to Paducah PD officials, officers 

accrue vacation and sick leave throughout the year, and the costs associated with 

vacation and sick leave are incorporated into an officer’s annual salary. 

Nonetheless, when completing its grant application, the Paducah PD included not 

only an officer’s full salary amount, but also listed separate amounts for vacation 

and sick leave in the fringe benefits category. Paducah PD officials stated that the 

application identified vacation and sick leave as separate fringe benefit costs, and 

as a result, the Paducah PD inserted the appropriate information related to the cost 

of these items in its application. Because vacation and sick leave had already been 

factored into an officer’s annual salary amount, these costs should not have also 

been separately itemized as fringe benefits. Based upon our review of the 

Paducah PD’s grant records, we determined that the Paducah PD did not charge the 

grant twice for vacation and sick leave and, therefore, are not questioning any 

costs in this area. However, the vacation and sick leave fringe benefit amounts 

included in the COPS Office’s Final Funding Memorandum represent a significant 

portion of the difference between the grant funds drawn down and the total award 

amount. Because the COPS Office’s Final Funding Memorandum only listed 

itemized fringe benefit costs for the first year of the award, we were unable to 

determine precisely how much of the total award amount was designated for 

vacation and sick leave fringe benefits. However, by using the Year 1 amounts 

allocated for vacation and sick leave fringe benefits and applying those same 

amounts to Years 2 and 3, we estimate that the total amount allotted for vacation 

and sick leave fringe benefits was approximately $43,326. 

We also found that the Paducah PD overstated its estimated Year 3 officer 

salary rate. In the COPS Office’s Final Funding Memorandum, the Paducah PD was 

authorized to claim reimbursement for salary costs of $1,639.50 per officer per pay 

period during the third year of the award period. However, at the time the 

Paducah PD prepared its grant application, including the budget detail worksheet, 

the wage rates for FY 2012 (i.e., Year 3 of the award period) had not yet been 

approved by the city of Paducah. As a result, the Paducah PD estimated the wage 

rate for Year 3 by using the wage rate for an officer with 2 years of experience 

(reflected in the contract between the city of Paducah and the Paducah PD 

Bargaining Unit) and applying an estimated 3-percent cost of living adjustment. 

9
 
 

 

 

 

However, the city of Paducah subsequently approved only a 1-percent cost of living 

adjustment for FY 2012. Therefore, the actual salary costs for Year 3 were only 

$1,608 per officer per pay period rather than the estimated $1,639.50 per officer 

per pay period reflected in the COPS Office’s Final Funding Memorandum. As a 

result, the award amount for salary costs would have been $2,457 less if the 

Paducah PD had known the actual salary costs for Year 3 at the time of submitting 

its grant application. 

Finally, we believe that in the later years of the grant there may have been 

instances in which the Paducah PD charged the grant for salary rates that were less 

than the amounts authorized in the COPS Office’s Final Funding Memorandum. This 

appeared to have occurred when two of the initial grant-funded officers left the 

Paducah PD’s employ, and new officers were hired to replace the original grantfunded officers. At the time these replacement officers were hired, the Paducah PD 

was in Year 2 of the award period. However, the replacement officers’ salaries 

were at the lower entry-level rate, not the salary rates authorized for Year 2 of the 

award period. 

As indicated above, the Paducah PD’s grant financial records did not contain 

sufficient detail for us to directly account for the $54,906 in grant funds that had 

not been drawn down. We believe that the Paducah PD should ensure that it 

maintains detailed accounting records that reflect individual grant-related costs 

incurred. In addition, we believe that the COPS Office should de-obligate the 

$54,906 in grant funds that were not drawn down and put those funds to better 

use. 

Drawdowns 

According to the 2009 CHRP Grant Owner’s Manual, agencies should 

minimize the time between their drawdown of grant funds and their payment of 

grant costs to avoid earning excess interest income on grant funds. We reviewed 

the Paducah PD’s process for requesting reimbursement for its grant-related costs 

to ensure that the requests were adequately supported by official grant accounting 

records and were in accordance with federal requirements. As previously 

mentioned, by the end date of the grant (December 31, 2013), the Paducah PD had 

drawn down $54,906 less than the total award amount of $607,194. 

The Paducah PD grant fiscal manager told us that the Paducah PD requested 

reimbursement of grant funds on a quarterly basis and stated that the amount 

requested for reimbursement equaled the previous quarter’s grant-related payroll 

expenses. This official further told us that the quarterly grant expenditures 

associated with its July 2010 drawdown were incorrect. In addition, the grant fiscal 

manager said that she inadvertently requested reimbursement for the April 2010 

salary and fringe benefit costs twice. The grant fiscal manager said that she 

corrected the grant records and reduced the amount requested in its October 2010 

drawdown. 

