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UNCLEAR,CONFLICTING,OR DUPLICATIVE REPORTING REQUIREMENTS <br /> rr�► <br /> 1.Constitutional Officer Self-Reporting <br /> As set forth in the provisions of Section 215.89(2)(c), Florida Statutes, "local government" means a municipality, <br /> county,water management district, special district or any other entity created by a local government. Inasmuch <br /> as this definition seems to exclude county constitutional officers from its operation (since they were created by <br /> Article VIIII, Section 1(d) of the Florida Constitution), much debate has occurred in the local government finance <br /> community. <br /> County constitutional officers typically operate independently of the county (primary) government from a <br /> financial management perspective. While county constitutional officers are reported as a part of the primary <br /> government (as that term is defined under generally accepted accounting principles) in the primary <br /> government's financial statements, historically, county constitutional officers have provided financial <br /> information to the county as a part of the "year-end closeout process" at the level of detail necessary for <br /> preparation of financial statements. <br /> Clarification is needed on whether the county constitutional officers will be responsible for independently <br /> reporting their financial information to the State of Florida, or does the state intend to place a conduit reporting <br /> responsibility on the chief financial officer of the county(be it the clerk or other duly created charter officer). In <br /> addition to adding an extra "layer" in the reporting hierarchy, the proposed UCOA monthly reporting <br /> requirement for revenues and expenditures will also place an undue burden on the county chief financial <br /> officers. <br /> `r 2. Double Reporting of Expenditures <br /> As noted above, historically, county constitutional officers have provided financial information to the county as <br /> part of the "year-end closeout process" at the level of detail necessary for preparation of the financial <br /> statements. That information is then utilized by the chief financial officer of the county to prepare "eliminating <br /> entries" on the county's financial statements so that financial transactions between county constitutional <br /> officers are not "double counted." If monthly reporting of revenues and expenditures is implemented by the <br /> state CFO, there will presumably be no opportunity to prepare "eliminating entries" on a monthly basis due to <br /> both cost and time constraints. There is a risk that both revenues and expenditures will be "double counted." <br /> This will occur if, for instance, the board of county commissioners reports a transfer out to a constitutional <br /> officer (as an expenditure), and that particular constitutional officer also reports his/her expenditures by <br /> individual line items. <br /> 6 <br /> 88 <br />