HomeMy WebLinkAbout- - Responses to Harvey Rose LLC - 10/18/2011CITY COUNCIL AGENDA REPORT
MEETING DATE: OCTOBER 18, 2011
ITEM NUMBER:
SUBJECT: RESPONSES TO FINANCIAL REVIEW CONDUCTED BY HARVEY M. ROSE
ASSOCIATES, LLC
DATE: OCTOBER 11, 2011
FROM: FINANCE DEPARTMENT /FINANCE ADMINISTRATION
PRESENTATION BY: BOBBY YOUNG, FINANCE AND I.T. DIRECTOR
FOR FURTHER INFORMATION CONTACT: BOBBY YOUNG, FINANCE AND I.T. DIRECTOR
(714) 754-5243
RECOMMENDED ACTION
Provide direction to staff regarding analysis of the recommendations made by Harvey M.
Rose Associates, LLC.
BACKGROUND/ANALYSIS
Throughout the month of May, City staff assisted Harvey M. Rose Assoc. (Rose) to
conduct a financial review of the City's financial status as requested by the Orange
County Employees Association (OCEA). On June 21, the City received the full financial
review report provided by Rose. In the report, Rose identifies 10 specific measures the
City could take to tap into additional resources. The following is a list of those items with
the estimated dollar value.
1. $9.2 million - Reduce designation for Working Capital Reserve (General Fund —
Fund Balance)
2. $2.9 million - Eliminate designation for Self Insurance Liability (General Fund — Fund
Balance)
3. $3.5 million - Reduce designation for Compensated Absences (General Fund — Fund
Balance)
4. $0.7 million - Reduce designation for Other Post Employment Benefits (General
Fund — Fund Balance)
5. $4.2 million - Recognize additional FY 2011 fund balance (General Fund — Fund
Balance)
6. $6.2 million - Refund excess Equipment Replacement reserves
7. ($0.8 million) - Buy-out Fire Truck Lease
8. $0.2 million - Eliminate Fire Truck Lease Purchase
9. $0.0 million - Recognize sufficiency of Liability Insurance reserves
10. $0.3 million - Borrow using Pension Obligation Bonds to fund pension UAAL
Before providing responses to each of the items above, staff has made some initial
observations of the financial review.
First, it should be noted that the Comprehensive Annual Financial Statements (CAFR's)
used by Rose had been audited and opined on by Mayer Hoffman McCann (MHM), the
City's contracted auditor, and no material misstatements have occurred. Auditors from
MHM annually perform substantive testing on the accounting records, internal controls,
and accounting procedures of the City's Finance Department. In comparison, the review
performed by Rose was not an audit, but simply a financial review performed using
analytical and trending analysis.
Second, it is the fiduciary responsibility of City Council, City management and City staff to
ensure the financial stability of the City of Costa Mesa. Over many years, our
predecessors have taken an approach of fiscal conservancy and prudent financial
planning to ensure the availability of cash and reserves upon which we operate and count
on today. These cash and reserves allow the City to achieve its highest priority: providing
quality services to the public. Between 2008 and 2010, the recession cut in half the City's
reserves and the unstable economy continues to threaten City revenue. The City of
Costa Mesa's General Fund is made up of 40% sales tax revenue and 20% property tax
revenue while 72% of the expenditure budget is comprised of current and retired
employee salaries and benefits. At a time of uncertainty and diminished reserves, it is
important to remain fiscally conservative and use prudent financial planning to ensure to
continued financial stability.
Staff believes the recommendations/suggestions provided by Rose are not fiscally
conservative and do not use prudent financial planning to ensure the financial stability of
the City of Costa Mesa. As demonstrated in the last paragraph on page 17 of the report
dated June 21, 2011, Rose states that:
"Certainly, if the City moves forward with the use of significant reserves for operations, its
cash position will weaken. Therefore, it is appropriate that the City manage its cash
closely to ensure that it does not have a cash crisis in the future."
Staff believes the 10 items - which Rose states will free up $26.4 million for spending - will
weaken the City's cash position and may dictate a cash crisis in the future. This should
not be a desire of the Costa Mesa community, City Council, City management or City
staff.
Staff has prepared responses to the 10 recommendations presented by Rose to help City
Council and public understand in more detail why some of them should not be considered
viable, while detailing the impacts of taking action on the others.
1. Reduce designation for Working Capital Reserve (General Fund — Fund
Balance) $9.2 million.