10
 
 

 

 

 

 

We compared the quarterly grant-related expenditures as recorded in the 

accounting records to the actual amounts drawn down and did not identify any 

instances in which the amounts drawn down differed from the costs recorded in the 

grant ledger. During this analysis, we also confirmed that the grant records 

associated with the July 2010 drawdown had been adjusted and the subsequent 

(October 2010) drawdown was reduced accordingly. However, as mentioned in the 

Budget Management and Control section of this report, the manner in which the 

Paducah PD maintained its grant accounting records made it difficult to identify 

individual costs charged to the grant and to ensure that those individual amounts 

were consistent with the authorized amounts in the COPS Office’s Final Funding 

Memorandum. As a result, we recommend that the Paducah PD establish written 

procedures to ensure that any future requested grant reimbursements are based 

only upon allowable costs as stipulated by the awarding agency. 

Grant Expenditures 

The 2009 CHRP Grant Owner’s Manual states that funding under this project 

is for the payment of approved full-time entry-level salaries and fringe benefits 

covering a 3-year period (for a total of 36 months of funding) for career law 

enforcement officer positions hired and/or rehired on or after the official grant 

award start date. Additionally, the manual states that the grantee may not use 

CHRP funds for any costs that are not identified as allowable in the COPS Office’s 

Final Funding Memorandum. 

To determine the accuracy and allowability of costs charged to the grant, we 

examined the Paducah PD’s grant transactions. We determined that 100 percent of 

costs billed to the grant were categorized according to approved personnel budget 

categories and were repetitive in nature. By the end date of the grant 

(December 31, 2013), the Paducah PD had recorded a total of $552,288 of grantrelated expenditures in its accounting records, which is consistent with the amount 

of grant funds drawn down. 

We selected two nonconsecutive pay periods for detailed testing to determine 

whether personnel costs were allowable and supported; resulting in a judgmental 

sample of payroll transactions totaling $12,383. In general, we determined that 

the transactions we tested were accurate and allowable. We also found that the 

transactions we tested were adequately supported by timesheets evidencing hours 

worked, properly approved by a supervisor, and properly classified in the grant 

accounting records. 

Grant Reporting 

According to the 2009 CHRP Grant Owner’s Manual, award recipients are 

required to submit financial reports, program progress reports, and Recovery Act 

reports. These reports describe the status of the funds and the project, compare 

actual accomplishments to the objectives, and report other pertinent information. 

We reviewed the Federal Financial Reports (FFR), progress reports, and 

11
 
Recovery Act reports submitted by the Paducah PO to determine whether these 

reports were submitted in a timely and accurate manner. 

Federal Financial Reports 

The 2009 CHRP Grant Owner's Manual requires grantees to submit FFRs no 

later t han 30 days after the end of each quarter. We reviewed the last four FFRs 

submitted during the awa rd period fo r timeliness and accuracy .7 We found t hat 

these four reports were submitted within the required timeframes. However, we 

found that one of these four FFRs did not accurately reflect the grant-related 

expenditures that were recorded in the officia l accounting records, as illustrated in 

Table 2. 

Table 2 

Accuracy of Federal Financial Reports 

FFR P ERIO[} EN[} 

DATE 

Q UARTE RLY EXPEN SES 

PER GRANT l EI>GER EXPEN SES PER FFR D I FFERENCE 

12/ 31/ 2012 $42,078 $42,078 $0 

03/ 31/ 2013 27, 177 64,341 37,164 

06/ 30/ 2013 9,435 9,435 0 

09/ 30/ 2013 0 0 0 

TOTAL $ 78,690 $ 115,8 5 4 $37 , 1 6 4 

Source. , The COPS Office and the Paducah PO s accounting records 

We asked the grant fiscal manager about the difference between the 

expenses reported on the FFR for the quarter ending March 31, 2013, and expenses 

reflected in the accounting records for the same time period . The grant fiscal 

manager said that she did not notice the overstatement until reviewing t he 

cumulative expenditures on the FFR for the quarter ending June 30, 2013. This 

official told us that she contacted t he COPS Office for guidance on correcting the 

FFR. According to the grant fiscal manager, the COPS Office said that it would 

correct the information on t he FFR and would provide the Paducah PO with the 

amended FFR. Based upon the documentation provided by the Paducah PO, the 

FFR for the quarter ending September 30, 2013, was revised to accurately reflect 

the cumulative expenditures, but the FFRs for the quarters ending March 31, 2013, 

and June 30, 2013, continue to inaccurately reflect the cumulative expenditures . 

