Interdepartmental Correspondence Sheet

Date: January 29, 2018

To: Harry Black, City Manager

From: Lauren Sundararajan, CFE, Internal Audit Manager

Copies to: Internal Audit Committee

Paul Booth, Human Relations Manager

Subject: Office of Human Relations Audit

Attached is the Office of Human Relations audit report. The primary objectives of this
performance audit were to evaluate the Office of Human Relations internal controls, determine if
established standards have been met, and identify impediments that prevent the organization
from fulfilling its mission. This audit was completed in accordance with Internal Audit’s current
work plan.

We would like to thank management and staff of the Office of Human Relations for their
assistance and cooperation during this audit.

If you need any further information, please contact me.

Attachment
City of Cincinnati
Office of Human Relations Audit

Office of Human Relations Audit

January 2018

Lauren Sundararajan, CFE

Internal Audit Manager

Ann Herzner
Internal Auditor

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Office of Human Relations Audit

Executive Summary 1

I. Introduction 2
Background
Audit Selection
Audit Objective
Audit Scope and Methodology
Statement of Auditing Standards
Commendations

II. Audit Findings and Recommendations 4

III. Conclusion 9

IV. Office of Human Relations Response 10

V. Appendix A – City Ordinance 0397-2015

VI. Appendix B – City Ordinance 0029-2016

City of Cincinnati
Office of Human Relations Audit

Executive Summary

Internal Audit (IA) conducted a performance audit of the Office of Human Relations (OHR). The
audit objective was to evaluate the division’s internal controls, determine if established
standards have been met, and identify any impediments that prevent the organization from
fulfilling its mission.

OHR became a City division in December 2015, after relinquishing its non-profit status as the
Cincinnati Human Relations Commission (CHRC). In June 2017, new leadership was selected
and IA found the office is currently transitioning due to these changes. For example, the office is
in the process of reviewing its mission statement in an attempt to create a more specific focus
for the organization. To assist with this process, the City administration is working with OHR to
align their goals with the needs of the City. Although this transition is taking place, IA identified
areas in current processes that need improvement.

Comprehensive policies and procedures serve as a valuable management tool by assisting

leadership with direction and guidance to staff. IA found OHR’s policy and procedural manual
needs updating. The current manual excludes OHR’s name change and responsibilities as a
City division, and its involvement with the Cincinnati Initiative to Reduce Violence (CIRV)
contract. Updating the policy and procedural manual to reflect operating practices of the
organization is essential in ensuring division goals are met.

Performance measures used by management help gauge an operation’s effectiveness and

efficiency, and highlight areas that need improvement. IA reviewed the performance measures
tracked internally for FY 2017 and found 17 discrepancies in the quarterly reports. Additionally,
IA attempted to verify one of the performance measures and found multiple discrepancies
among those reported and those tracked through an internal spreadsheet. The failure to
accurately report performance measures puts management at risk for making poor decisions
based on inaccurate data.

IA also found there is a lack of management oversight over key processes. Management
oversight must play a vital role in the review of case work and performance measures to avoid
errors and inconsistencies in daily operations.

To ensure OHR is functioning at an optimal level, IA recommends updating the policy and
procedural manual, verifying and accurately tracking performance measures, and increasing
management’s role in the oversight of key processes. If done properly, OHR will better serve its
constituents and the needs of the communities.

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Office of Human Relations Audit

I. Introduction

Background

The history of the Office of Human Relations dates back over 70 years to the creation of the
Mayor’s Friendly Relations Committee (MFRC). The MFRC was created by City Council and
passed by resolution on November 17, 1943. The resolution allowed the Mayor to appoint an
independent committee representing various racial, industrial, religious, and other groups “for
the purpose of studying problems connected with the promotion of harmony and tolerance, and
acting as an advisory committee for the solution of such problems.”1 At the time of creating this
committee, it was the second group to be established in the United States.

The MFRC addressed racial tensions in neighborhoods, parks, schools, businesses, and fair
employment practices throughout the 1950s.2 However, MFRC began looking at the
organization’s format and methods to determine best how to meet the changing needs of the
early 1960s.3 This resulted in an administrative change to the organization with the help of City
Council support.