Summary: Rose's proposal is that the City reduce its capital reserve from 15% of its
revenue budget to 10%. According to Government Finance Officers Assn.'s best practices
recommendations, Costa Mesa's reserve should be 17%. It wouldn't be prudent to reduce
the capital reserves more than they already have been.
Details: Rose contends that the City's annual Operating Reserve of $14.125 million
(which is established by Costa Mesa Municipal Code Section 2-205) is set at the "high
end of reserve levels recommended by the Government Finance Officers Association
(GFOA)", and approximately $9.2 million could be re -appropriated by the City Council.
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Attached is the Best Practice Recommendation for the Appropriate Level of Unrestricted
Fund Balance in the General Fund (2002 and 2009 — Budget and CAAFR). As seen on
page 2, 1St paragraph, 2nd sentence, GFOA recommends to "maintain unrestricted fund
balance in their general fund no less than two months of regular general fund operating
revenues or regular general fund operating expenditures". Two months of a 12 -month
fiscal year is 17%. At no point does it reference "between 5% and 15%," as stated by
Rose in its review.
It should also be noted on page 1, 6th paragraph the GFOA Recommendation states:
"Those interested primarily in a government's creditworthiness or economic condition are
likely to favor increased levels of fund balance. Opposing pressures often come from
unions, taxpayers and citizen's groups, which may view high levels of fund balance as
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The City's current designation of $14.125 million is 15% of the adopted $94.6 million
revenue budget. Therefore, staff not only believes the current designation is appropriate,
but based on the entire GFOA best recommended practice, the current amount could be
seen as too low.
In previous years, the City had the annual Operating Reserve and also an unreserved
undesignated amount. These two amounts combined helped keep the General Fund's
total undesignated reserve in excess of the GFOA recommendation. However, the City
has used more than $30 million of total fund balance over the last three fiscal years,
which decreased the amount of unreserved undesignated fund balance. At Council
direction, staff has presented Financial and Budget policies that it hopes will increase
future reserve amounts to once again exceed the GFOA minimum recommended
amounts. Therefore, staff would not recommend any portion of the Operating Reserve
(as set forth by Municipal Code) should be made available for appropriation.
2. Eliminate designation for Self Insurance Liability (General Fund — Fund
Balance) $2.9 million.
Summary: Rose proposes that the City eliminate $2.9 million it has reserved in the
General Fund for potential self insurance liabilities. As of June 30, 2010, the City's third -
party claims administrators estimated that the City would potentially need approximately
$10.2 million for outstanding claims. Should the City need to pay those claims, it only had
$7.3 million available in the Self Insurance Fund. Eliminating the $2.9 million from the
General Fund will mean the City will not have reserves if the payouts need to be made.
Details: Rose contends that since the City has established a Self Insurance Fund and the
City pays for costs as they are incurred, the current reserves "are funded at sufficient
levels to ensure solvency through the recession, so this designation is unnecessary."
While the City has established the Self Insurance Fund (separate from the General Fund)
as of June 30, 2010, it did not have enough in reserve to cover the estimated current and
long term liabilities, as calculated by the City's third party claims administrators. If the
City should incur expenses in excess of available cash in the Self Insurance Fund, the
City's General Fund would be responsible for any additional amounts due. Therefore, the
remaining amount necessary is designated in the General Fund to ensure all potential
liabilities could be paid.
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Also, staff believes assuming these funds are available for another use because the
current reserves "are funded at sufficient levels to ensure solvency through the recession"
is not prudent financial planning with the City's best interest in mind. While the economic
future of the City is still uncertain, use of these reserves in the short term may put the City
in a poor financial position in the future. Staff would not recommend any amount is
available for appropriation.
3. Reduce designation for Compensated Absences (General Fund — Fund
Balance) $3.5 million.
Summary: Rose contends that the City does not payout all compensated absences on an
annual basis, therefore it should reduce the amount reserved to pay employees due to
them as of June 30, 2010 from $4.7 million to $1.2 million. Since the current reserve
amount is only 75% of the actual potential liabilities ($6.3 million), it is not recommended
to reduce the current amount reserved.
Details: This compensated -absences designation is to ensure that the City would be able
to pay amounts owed to all employees should they separate from service with the City.
The City does not budget for expected payouts because it does not know when those
separations will occur. Over the course of the fiscal year, the total amount owed to
employees could fluctuate based on activity, resulting in a different amount owed.