Because the cumulative expenditures are accurately reflected on the final FFR filed 

(the FFR for the quarter ending September 30, 2013), we are not taking exception 

to the FFRs for the quarters ending March 31, 2013, and June 30, 2013, that 

inaccurately report the cumulative expenditures. However, we believe that t he 

Paduca h PO needs to improve its process for completing FFRs. According to 

7 The grant end date was December 31, 2013. However, the grantee indicated that the FFR 

covering the quarter ending September 30, 2013, was its fina l FFR. In addition, the Padu cah PO 

indicated that the last pay period it expended grant funds was in May 2013. Therefore, we concluded 

that the Paducah PO completed its programmatic responsibilities by September 30,2013. 

12 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Paducah PD officials, the former grant program manager was responsible for 

preparing the FFRs based on the accounting information and drawdown requests 

that were provided by the grant fiscal manager. However, the grant fiscal manager 

said that the process is not formalized or well documented. Because these reports 

are relied upon by the granting agency to monitor the progress of the grant, we 

recommend that the Paducah PD develop and implement procedures to ensure that 

its grant-related financial reports are reviewed and approved prior to submission. 

Program Progress Reports 

According to the 2009 CHRP Grant Owner’s Manual, grantees are required to 

submit progress reports no later than 30 days after the end of each quarter. We 

reviewed the last four progress reports submitted and found the progress reports 

were generally submitted on time. Based on our review, we found that three of the 

four reports were filed in a timely manner, and the report for the quarter ending 

September 30, 2013, was 7 days late. According to Paducah PD officials, the former 

grant program manager was responsible for preparing and submitting the progress 

reports. However, the former grant program manager left the city’s employ shortly 

before the due date of the final report and the Paducah PD did not hire the current 

grant program manager until October 2013. In addition to the vacant grant 

program manager position, Paducah PD officials said that they do not have a 

formalized, written policy regarding the preparation, review, and submission of 

progress reports. We recommend that the Paducah PD develop and implement 

procedures to ensure that its grant-related progress reports are prepared, reviewed, 

and approved prior to submission. 

We also evaluated the accuracy of the four most recently submitted progress 

reports and determined that the information contained in the reports appeared to 

be accurate. The progress reports we reviewed also appeared to be acceptable in 

form and content. With the exception of the final progress report, the reports only 

required the Paducah PD to indicate how many officers were hired, whether the 

officers were new hires or rehires, and the status of any vacant positions. For the 

final progress report, the report required similar hiring information as the previous 

reports, while also requiring information on whether the officers had been retained 

using local funds for a minimum of 12 months following the conclusion of the 

federally funded 36-month period. In addition, the final progress report included a 

section in a survey format that rated a series of program performance statements 

on a scale of 1 to 10. The reports we reviewed were fully completed and appeared 

relevant to the performance of the grant-funded program. 

Recovery Act Reports 

According to the 2009 CHRP Grant Owner’s Manual and the special conditions 

for this CHRP grant, grantees are required to submit Recovery Act reports within 

10 days after the end of each quarter. The report should contain information on 

the award amount, expenditures, and information about all projects utilizing 

Recovery Act monies. 

13
 
 

 

 

 

 

 

 

 

 

We examined the timeliness of the Recovery Act reports submitted by the 

Paducah PD for the previous 2 years. Based on our analysis, the Paducah PD 

submitted each of the quarterly Recovery Act reports for the last 2 years within the 

required 10-day timeframe. 

We also evaluated the accuracy of the five most recently filed Recovery Act 

reports and determined that, with the exception of the most recently filed 

Recovery Act report for the period ending September 30, 2013, the Paducah PD 

incorrectly reflected that it did not have any grant-funded officers employed during 

the reporting periods. According to Paducah PD officials, the former grant program 

manager was responsible for preparing the Recovery Act reports. However, none of 

the current officials responsible for administering the grant knew how the reports 

were prepared, reviewed, or submitted. Further, none of the Paducah PD officials 

associated with the grant during the reporting period had received training on how 

to administer a Recovery Act grant.8 As noted above, we recommend that the 

Paducah PD develop and implement procedures to ensure that its grant-related 

reports are reviewed and approved prior to submission. 

Program Performance and Accomplishments 

The COPS Office established two performance measures for CHRP grants: 

(1) hiring or retaining police officer positions, and (2) enhancing the community 

policing capacity of the police department. To evaluate performance, the 

COPS Office uses quarterly progress reports describing how grantees are using 

CHRP funding to implement their community policing strategies and their progress 

in hiring or rehiring officers. However, the COPS Office does not require grantees 

to document the statistics used to complete questions in the progress reports and 

does not use the grantees’ community policing capacity implementation rating, 

identified in the progress reports, in determining grant compliance. 