On March 17, 1965 City Council passed an ordinance to create the Cincinnati Human Relations
Commission. It was to replace the MFRC and be established as an independent 501(c)(3) non-
profit. CHRC’s purpose was to study and investigate problems of relationships between various
religious, racial, and ethnic groups for the purpose [of] fostering mutual respect and
understanding.”4 For nearly 50 years, CHRC addressed these issues in Cincinnati.

On December 16, 2015 City Council passed ordinance 0397-2015 to create the Office of
Human Relations.5 OHR reports to the City Manager’s Office and is administered by a Human
Relations Manager and four full-time staff members. OHR’s primary functions include:
investigating and reviewing complaints against the City or its independent boards and
commissions of alleged discriminations in services, employment practices or personnel policies;
reviewing compliance of non-discrimination provisions of City contracts by contractors doing
business with the City or its independent boards and commissions and; investigating complaints
regarding the impact of relocation for neighborhood residents and urban development for
diverse populations.6

1 Cincinnati Human Relations Commission (CHRC) Personnel Policies and Procedures Manual, April 2010, p. 5.
2 Obermiller, Phillip J., and Thomas E. Wagner. The Cincinnati Human Relations Commission A History, 1943 – 2013
(Athens: Ohio University Press, 2017), 15.
3 Obermiller and Wagner. The Cincinnati Human Relations Commission A History, 1943 – 2013, 15.
4 CHRC Personnel Policies and Procedures Manual, p. 5.
5
See Appendix A – Council Ordinance 0397-2015
6 See Appendix B – Council Ordinance 0029-2016

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Office of Human Relations Audit

Audit Selection
IA conducted this audit in accordance with the current work plan.

Audit Objective
Evaluate the Office of Human Relations internal controls, determine if established standards
have been met, and identify impediments that prevent the organization from fulfilling its mission.

Audit Scope and Methodology

To accomplish the objective of this audit, IA interviewed relevant staff members, analyzed data,
examined reports, reviewed excel spreadsheets, and all applicable policies and procedures.
Records reviewed included data generated in FY 2016, FY 2017, and FY 2018.

Statement of Auditing Standards

As required by Article II, Section 15 of the City of Cincinnati Administrative Code, this audit was
conducted in accordance with the Generally Accepted Government Auditing Standards
(GAGAS), except for standard 3.96 pertaining to external peer review requirements. This
exception did not have a material effect on the audit.

IA continues to conduct internal quality reviews to assure the conformance with applicable
GAGAS. IA performed fieldwork between October 2017 and November 2017.

Commendations
IA commends the Office of Human Relations staff for their cooperation throughout the audit.

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Office of Human Relations Audit

II. Audit Findings and Recommendations

The audit report is outlined in three areas: policies and procedures, performance measures and
case work, and management operations. The risks associated with each area are discussed
below.

Policies and Procedures

OHR's policy and procedural manual needs updating.

Updated comprehensive policies and procedures are essential to every organization. They
provide the framework and guidance needed for staff to support the organization’s goals and
allow management to hold employees accountable. IA found that the current policy and
procedural manual needs updating.

For example, the current manual addresses the organization by its former name, Cincinnati
Human Relations Commission and its status as an independent 501(c)(3) non-profit agency. In
2015, CHRC became a City division and revoked its non-profit status. Updating the division’s
policies and procedural manual to reflect this change is important to ensure that the office’s
goals and objectives align with City policies. Additionally, this step is critical to managing internal
operations and key processes within the organization.

Another example is the manual does not address OHR's involvement with the Cincinnati
Initiative to Reduce Violence. CIRV is a multi-agency and community collaborative effort
initiated in 2007 to reduce gun-violence and homicides in the City. Community Outreach
Advocates (COA's) are part of the CIRV initiative and help by engaging gang members to stop
violence and make positive changes in their lives.

The COA's are contracted by the City through the Urban League of Southwestern Ohio contract.
OHR is responsible for providing administrative support to the COA’s because they oversee the
terms of the contract with other City officials. OHR’s administrative duties include processing
timesheets and reimbursement checks for the COA’s. Updating the policy and procedural
manual to reflect these administrative duties is essential for holding employees accountable and
abiding by contract guidelines.