Unfortunately, assuming that this money would be paid from budgeted "salary savings
after a position is vacated" (as suggested by Rose) is not always the case and therefore
should not be relied upon as a sound fiscal policy or financial planning approach when a
potential liability exists.
It should be noted that as of June 30, 2010, the total amount of actual compensated
absences for all employees was $6.3 million. In past years, the City designated 100% of
the compensated absences amount. This was seen by staff as prudent financial planning
for a potential liability. The amount designated as of June 30, 2010 was 75% (or $4.7
million) of the actual total because the City did not have available fund balance to meet
the 100% amount and other fund balance designations. Staff believed reducing the
designation to 75% was still providing the City with adequate financial planning. Staff
believes reducing it to 19% (or $1.2 million), as recommended by Rose, would not be
acceptable financial planning, and therefore would not recommend any amount is
available for appropriation.
4. Reduce designation for Other Post Employment Benefits (General Fund — Fund
Balance) $0.7 million.
Summary: Rose contends that since the City funds its current Other Post Employment
Benefits (OPEB) on a pay as you go plan, it should eliminate the designation of the
Annual Required Contribution (ARC). Staff believes if the City was required or chose to
establish an irrevocable trust to fund OPEB obligations, the funds in this designation
would be available for that purpose instead of appropriating for other expenses.
Details: For the City, the OPEB obligation is the retiree health insurance reimbursement
program (Council Policy 300-1). Governmental Accounting Standards Board (GASB)
Statement #43 allows agencies to pay for existing costs "as they go" or establish an
irrevocable trust to fund the future liabilities. This GASB Statement does require the City
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to determine if a liability exists between the ARC and pay-as-you-go plan and record that
liability as if the City had established an irrevocable trust. This requirement is part of
GASBs effort to ensure governmental agencies are bringing potential OPEB liabilities
onto the Government -Wide balance sheet.
To provide the most amount of cash flexibility, especially in uncertain economic times, the
City has continued to pay the actual annual costs instead of prefunding liabilities in an
irrevocable trust. Therefore, Rose is correct that the City does not currently fund the
ARC. However, with this designation, should irrevocable trusts or mandatory funding of
OPEB obligations be required by a federal agency, the Governmental Accounting
Standards Board (GASB) or the City Council in the future, the City would have funds
designated for this purpose. So while this designation is not legally required, staff
believes it is prudent to maintain flexibility of reserves when determining the necessity of
prefunding future OPEB obligations.
5. Recognize additional FY 2011 fund balance (General Fund — Fund Balance) $4.2
million.
Summary: Rose contends that since the average historical budget patterns of revenues
and expenditures (independent of each other) calculate to show a surplus, the City should
have a surplus amount at the end of the 2010-2011 fiscal year that could be appropriated
in FY 2011-12. Unfortunately, simply using historical budget trends is not an accurate
way to calculate a financial surplus in a given fiscal year and therefore should not be
relied upon when establishing a budget in the next fiscal year.
Details: Rose included in its report (Table 2) a five-year historical trend of both budget
and actual revenues and expenditures to determine if the City would have a surplus in FY
10-11. Staff believes this type of analysis is severely flawed. A surplus (or deficit) is
calculated using current year revenues compared to current year expenditures. Using
historical budget to actual amounts has nothing to do with current year amounts.
While Rose agrees with staff's mid -year budget review increase in revenues of $6.8
million, it did not take into consideration (based on information provided by City staff):
- a brightening economy that increased the City's Sales Tax revenue from January 2011
to June 2011 over the amount projected by staff at the January mid -year budget review.
- increases in the Transient Occupancy Tax (TOT) revenue due to hotel occupancy from
January 2011 to June 2011 that exceeded staff's projected amount at the January mid-
year budget review.
These two revenue items alone will more than likely cause the year-end actual revenue
amounts to exceed the mid -year budget estimates.
Using historical information in Table 2 of the report, Rose assumes that since the City's
actual expenditures for FY 08-09 and 09-10 "achieved annual savings" of 3.2% and 4.5%
respectively (when compared to the original adopted budget amount), this trend will
continue and the City should expect at least a 4.4% (or $4.2 million) savings in FY 10-11.
Unfortunately, this analysis in only looking at the expenditure budget to actual results and
not taking into account the actual revenue amount to determine a surplus or deficit.