We determined that the Paducah PD hired the three officers funded by this 

grant in a timely manner. In addition to analyzing how well the Paducah PD filled 

its CHRP-funded officer positions, we assessed whether the Paducah PD continued 

its community policing efforts during the grant period. 

According to the grant application, the Paducah PD stated that it would 

continue to implement its community policing program and that the grant would 

help the department obtain more community involvement. Through our review of 

the progress reports submitted to the COPS Office, discussions with Paducah PD 

personnel, and our review of documentation provided by the Paducah PD, we 

determined that the Paducah PD continued to engage in and expanded its 

community policing activities during the grant period. 

For example, in its progress reports submitted to the COPS Office the 

Paducah PD reported that the hiring of the three grant-funded officers allowed the 

8 According to Paducah PD officials, the current grant program manager received training on 

administering Recovery Act grants while employed in a previous position with a different organization. 

14
 
 

 

 

 

 

Paducah PD to establish a Traffic Enforcement Unit that reportedly resulted in a 

23-percent reduction in traffic accidents while also combating crime in the city’s 

highest retail sales areas. In addition, the Paducah PD stated that it had been able 

to implement and expand upon an initiative in which it collected and analyzed crime 

statistics, including the frequency of the occurrence of various crimes. By 

determining which types of crime were more likely to occur during different days of 

the week and times of the day, the Paducah PD reported that it was able to deploy 

officers to those locations and at particular times that tended to have higher 

frequencies of crime. The Paducah PD reported that this analysis had reduced 

crime rates and helped the Paducah PD to continue building positive relationships 

with the community by reducing the fear of crime. 

View of Responsible Officials 

We discussed the results of our review with grantee officials throughout the 

audit and at a formal exit conference, and we have included their comments as 

appropriate. 

Recommendations 

We recommend that the COPS Office: 

1.	 Ensure that the Paducah PD establishes written procedures to ensure future 

data submitted on DOJ grant applications is accurate and correct, as well as 

based on appropriate and supported information. 

2.	 Ensure that the Paducah PD maintains detailed accounting records that reflect 

individual grant-related costs incurred. 

3.	 De-obligate the $54,906 in remaining grant funds that were not requested for 

reimbursement by the Paducah PD and put these funds to better use. 

4.	 Ensure that the Paducah PD establishes written procedures to ensure that any 

future requested grant reimbursements are based upon allowable costs as 

stipulated by the awarding agency. 

5.	 Ensure that the Paducah PD establishes written procedures to ensure that its 

grant-related reports are accurately prepared and appropriately reviewed and 

approved prior to submission. 

15
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX 1
 

OBJECTIVES, SCOPE, AND METHODOLOGY 

The objectives of the audit were to: (1) determine whether key CHRP grant 

application data were accurate and adequately supported the award in 

consideration of the COPS Office's award methodology, and (2) assess performance 

in the key areas of grant management that are applicable and appropriate for the 

grant under review. These areas included: (1) internal control environment, 

(2) CHRP application statistics, (3) compliance with grant requirements, (4) budget 

management and control, (5) drawdowns, (6) grant expenditures, (7) grant 

reporting, and (8) program performance and accomplishments. 

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 audited CHRP grant 2009-RK-WX-0377 awarded to the Paducah PD. We 

tested compliance with what we consider to be the most important conditions of the 

CHRP grant. Unless otherwise stated in our report, the criteria we audited against 

are contained in the 2009 CHRP Grant Owner’s Manual, the grant award 

documents, and relevant OMB Circulars. Our audit concentrated on, but was not 

limited to, the inception of the grant on July 1, 2009, through the end of the grant 

period on December 31, 2013. 

In conducting our audit, we reviewed FFRs, progress reports, and 

Recovery Act reports and performed testing of grant expenditures. We also 

reviewed internal controls and procedures for the grant that we audited and 

judgmentally selected a sample of expenditures. A judgmental sampling design 

was applied to obtain broad exposure to numerous facets of the grant reviewed, 

such as dollar amounts, expenditure category, and risk. This non-statistical sample 

design does not allow for projection of the test results to all grant expenditures or 

internal controls and procedures. In total, the grantee had drawn down and 

expended $552,298 in salary and fringe benefits as of April 2, 2014. We selected 

two nonconsecutive pay periods for detailed testing and reviewed $12,383 in 

personnel transactions to determine whether personnel costs were allowable and 

supported. 