Recommendation 1: Update OHR's policy and procedural manual to reflect current operations.

Department Response: Agree. OHR will update policy and procedural manual in the next six
months.

There are no policies and documented procedures governing the constituent case process.

To keep track of the cases OHR receives, the office uses an excel spreadsheet to track
pertinent information from each case. This includes client name, date, incident details,
individuals involved, contacts and results. IA obtained a copy of the spreadsheet7 and
categorized the issues into a graph to show a summary of the cases worked over an 18-month
period.

7 Data collected is from May 2016 to November 2017. IA received a copy of the spreadsheet on November 27, 2017.

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Office of Human Relations Audit

OHR Client Log

15% 3%
27%

6% 21%

28%

Discrimination & Hate Crime Health Services

Housing Neighborhood & Crime
Nonjurisdiction Other

When an allegation is reported, the information received goes through a process. The first step
is to complete an incident form, which asks for specific details about the nature of the event or
incident. This form may be filled out by the constituent, if they come into the office, or by a staff
member if the person calls by phone. Next, a staff member will primarily review the information
to determine if the allegation or concern is something OHR is able to assist. If OHR is able to
offer assistance, one of two staff members will take the case and work with the individual to
resolve the issue. This is done by listening to their concern or allegation, and then offering OHR
assistance, if applicable. Once the issue is resolved, the form is filed internally along with any
notes taken during the process. Additionally, pertinent information collected during the process
is entered into the excel spreadsheet.

After careful review of this procedure, IA found there is no policy that governs the constituent
case process and there are no documented procedures. IA reviewed the data collected from the
spreadsheet and found 33 people reported allegations to OHR between May 2016 and
November 2017. Of the 33 people listed, 14 (42%) did not have incident sheets completed, and
8 (24%) did not have any supporting documentation on file to reflect OHR assisted them.
Additionally, IA found the spreadsheet did not contain the name of the staff member assigned to
the case and the date the case was resolved. Therefore, IA was unable to accurately test the
timeliness and efficiency of resolving these cases.

The failure to create comprehensive policies that mandate the completion of internal forms,
establishes case deadlines, and compiles case notes onto the spreadsheet is critical to the
success of the operation. Additionally, documented procedures are necessary to provide proper
instruction to employees on how to follow policies and avoid errors in the process.

Recommendation 2: Create policies and document procedures used to govern the constituent
case process. This includes creating standards for completing paperwork, entering case notes
and the employee assigned into the spreadsheet, and establishing case deadlines.

Department Response: Agree. Constituent case process will be revised accordingly.

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Office of Human Relations Audit

Tracking of Case Work and Performance Measures

The alleged hate crime & bias incident spreadsheet does not track the services offered by OHR
in response to incidents reported.

OHR created the alleged bias incident spreadsheet to track alleged hate crimes occurring
around the Greater Cincinnati area. The spreadsheet documents the alleged incident, date,
location, classification of crime (hate or bias), population affected, outcome, whether the
information was reported to the City Manager, and source of information. Since the
spreadsheet's inception of September 2016, 34 alleged hate crimes have been tracked by OHR.

After careful review of the information collected, IA found that the spreadsheet does not
document the methods used or the actions taken when OHR responds to alleged incidents of
hate crimes. The failure to document the steps or methods used to show how OHR’s responds
to incidents of alleged hate or bias crimes on the spreadsheet makes it difficult to measure
performance and calculate the impact OHR has in the communities.

Recommendation 3: Document the methods used and actions taken in the alleged hate crimes
& bias incidents spreadsheet when OHR responds to incidents around the region.

Department Response: Agree. This is a new project and evolving process for OHR We are
working toward a goal of documenting, categorizing data how when appropriate to respond to
bias incidents.

The performance measures tracked internally are inaccurate.

Management uses performance measures to gauge an operation’s effectiveness and efficiency.