Based on Table 2, while FY 08-09 and FY 09-10 actual expenditures came in under
budget, when compared to revenues, the City spent $14.6 million and $4.9 million,
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respectively, more than it brought in. Staff does not consider those two fiscal years to
have achieved a "savings."
Staff believes to determine an annual surplus or deficit, revenues and expenditures
should not be considered independently. They should be considered together since it is
the net effect at the end of the fiscal year that will actually determine a surplus or deficit.
That said, after a review of FY 10-11 projected year-end balances for both revenues and
expenditures, it is likely the City will end with approximately a $3 million surplus. This is
because revenue amounts increased with the economy and current year expenditures
decreased with city employees contributing more their pension plans and budgeted
staffing reductions made in July 2010. It is not due to staff's ability/inability to accurately
project the City's annual revenues or expenditures at the time of budget adoption.
Also, analyzing staff's budgetary performance using only the original adopted budgeted
amounts does not provide an accurate representation of the work and adjustments made
by staff during the budget year and are included in the City's fiscal year end
Comprehensive Annual Financial Report (CAFR). The City's annual budget is prepared
almost 15 months in advance of the fiscal year end, which is why staff recommends
adjustments in January (6 months in advance of year end) at the Mid -Year Budget
Review.
6. Refund excess Equipment Replacement Fund (ERF) reserves $6.2 million.
Summary: Rose contends that the City should only reserve an amount necessary for 60
days working capital. In the report, Rose references Federal OMB Circular A-87 as its
source for this contention. With approximately $15 million of assets accounted for in the
ERF, staff does not believe 60 days working capital is a sufficient reserve for vehicle
maintenance and replacement nor does it recommend using any amount for General
Fund purposes at this time.
Details: Fact note - The City does charge the maintenance and replacement costs of two
code enforcement vehicles to the Community Development Block Grant (CDBG), a
federally funded program. The estimated replacement value of these two vehicles
represent 0.35% of the total estimated replacement value of the City's entire fleet.
Office of Management and Budget (OMB) Circular A-87, Attachment C (attached) refers
specifically to "State/Local-wide Central Service Cost Allocation Plans" and does so with
the following overview, "Most governmental units provide certain services, such as motor
pools, computer centers, purchasing, accounting, etc. to operating agencies on a
centralized basis."
The City does not bill federal programs using a cost allocation plan. All costs billed are
for actual costs incurred and not estimated costs of providing the service. This is
especially true for vehicle maintenance services, which charges are "supported by formal
accounting and other records that will support the propriety of the costs assigned to
Federal awards." Thereby any reference to this Circular should not be considered valid in
reference to the Equipment Replacement Fund.
With the general nature of the Circular to encompass all Cost Allocation Plans, staff
believes Rose contention of utilizing the Circular's definition of working capital (up to 60
days cash expenses for normal operating purposes) is very limited and should not be
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used as the general policy for the entire Equipment Replacement Fund. The ERF was
established to record both the maintenance and replacement cost of vehicles. In
reference to the Circular's definition of working capital, staff believes only the
maintenance portion of the fund would be considered the normal operating expenses, not
the replacement portion. The City currently estimates that it has approximately $15
million in total assets to eventually be replaced with an unrestricted reserve of only $6.5
million (as of June 2010). Staff would hope that even the federal government would see a
need for more than 60 days working capital to prudently plan for the eventual replacement
of $15 million worth of assets.
Rose contents that the annual expense net depreciation less a 60 -day working capital
amount dictates a surplus. This analysis does not take into consideration the actual
unrestricted reserve available in the ERF. Based on the FY 10-11 adopted budget, staff
estimated an ending fund balance/unrestricted reserve amount of $5.2 million, but Rose
states $6.2 million could be moved to the General Fund. Which raises the question, how
can the ERF have more in excess reserves than it has in actual unrestricted reserve?
Unfortunately it cannot. The ERF cannot give back to the General Fund more than it has
immediately available.
Given the current value of total assets in the ERF and the unrestricted reserve available,
staff would not recommend any amount is available for General Fund appropriation.
7. Buy-out Fire Truck Lease ($0.8) million.
Summary: Rose contends that the City should pay off the remaining balance on a lease
agreement to purchase a fire truck in the amount of $760,000. In doing so, Rose believes
this will "provide annual General Fund savings of nearly $220,000 in FY 2011-12 through
FY 2015-16." However, since the General Fund is not charged directly for any debt
payments, this would not directly reduce the General Fund budget.