We performed limited testing of source documents to determine the accuracy 

of the grant application; assessed the timeliness and accuracy of reimbursement 

requests, FFRs, progress reports, and Recovery Act reports; tested expenditures to 

determine the accuracy and allowability of costs charged to the grant; evaluated 

performance to grant objectives; and reviewed the grant-related internal controls 

over the financial management system. In addition, we reviewed the internal 

controls of the city’s financial management system specific to the management of 

DOJ funds during the award period under review. However, we did not test the 

reliability of the financial management system as a whole. 

16
 
 

The Paducah PD, a component of the city of Paducah, was included in citywide annual audit reports. The results of these audits were reported in the Single 

Audit Reports accompanying the overall audit reports. The Single Audit Reports 

were prepared under the provisions of OMB Circular A-133 and Government 

Auditing Standards issued by the Comptroller General of the United States. We 

reviewed the city of Paducah’s Single Audit Reports for FYs 2009 through 2012 and 

did not identify any findings directly related to DOJ funds. However, we identified 

one instance of a significant control deficiency, which is discussed in the Single 

Audit section of this report. 

17
 
 

 

 

 

APPENDIX 2 

SCHEDULE OF DOLLAR-RELATED FINDINGS 

Description Amount Page 

Funds to Better Use9 

Remaining Grant Funds Not Reimbursed $54,906 

Total Funds to Better Use: $54,906 

Total Dollar-Related Findings $54,906 

 

 8 

9 Funds to Better Use are funds that could be used more efficiently if management took 

actions to implement and complete an audit recommendation, including deobligation of funds from 

programs or operations. 

18
 
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APPENDIX 3
 

AUDITEE RESPONSE TO THE DRAFT AUDIT REPORT
 

19
 

November 18, 2014 

Carnl S. Taraszka " 

Regional Audit Manager 

Chicago Regional Audit Office 

Office of the Inspector General 

US. Department of Justice 

500 W. Madison, Suite l U1 

Chicago, IL 60661 

RE: City of Paducah. Paducah Police OC'partment 

COPS Hiring Recovery Program (CHRP) 

Grant No.: 2009-RK-WX-0377 

Dear Ms. Taraszka: 

The Paducah Police Department is in reccip"t of the draft audit report prepared by the 

Department of Justice (OOJ) for the above referenced project. Based on the recommendations 

provided in the draft audit report, the Paducah Polke Department offers the following 

assurances: 

1. A written procedure will be developed to ensure that future data submitted on DOJ 

grant applications is ae<;urate and correct; furthermore, (Ippropriate supporting 

documentation will be maintained in the project files; 

2. S54,906 in remaining funds that were not requested for reimbursement should be deobligated and put to better use; 

3. A written procedure will be developed to ensure that any future requested grant 

reimbursements are based upon allowable costs as stipulated by the awarding 

agency; and, 

4. A written procedure will be developed to ensure that the Paducah Police 

Department's grant-related reports are acruralo!ly prepared; as wo!ll as, appropriately 

reviewed and approved prior to submission to ooJ. 

In regards to recommendation number two (2) outlined in the draft audit To!port, the 

Paducah Police Department offers the following response: 

Bri3n W. Io.:n/('II"r 

AS$i.lanl Chief of Poh .. ~ 

270·~.\~·Ht'>9l 

Ora ndon L. li,ul1hlll 

Chief of .)Ii.:~ 

2iu·~~"- )(5'}l1 

"la,-c), II . Gnm," 

,\"i "3111 ("h ,.·f " f P"I ic,' 

::!71).-..... . ~~ .. 9 
The City of Paducah disugn."t!s with the statement that uwe were unable to fully 

aCCQunt for the $54}XJ6 difference betwl"t!n the amount awarded and the 

reimbursed grant costs because the Paducah Police Department's grant 

accounting records lacked the n~essary details," The City Finance Department 

maintained extremely detailed records by officer throughout the grant period. 

The City did not draw down all of the grant funds due to actual expenditures 

being less than those outlined on the Final Funding Memorandum. This audit 

report outlined the majority of those reasons induding: duplicate of vacation and 

sick leave in the Final Funding Memorandum, turnover that lead to officets 

being paid at the lower salary rates, and annual salary adjustments being less 

than those projected in the Final Funding Memorandum. According to this audit 

report, these reasons account for $45,783 or 83% of the unused funds. 

