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The survey of the Cost of Implementation that the Florida Department of Financial Services has undertaken is not complete as of the writing of this white paper, nor are the results available. However, there are key points to consider regarding the Cost of Implementation. IMPLEMENTATION: In our view, regardless of the approach taken to implement the provisions of Section 215.89, Florida Statutes, significant resources will be required to comply with the proposed UCOA reporting requirements. MODIFYING CURRENT ACCOUNTING SYSTEMS: The first point to be made is that modifying the current accounting system to mirror the proposed UCOA will be labor intensive on the part of the entity's staff. Current accounting systems are set up to meet the needs of the individual entity's management and constituency. The UCOA concept with a goal of transparency does not focus on the individual particular needs of their constituencies. Modifications to mirror the UCOA will put financial burdens on entities and their staffs who are already burdened by budget cuts and staff reductions. A second point, as indicated in the section "UNCLEAR, CONFLICTING, OR DUPLICATIVE REPORTING REQUIREMENTS," is that some entities will perform double work to create the report required by other statutes, which will necessitate reporting on two different formats and entering data twice on a monthly basis, hence doubling the staff time and costs. CREATING A CROSSWALK FROM CURRENT SYSTEMS TO UCOA: Creating a crosswalk from current accounting systems to the UCOA will be costly for several reasons. First and foremost will be software costs. Programming current systems will require the particular vendor to provide programming services to accounting systems that are proprietary in nature and can only be reprogrammed by the vendors themselves. In today's world, programming rates on an hourly basis usually are in the range of$200 to$400 per hour. In addition, most systems would require additional software licensing fees and ongoing monthly maintenance support fees. Once the crosswalk is completed, there will still be the costs of staff time for preparation and reporting as previously expressed elsewhere in this white paper. ONGOING REPORTING: Currently, most entities report annually to Florida Department of Financial Services their AFR through a system known as LOGER. As noted above, the level of reporting for the AFR is at the fund-type level. More specifically, local governments currently report expenditures by fund type (i.e. general, special revenue, debt service, capital outlay, etc.), by function (i.e. 513.00-Financial and Administrative, 521.00- Law Enforcement, 541.00-Road and Street Facilities, etc.) and by major category(i.e. personal services,operating expenditures/expenses, capital outlay,debt service,grants and aids, and other uses). The average time to enter the information annually for a representative county is 1 1/2 to 2 days of staff time. This does not include the time it takes to assimilate the information from the accounting system into the format required for the AFR. It is our understanding that the state CFO will require units of local government to report to the individual fund level, by department and by object code. Reporting by object code versus category is a big issue. It is our estimation that the sheer volume of data to be reported at this expanded level (not to mention the cost of staff to create and verify the information) will grow by more than 100 times, and that is just for the year-end reporting. Interpolating this out on a monthly basis for revenue and expenditure reporting at the comprehensive level of detail requested by the Florida Department of Financial Services realistically could add substantially to this process. Making it a monthly routine will require another staff person. In addition, currently the AFR reporting requires only reporting of revenues and expenditures. The proposed UCOA requires reporting on balance sheet accounts as well, creating even more burden on staff. Another consideration is the impact that monthly financial reporting will have on governmental computer systems and networks. Many governments have a substantial number of funds, some that exceed 100, which will be required to provide reporting. The monthly reporting will require substantial computer resources, which may result in many governments having to upgrade current systems at a substantial cost. The Summary of Reporting Requirements on this website h_t_tp://www.mvfloridacfo.com/aadir/CO/ACOAproiectdocuments/SummaryofReportingRequirments.pdf °`"" 12 94