They align with division goals and objectives, and can highlight specific areas that need
improvement. One way OHR tracks performance internally is through use of quarterly reports.
Each report accounts for OHR’s level of outreach and engagement, citizen training, and public
relations and marketing.

IA reviewed the quarterly reports from FY 2017 and found 17 discrepancies. For example, in the
first and second quarterly reports, it states OHR staff will attend 25 community council meetings
in the City’s neighborhoods throughout the fiscal year. The numbers reported for first quarter
was 10 and the second quarter was 6, respectively. However, during the third and fourth quarter
reports, the numbers previously reported under the first and second quarters changed to 0.

Another example of a discrepancy found in the FY 2017 reports was the distribution of 12
newsletters. In the first and second quarter reports, they reflect 3 newsletters were issued per
quarter. However, the third quarter report reflects 4 newsletters were issued during the first,
second, and third quarters and the fourth quarter report reflects 3 newsletters were issued
during the first, second, third, and fourth quarters of the fiscal year. These discrepancies make it
difficult to gauge what services are actually being performed by the organization.

Additionally, IA attempted to verify the data reported under the community engagement
performance measure because it most closely aligns with the ordinance 0397-2015, which
established the office. Community engagement, as defined by OHR’s quarterly report, is
individuals requesting resolution to conflicts, ethnic intimidation and/or groups willing to meet
with OHR staff to discuss their concerns.

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Office of Human Relations Audit

IA reviewed the performance measures listed in all the quarterly reports for FY 2017, first
quarter FY 2018 and compared the data tracked in the OHR Client Assistance Log. IA found
multiple discrepancies between the numbers reported versus the actual numbers tracked in the
spreadsheet. The chart below reflects those discrepancies.

Quarterly Reports Reported Performance Attainment of Performance

Measure Measure
(Internal Quarterly Reports) (OHR Client Assistance Log)

1st Qtr. 2016 – 2017 15*/30** 1

(7/1/2016 – 9/30/2016)
2nd Qtr. 2016 – 2017 18*/35** 3
(10/1/2016 – 12/31/2016)
3rd Qtr. 2016 – 2017 44 9
(1/1/2017 – 3/31/2017)
4th Qtr. 2016 – 2017 16 13
(4/1/2017 – 6/30/2017)
1st Qtr. 2017 – 2018 30 5
(7/1/2017 – 9/30/2017)
*This number changed in the third quarter report.
**This is the new number reported in the third and fourth quarter reports.

When IA asked OHR management if there were any other places in the office that may contain
data or information on these specific performance measures, IA was informed they were not
aware of any.

Performance measures enable management with the ability to analyze trends, and determine if
its services meet division goals and objectives. However, inaccurate data puts the organization
at risk to make poor decisions based off the information collected.

Recommendation 4: Management should routinely check the information that is submitted to

ensure accurate tracking of performance measures.

Department Response: Agree. Performance standards will be reviewed and revised as

necessary for greater accuracy.

Management Operations

There is no board of commissioners.

An oversight body is responsible for overseeing the strategic direction of the entity and
obligations related to the accountability of the entity. This includes overseeing management’s
design, implementation, and operation of an internal control system. When CHRC operated as a
non-profit organization, it had a board of 15 to 25 members at any given time, per CHRC
bylaws. However, when CHRC became a City division in 2015, IA found there was no longer a
board of commissioners.

Having a board of commissioners can be beneficial to the agency. The Department of Justice
issued guidelines for an effective Human Relations Commission in 2003. They state a

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Office of Human Relations Audit

commission’s success stems from having a board of commissioners who are committed to the
philosophy of inclusion, equal opportunity, and fair treatment. Also, the size of the board is
critical and varies among cities, citing most board of commissioners have "an average of seven
to fifteen members.” 8

Unfortunately, CHRC’s previous board had its own challenges. Board minutes reviewed from
2014 and 2015 reflect the difficultly with obtaining quorums, retaining board members, and
properly staffing subcommittees. These challenges may have limited CHRC’s ability to lead with
optimum effectiveness during this time because of the disorder.

Recommendation 5: Re-establish a board of commissioners that falls within the guidelines of

the Department of Justice and determine how they will advance the new mission of the office.

