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 «DonateResponse 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