Furthennorc, the City believes the rest of the difference was identifiable, and the 

auditor's difficulty in det.:rmining the re.maind(>T was duf' to a portion of the 

quarterly grant draw request being done by hand because of limitations in orn 

software to acconunodate the ceilings on the various categories outlined in the 

Final Funding Memorandum. The City agrees that it was difficult to analyze the 

data easily/quickly, but the records were present and in full detail, by officer for 

the entire grant period. As a result of our own study of the draw amounts verses 

the allowable costs, the city was able to discern where another approximately 

$7,700 was left unutilized. One of the officers during the grant period waived 

health insur(lllCe coverage; therefore, he received the waiver credit of 5250 per 

month. The Final Funding Memorandum allowed for $726/month per officer, 

resulting in over $7,700 in unused health insurance budget funds during his 

employment. When added to the findings of the auditor, approximately 97% of 

the unused funds have been accounted for. In summary, the City believes that 

information n~essary to calculate the unused funds was present and available 

during the audit process. 

The Paducah Police Department appreciates your favorable consideration of its request 

for COPS grant assistance. Should you have any questions, or Tt,'quire additional information, 

please do not hesitate to contact me. 

j)3~"~ BrandonBa~ Chief of Chid 

BB/sdc 

CC: Office of Community Oriented PoliCing Service 

Audra Herndon, CPA, Controller, Cit)' of Paducah 

Sheryl Chino, Grants Administrator, City of Paducah 

20
 
COPS 

ADVANC I NG PU BLI C SAFETY THROUGH COMMUNITY POLI C I NG 

;. 

APPENDIX 4 

OFFICE OF COMMUNITY ORIENTED POLICING SERVICES 

RESPONSE TO THE DRAFT AUDIT REPORT 

21
 

u.s. DEPARTMENT OF J USTICE 

OFFI CE OF COMMUNITY ORIENT ED POLICING SERVICES 

Grant Operations Directorate/Grant Monitoring Division 

145 N Street, N.E., \Vash ington, DC 20530 

MEMORANDUM 

To: Carol S. Taraszka 

Regional Audit Manager 

Chicago Regional Audit Office 

Office of the Inspector General 

From: George Gibmeyer 

Supervisory Grant Monitoring Specialist 

Office of Community Oriented Policing Services 

Grant Monitoring Division 

Audit Liaison Section 

Date: December 12,2014 

Subject: Response to the Draft Audit Report for the City of Paducah, Kentucky 

This memorandum is in response to your November 6, 2014 draft audit report on COPS 

CHRP Grant #2009RKWX0377, awarded to the Paducah, Kentucky, Police Department 

(Paducah PD). For ease of review, each audit recommendation is stated in bold and llllderlined, 

followed by a response from COPS concerning the reconunendation. 

Recommendation 1- Ensure that the Paducah PD establishes written procedures to ensure 

future data submitted on DOJ grant applications is accurate and correct. as well as based 

on appropriate and supported information. 

The COPS Office concurs that procedures should be developed by the grantee to ensure 

that data submitted for future DO] grant applications are verified for accuracy. 

Planned Action 

The COPS Office will work with the grantee to develop appropriate procedures for 

verifying data for fntnre DO.T grant applications 

Request 

Based on the planned action, COPS requests resolution of Reconunendation 1. 
Carol S. Taraszka 

Chicago Regional Audit Office 

Officc of Inspector General 

December 12, 2014 

Page 2 

Ret:mllmendation 2 - J<:nsu re tha t the l'aducah PI) ma inta ins d eta iled au:ounting ret:onls 

that ren t'C.t ind h 'idua l grant_r ela ted '-"fists incurred. 

The COPS Oflice concurs that the grantee should develop procedures to maintain 

detai led accowlting records for each individual grant-related cost incurred. 

Planned Actions 

TIle COPS Office will work with the grantee to develop appropriate procedures to ensure 

accurate and detailed accounting records for each individual grant-related cost incurred. 

Based on the planned action, COPS requests resolution of Recommendation 2. 

Recommendation 3 - De...()bligate the $54,906 in r emaining grant fu nd s that were not 

r eq u ested for reimhu rsem ent h)' the Paducah P I) a nd (lut th ese fund s til hette r use. 

The COPS Oflice concurs that the $54,906 in remaining grrult funds should be deobligated immediately and put to better use. 

Planned Action 

"Ibe COPS Office will dc-obligate the $54,906 in remaining grant funds immediately. 

Based on the planned action, COPS requests resolution of Recommendation 3. 

Recommendation 4 - Ensure that the Paducah I'D establishes written procedures to ensure 

that anv futu re requested graJlt reimbul"scments are based upon allowable costs as 

stipulated hl' the a"'arding a gency_ 

The COPS Oflice concurs that procedures should be developed by the grantee to ensure 

that all grallt reimbursements are based upon allowable costs as stipulated in the grant award and 

as approved on the grrult final fu nding memorruldum. 

Pla n.ned Action 

The COPS Office will work with the grantee to develop appropriate procedures to ensure 

all grant reimbursements arc allowable as stipulated in thc grrult award and as approved on the 

grant fi nal funding mcmorandwn. 