Department Response: Agree. Re-establishing a board of commissioners is a decision of the

Mayor and City Council. We will determine whether the Department of Justice or another
agency is best suited to model the guidelines.

Management review and oversight is lacking over key processes.

Management oversight is necessary to ensure processes are functioning as intended and errors
are detected. IA found management is not providing oversight over internal processes. This
includes constituent case work and quarterly reports, identified previously in this report. The lack
of attention is critical because errors and discrepancies occur, and produce misleading results
for the organization. This makes it difficult for IA to accurately gauge the effectiveness of the
organization.

Recommendation 6: OHR management should routinely review and check data reported in key
processes for accuracy.

Department Response: Agree. Management will provide the necessary oversite to insure
effectiveness in all OHR operations.

OHR is not administering one key function of City ordinance 0397-2015.

When OHR was created, one of its primary responsibilities was to review “…compliance with
non-discrimination provisions of City contracts by contractors doing business with the City or its
independent boards and commissions.” 9 Through staff interviews IA found OHR is not fulfilling
this duty. OHR was established to perform this service to the City and failure to do so prevents
the division from operating at maximum capacity and reaching its fullest potential.

Recommendation 7: Comply with City ordinance 0397-2015 to ensure that this service is being
performed.

Department Response: Agree. OHR will operate pursuant to City ordinance 0397-2015.

8
U.S. Department of Justice Community Relations Service: Guidelines for Effective Human Relations Commissions,
March 2003, p.4.
9
See Appendix A – City Ordinance 0397-2015

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Office of Human Relations Audit

III. Conclusion

OHR plays a critical role in providing services to constituents and communities. Their services
promote positive relationships among various groups, cultures and communities, while
addressing sensitive issues and investigating cases that may have an impact on the City. IA
found areas that need improvement in order for the agency to operate efficiently.

IA suggests updating policies and procedures, accurately tracking and reviewing performance
measures, and increasing management oversight over internal processes. By implementing
these recommendations, OHR will be able to better serve the needs of the City and its
constituents.

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Office of Human Relations Audit

IV. Office of Human Relations Response

The Office of Human Relations became a City Department in December, 2015 after having
operated as the Cincinnati Human Relations Commission, an independent agency since its
establishment in 1943, then the Mayor’s Friendly Relations Committee. During this period of
transition from an independent agency to a City department OHR has been working to clarify its
mission and operations in eliminating bias and discrimination at all levels and all forms within
the City of Cincinnati.

Recommendation 1: Update OHR's policy and procedural manual to reflect current operations.

Department Response: OHR will update policy and procedural manual in the next six months.

Recommendation 2: Create policies and document procedures used to govern the constituent
case process. This includes creating standards for completing paperwork, entering case notes
and the employee assigned into the spreadsheet, and establishing case deadlines.

Department Response: Constituent case process will be revised accordingly.

Recommendation 3: Document the methods used and actions taken in the alleged hate crimes
& bias incidents spreadsheet when OHR responds to incidents around the region.

Department Response: This is a new project and evolving process for OHR We are working
toward a goal of documenting, categorizing data how when appropriate to respond to bias
incidents.

Recommendation 4: Management should routinely check the information that is submitted to

ensure accurate tracking of performance measures.

Department Response: Performance standards will be reviewed and revised as necessary for
greater accuracy.

Recommendation 5: Re-establish a board of commissioners that falls within the guidelines of

the Department of Justice and determine how they will advance the new mission of the office.

Department Response: Re-establishing a board of commissioners is a decision of the Mayor

and City Council. We will determine whether the Department of Justice or another agency is
best suited to model the guidelines.

Recommendation 6: OHR management should routinely review and check data reported in key
processes for accuracy.

Department Response: Management will provide the necessary oversite to insure

effectiveness in all OHR operations.

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Office of Human Relations Audit

Recommendation 7: Comply with City ordinance 0397-2015 to ensure that this service is being
performed.

Department Response: OHR will operate pursuant to City ordinance 0397-2015.

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V. Appendix A – City Ordinance 0397-2015

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Office of Human Relations Audit

VI. Appendix B – City Ordinance 0029-2016