Details: Paying off the fire truck lease agreement early will require the use of cash, which
the Equipment Replacement Fund (ERF) has access to. However, while paying off the
lease agreement will save interest that would otherwise be paid through 2015-16, it will
not reduce the amount of internal rent charges to the General Fund. Staff calculates
internal rent charges based on the cost, useful life, replacement cost of current equipment
and the available cash balance of the Equipment Replacement Fund. It does not directly
take into consideration a lease payment for a vehicle. Therefore, staff estimates no direct
savings to the General Fund in FY 11-12, and since this payment would reduce available
cash, it is likely future rental charges would stay consistent in FY 11-12 or increase.
8. Eliminate Fire Truck Lease Purchase $0.2 million.
Summary: As stated above in #7, the annual internal rent charges are calculated charges
based on the cost, useful life, replacement cost of current equipment and the available
cash balance of the Equipment Replacement Fund. It does not directly take into
consideration a lease payment for a vehicle. Therefore, staff estimates no direct savings
to the General Fund in FY 11-12, and since this payment would reduce available cash, it
is likely future rental charges would stay consistent or increase.
9. Recognize sufficiency of Liability Insurance reserves.
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Summary: Rose contends that the City should eliminate the designation for self
insurance in the General Fund (as stated in #2 above), but—related to the Self Insurance
Fund—acknowledges, "We do not suggest that these reserves be reduced further." Staff
agrees that the Self Insurance Fund reserves should not be reduced.
Details: As of June 30, 2010 the Self Insurance Fund had available cash of $7.3 million
and reported $10.2 million in total liabilities. Therefore, should the City be required to pay
all outstanding liabilities, the difference of $2.9 million would be required to be paid by the
General Fund. Staff agrees with the analysis by Rose, and does not recommend using
any reserves currently established in the Self Insurance Fund. As stated in #2 above,
given this current deficit, staff disagrees with Rose's contention that the City could
eliminate the $2.9 million designation in the General Fund and use it for another purpose.
It should be the City's desire to maintain fiscal stability when potential liabilities exist.
10. Borrow using Pension Obligation Bonds to fund pension UAAL $0.3 million.
Summary: Rose contends that the City should issue Pension Obligation Bonds (POB) for
the advance payment of the unfunded actuarial accrued liability (UAAL) for the Fire Safety
Plan to reduce the annual PERS contribution. While the potential exists, staff does not
recommend anticipating a savings of any amount until further analysis can be completed.
Details: During the City's review of all PERS pension plans with consultant John Bartel,
staff inquired of the logic to issue POBs for the Fire Safety Plan. At the time, Mr. Bartel
did state that the possibility may exist, and likely with only the Fire Safety Plan because
the plan is in a pool and has a "Side Fund." More financial analysis would need to be
completed before determining if and how much of a savings would be generated. Along
with the variables of interest rates and the markets, staff also recommends clearly
defining the future of the Fire Safety Plan before making such an obligation.
With so much analysis to be completed and the uncertainty of the Fire Safety Plan, staff
believes an estimate of any savings in FY 11-12 is presumptuous, and not something the
City could plan on or determine is available for another purpose.
ALTERNATIVES CONSIDERED
Staff has not considered any alternatives at this time.
FISCAL REVIEW
Based on the recommendation action, there is no fiscal impact at this time.
LEGAL REVIEW
A legal review is not required for the recommended action.
CONCLUSION
Recently, the Orange County Employees Association (OCEA) requested a financial review of
the City's financial status to be completed by Harvey M. Rose Associates, LLC. Throughout
the month of May and June 2011, staff provided Rose with all requested documents to
complete the review. On June 21, the City received the final report which included 10 items
that Rose concluded could allow for the appropriation of approximately $26.4 million.
At this time, staff does not recommend taking action on any of the 10 items
recommended by Rose. Staff believes many items are irresponsible and, as stated by
Rose, have the possibility of putting the City into a cash crisis. While noting that the City's
General Fund, Equipment Replacement Fund, and Self Insurance Fund all have reserves,
staff believes those reserves should continue to be guarded until a clear economic
recovery has occurred. It is only with prudent financial planning that the City can balance
its budget and maintain fiscal stability.
BOBBY YOUNG
Finance and I.T. Director
Attachment(s): 1 — GFOA Best Practice "Appropriate Level of Unrestricted Fund
Balance in the General Fund"
2 — Federal Office of Management and Budget (OMB) Circular A-87
3 — Previous Rose report dated September 21, 2004