22
 
Carol S. Taraszka 

Chicago Regional Audit Office 

Officc of Inspcctor Gcneral 

December 12, 2014 

Page 3 

Based on the planned action, COPS requests resolution of Recommendation 4. 

R~lmmendation 5 . J<:nsure that Ihe Padueah PI) eslahlishes wrilten pmcedul'l's to ensure 

that its gmnt-rehted repnrts are accurately pl"Cpared anti appropriately re"i"""ed and 

approved prior to submission. 

TIle COPS Office concurs that writtcn procedures should be developed by the grantee for 

ensuring that grant-related reports are prepared accurately, and appropriately reviewed and 

approved prior to submission. 

Planned Action 

Thc COPS Office will work with the grantee to develop wrinen procedures to ensure that 

grant-related reports are prepared accurately, and appropriately reviewed and approved prior to 

submission. 

Request 

Based on the planned action, COPS requests resolution of Reconunendation 5. 

The COPS Office considers Recommendations 1 through 5 resolved, based on the 

plalUled actions shown above. In addition, COPS requests \vritten acceptance of the 

detennination from your otrice. 

The COPS Office would like to thank you for thc opportunity to review and respond to 

the draft audit report. If you have ruJy questions, please contact me at 202· 305-2564 or via email: george.gihmeyer@usdoj.gov. 

cc: Gayle Kaler 

Mayor 

City of Paducah 

Brandon L. Barnhill 

Chief of Police 

City of Paducah Police Department 

Richard P. Theis 

Justice Management Division 

23
 
Carol S. Taraszka 

Chicago Regional Audit Office 

Officc of Inspcctor Gcneral 

December 12, 2014 

Page 4 

Marcia Samuels Campbell 

A~si~tant Director, Grant Monitoring Division/Audit Liai~on 

Grant File : CHRP #2009RKWX0377 

24
 
Carol S. Taraszka 

Chicago Regional Audit Office 

Officc of Inspcctor Gcneral 

December 12, 2014 

Page 5 

OR!: KY07301 

Response to Draft Audit Report for City of Paducah Police Department 

CHRP Grant #2009RKWXO)77 

Reviewed by: 1I.-Ic1onie v. Shi e#...4.,.iVS'~ 

Management Analyst 

Audit Liaison 

Date: December 4, 201 4 

25
 
 

 

 

 

 

 

 

 

 

 

APPENDIX 5
 

OFFICE OF THE INSPECTOR GENERAL
 

ANALYSIS AND SUMMARY OF ACTIONS
 

NECESSARY TO CLOSE THE REPORT
 

The OIG provided a draft of this audit report to the Paducah Police 

Department (Paducah PD) and the U.S. Department of Justice, Office of Community 

Oriented Policing Services (COPS Office). The Paducah PD’s response is 

incorporated in Appendix 3 of this final report, and the COPS Office’s response is 

incorporated as Appendix 4. The following provides the OIG analysis of the 

responses and summary of actions necessary to close the report. 

Analysis of the Responses 

In summary, the COPS Office concurred with each of our recommendations. 

The Paducah PD concurred with Recommendation Numbers 1, 3, 4, and 5, while 

disagreeing with Recommendation Number 2. We address the Paducah PD’s 

specific responses to our draft report, including the one recommendation with 

which it disagrees, under each individual recommendation. 

Recommendation: 

1.	 Ensure that the Paducah PD establishes written procedures to ensure 

future data submitted on DOJ grant applications is accurate and 

correct, as well as based on appropriate and supported information. 

Resolved. Both the Paducah PD and the COPS Office concurred with our 

recommendation. In its response, the Paducah PD stated that it would 

develop written procedures to ensure that future data submitted on DOJ 

grant applications is accurate and correct and that appropriate supporting 

documentation is maintained in the project files. The COPS Office said that it 

will work with the Paducah PD to develop appropriate procedures. 

This recommendation can be closed when we receive a copy of the written, 

implemented procedures that ensure future data submitted on DOJ grant 

applications is accurate and correct, as well as based on appropriate and 

supported information. 

2.	 Ensure that the Paducah PD maintains detailed accounting records 

that reflect individual grant-related costs incurred. 

Resolved. The COPS Office concurred with our recommendation. In its 

response, the COPS Office reported that it will work with the Paducah PD to 

develop appropriate procedures to ensure accurate and detailed accounting 

records for each individual grant-related cost incurred are maintained. 

