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Animal & Control"NYC 11 Park Place Suite 805, ‘New Yor, NY 10007 Fax (212) 341-2089 wrw.nycaceorg Apel, 2015, SyHAND ‘Marjorie Land Deputy Comptrole for Audit (Office of the New York City Comptroller 1.Cenire Street, Room 1100, New York, Wy 10007-2383 IE: Draft Audit Report on Animal Care and Control of New York City Inc's Financial and Operating Practices FMn4-089A\ Dear Deputy Comptroller Landa: ‘This sin response tothe draft Aust Report on Animal Care and Control of New York City, Ines {nancial and operating practice issued by the Office of the Comptroller on March 17, 2035. ‘Attached please find AC&C’s detailed responses in regard to the auditors’ findings and recommendations. Thank you forthe opportunity to provide our comments and input Very truly yours, YQ. [inl dint — Executive Director 2 General Counsel Cewith attachment: Daniel Kass, Deputy Commissioner, Disease Control Sara Packman, Assistant Commissioner, Ault Services Patrick Nolan, Chairman, ARC Board of Directors rine name eT oT) Adopt a Volunteer «Donate Response tothe City of New York Office ofthe Comptroller Financial Avdt/ Aut Reporten ‘Animal Care and Control of New York City Ine’ Financial and Operating Practices ‘AUDIT NUMBER F¥14-099, ‘Animal Care & Control of NYC (ACEC) reviewed the draft audit report prepared by the Office of the Comptroller referenced above, and appreciates the opportunity to respond. The objective of the audit was to determine whether AC&C has adequate contros to ensure proper operations ‘and tnancia aecountabity under its contact withthe Cy of New Yorkin key areas, ncding controled substances; facilty maintenance; insurance coverage; and the recording and reporting of revenue and expenses. The scope ofthe audit generally covered Fiscal Year 2015, but was expanded in certain areas ofthe audit ‘The audit concluded with eighteen recommendations fifteen of whic ae directed to ACEC and three directed tothe NYC Department of Health and Mental Hygiene (DOHMH). The following is [ACEC detailed response tothe ausitors! findings and 25 recommendations specific to ACEC. [As a vendor ofthe Cty and DOHMH, ACR defers to DOHMH to provide its own responses tothe auditors’ three recommendations directed specifically to DOHMH, Lack of Oversight of Controlled Substances ‘The auditors state that ACRC dd not exercise sufclent care over its storage and administration of controlled substances (COS). They found that ACC relies ona single employee to perform several functions related to CDS. The auditors found that although each shelter’ orders contain Independent approvals, the record di not contain evidence of independent checks on the receipt and recording of CDS, or that COS inventory reconciliations were performed. The audors further found that AC&C doesnot use a computerized Inventory system for is controlled substances, as require by its contract withthe city, and instead relies ona manual sytem fr inventory. ‘Auditor’ Recommendation #i: ACEC should ensure thatthe duties of equesting, receiving and recording controlled substances are segregated among different individuals. [ACEC Response: ACEC agrees with ths recommendation and has already begun improving ‘the oversight of controlled substances. ACAC has revised is internal written procedures and process for requesting, ceiving and recordin controled substances in response tothe auditors’ recommendation so that the duties of requesting, ordering receiving and recor 5 are segregated among various positions in the care centers, inluding medical ert, licensed veterinary technicians, veterinarians andthe shelter managers and supervisors, Additionally, upon receipt, veterinarian and shelter manager (or ther designee] must confi receipt of CDS and sign/date such receipt. As an added layer of oversight, reconcliaton of inventory will now be performed and signed by two separate, authorized staf as opposed tc the same person who previously requested, received and reconciled the inventor. ‘Auditor’ Recommendation #2: ACAC should implement a computerized inventory system te accurately account for all controled substances and monitor expiration dates. [ACEC Response: ACRC agrees with this recommendation and is curenthy evaluat software that maintains inventory of medicstion (COS and non-CDS) use, and has already Identified one vendor and scheduled a meeting withthe vendor to discuss inventory control [ACEC will aso work with DOHMH for guidance on best practices and computerized inventory ‘ystems used by thei pharmacies. Until the acquston of such a system, the present manu recordkeeping system shall be utilze but aéded levels of review and oversight have been implemented. The addltions ofa ull tine Medical Director as of 1/2/2015; and more recenty 2 Senior Manager of Veterinary Mecicin (OVI); Lead Veterinarian; Qualty Assurance/Qualty Control Licensed Veterinary Technician (QA/QC LVT}; and a Medical Practice Adminisuator are «aso Intended toad another layer of COS oversight of CDS inventory. ‘Unaccounted for Controlled Substances ‘The auditors stated that ACEC records didnot adequately account for its CDS and noted tha the ending balances in CDS record (tablet and injectable forms) di not reconcile withthe doses administered to animals. During the review period (12/01/13 -03/31/14), the auditors found that 224 out of 257 bottles of injectable CDS usage logs contained irreconcilable disrepancies and some were due to math errors. n toa, the autos found that ACE's usage logs fled to account for 343.2 milters of qui, oF an equivalent of 43 botles. The auditors also noted a

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