Machine-extracted (OCR) from the official document — formatting is approximate; the official copy governs.
2023 REPORT ON INTERNAL CONTROL STRUCTURE AND PROCEDURES
AGENCY ACTION CONTROL STRUCTURE CONTROL PROCEDURE FINDING
Agency Capital Procurement Policy Board Review and Approval
Projects Property Disposition Staff Recommendation Adequate
Policy
Project Review • Statute • Written Application
• Regulation • Cost Benefit Analysis
• By-Laws • Staff Review
• Classes of Projects Policy • Board Attorney Oversight
Adequate
• Local Access Policy • Board Review & Approval
• Conflict of Interest Statement
SEQRA • Statute • Formal EAF Statement
Determination • Regulation • Staff Review
• By-Laws • Attorney Review Adequate
• Classes of Projects Policy • Board Review & Finding
Public Hearing • Statute • Board Approval
• Regulation • Written Minutes
• By-Laws • Report on Public Hearing at Adequate
Board Meeting
• Statute • Written Application
Project Inducement• Regulation • Cost Benefit Analysis
• By-Laws • Staff Review
• Classes of Projects • Board Attorney Oversight Adequate
• UTEP • Board Review & Approval
• Local Access Policy
Benefit Oversight • Statute • Annual Survey of Companies
• Regulation • Staff Review
• Agency Policies • Exec Director Oversight
Adequate
Board Review & Approval of
Annual Reporting
• Board Attorney Oversight
PILOT Benefits • Uniform Tax Exemption • Review of comparable
Oversight Policy properties/ assessment value
• Statute • Review of cost of improvements
• Regulation • Review by School District Adequate
Superintendent, Town
.
Supervisor, Village Mayor, and
the County Executive
• Review by Agency Attorney
• Board Review & Approval
Sales Tax • Statute • Staff Review of project
Exemption • Regulation documents
Oversight • Agency Policy • Attorney Review
• Staff review of ST -60 and
supplemental letter when Adequate
additional agents are appointed
for a project
• Board review and approval
Recapture of • Statute • Annual Survey of projects
Benefits • Regulation • Annual Employment Report
• Agency Policy • Staff Review of reported numbers
• Lease Documents versus application numbers Adequate
• Explanations from Companies
• Board Review & Approval of
Report & Recommendations
Agency Service • Procurement Policy • Review by Staff
Contracts • Funding Policy • Attorney Review
• EPP Policy & Guidelines • Board Review & Approval
• Inducement to Prospects • Formal Contracts for EPP Adequate
Policy • Annual Audit of Expenditures
Agency Fees • Project Fee Policy • Staff Review
• Legal Fee Policy • Board Review & Approval
• Annual Audit Adequate
• Attorney Review
Documents & • Statute • Annual Election of Foil Officer
Administration • Regulation Annual Election of Foil Appeals
Adequate
Foil Policy Officer
Public Comment • Statute • Publication of Hearing Notices
• Regulations • Written Record of Proceedings
• Board By-Laws • Report public comments to the Adequate
• Board for each project
Understanding of• Statute • PAAA Training
Mission, Goals, • Agency By-Laws • New Member Orientation
Adequate
•
Process & Controls Agency Policies • Study Sessions
.
• Annual Acknowledgement of
Responsibilities
• Agency Handbook - Reference
Material for Board
Ethics & Conflict•of Statute • Annual Conflicts
Interests • Conflict of Interest Policy Acknowledgement
Agency Code of Ethics • Annual COI statement
Adequate
Conflict of interest certificate
signed at every meeting
•
Financial Planning Statute • Annual Budget
& Expenditures • Regulation • Annual Audit
• Agency Policies • County Contract for Services
• Procurement Policy • Board Monthly Review of
Finances
Adequate
• Board Approval of Monthly
Payment of Bills
• Signature Authority and Two
Signature for all expenditures
Financial • Statute • Approval of Board of all
Safeguards • Procurement Policy expenditures
• Travel Policy Adequate
•