The Paducah PD disagreed with our recommendation and the statement in 

our report that says “We were unable to fully account for the $54,906 

difference between the amount awarded and the reimbursed grant costs 

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because the Paducah PD’s grant accounting records lacked the necessary 

details.” In its response, the Paducah PD stated that it believes it maintained 

extremely detailed records by officer throughout the grant period. However, 

the Paducah PD acknowledged that its information was difficult to analyze 

because a portion of its quarterly grant drawdown requests were completed 

by hand as a result of limitations in its accounting software. The Paducah PD 

noted that this manual intervention was necessary to accommodate the 

COPS Office’s authorized amounts per budget category. In addition to the 

primary factors contributing to the difference that we cited in our report, the 

Paducah PD stated that it identified approximately $7,700 in additional 

authorized grant funds that were not expended because one officer waived 

health insurance coverage. According to the Paducah PD, when this amount 

is included along with the information in our report, the Paducah PD was able 

to account for 97 percent of the difference between actual expenditures and 

the amounts stipulated in the Final Funding Memorandum. 

While the Paducah PD maintained an accounting system and financial records 

that accounted for grant-related costs incurred, the method in which the 

expenses were recorded made it difficult to compare actual costs to 

authorized costs on an officer-by-officer basis. As noted in our report, this 

difficulty predominantly occurred as a result of the grant fiscal manager 

consolidating the pay period expenditures by approved budget category and 

recording them in the grant ledger on a quarterly basis. For example, the 

grant ledger indicated that the Paducah PD incurred $31,511 in salary costs 

for each officer during the quarter ended March 31, 2012, while each officer’s 

regular salary costs per the payroll records for this time period totaled 

$32,502. Moreover, the Paducah PD was authorized to charge $33,433 in 

salary costs during this same time period. In addition, despite the 

Paducah PD identifying another approximately $7,700 in unexpended funds 

that it states contributed to the difference between the amount awarded and 

the amount expended, the Paducah PD acknowledged that it was unable to 

account for the entire difference. Therefore, we continue to believe that the 

Paducah PD needs to maintain better accounting records that detail the 

individual grant-related costs incurred and that can be easily compared to 

the individual grant-related costs authorized and requested for 

reimbursement. 

This recommendation is resolved based upon the COPS Office’s agreement 

with it. This recommendation can be closed when we receive evidence that 

the Paducah PD has implemented procedures to ensure that it maintains 

detailed accounting records that reflect individual grant-related costs 

incurred. 

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3.	 De-obligate the $54,906 in remaining grant funds that were not 

requested for reimbursement by the Paducah PD and put these funds 

to better use. 

Closed. Both the Paducah PD and the COPS Office concurred with our 

recommendation. Subsequent to the COPS Office’s response to the draft 

report, the COPS Office provided documentation showing that the $54,906 in 

remaining grant funds had been de-obligated. We reviewed the documents 

provided by the COPS Office and determined that the COPS Office’s actions 

adequately address our recommendation. Therefore, this recommendation is 

closed. 

4.	 Ensure that the Paducah PD establishes written procedures to ensure 

that any future requested grant reimbursements are based upon 

allowable costs as stipulated by the awarding agency. 

Resolved. Both the Paducah PD and the COPS Office concurred with our 

recommendation. In its response, the Paducah PD stated that it would 

develop written procedures to ensure that any future requested grant 

reimbursements are based upon allowable costs as stipulated by the 

awarding agency. In its response, the COPS Office said that it will work with 

the Paducah PD to develop appropriate procedures. 

This recommendation can be closed when we receive a copy of the written, 

implemented procedures that ensure any future requested grant 

reimbursements are based only upon allowable costs as stipulated by the 

awarding agency. 

5.	 Ensure that the Paducah PD establishes written procedures to ensure 

that its grant-related reports are accurately prepared and 

appropriately reviewed and approved prior to submission. 

Resolved. Both the Paducah PD and the COPS Office concurred with our 

recommendation. In its response, the Paducah PD reported that it would 

develop written procedures to ensure its grant-related reports are accurately 

prepared and appropriately reviewed and approved prior to submission. In 

its response, the COPS Office said that it will work with the Paducah PD to 

develop appropriate procedures. 

This recommendation can be closed when we receive a copy of the written, 

implemented procedures that ensure that the Paducah PD’s grant-related 

reports are accurately prepared and appropriately reviewed and approved 

prior to submission. 

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The Department of Justice Office of the Inspector General 

(DOJ OIG) is a statutorily created independent entity 

whose mission is to detect and deter waste, fraud, 

abuse, and misconduct in the Department of Justice, and 

to promote economy and efficiency in the Department’s 

operations. Information may be reported to the DOJ 

OIG’s hotline at www.justice.gov/oig/hotline or 

(800) 869-4499. 

Office of the Inspector General 

U.S. Department of Justice 

www.justice.gov/oig