CITY OF SAN ANTONIO

OFFICE OF THE CITY AUDITOR

ANIMAL CARE SERVICES DEPARTMENT

AUDIT OF RESCUE GROUP CONTRACTS
PROJECT NO. AU23-001
FEBRUARY 15, 2024

KEVIN W. BARTHOLD, CPA, CIA, CISA

CITY AUDITOR
 Audit of Animal Care Services
Rescue Group Contracts

Table of Contents

Executive Summary ............................................................................................................................... 2

Background ............................................................................................................................................. 3
Audit Scope and Methodology.............................................................................................................. 5
Audit Results and Recommendations ................................................................................................. 6
A. Contract Monitoring ................................................................................................................. 6
B. Building and System Access .................................................................................................. 8
Appendix A – Staff Acknowledgement .............................................................................................. 10
Appendix B – Management Response .............................................................................................. 11

1
 Audit of Animal Care Services
Rescue Group Contracts

Executive Summary
As part of our annual Audit Plan approved by City Council, we conducted an audit of the Animal
Care Services (ACS) Department, specifically rescue group contracts. The audit objectives,
conclusions, and recommendations follow:

Determine if ACS and rescue groups are in compliance with contract terms.

ACS actively works with rescue partners to provide placement for animals in need. Animal
medical history is also provided by ACS to rescue partners upon animal transfer. In addition,
compensation paid to rescue partners is appropriately approved and amounts are accurate.

However, the audit team identified areas in which controls could be improved over contract
monitoring and system/building access. ACS lacks controls to ensure key contractual
requirements are met by both ACS and the rescue groups. Key requirements include:
• Receipt of required documents from rescue partners,
• Adequate insurance coverage,
• Completion of rescue partner facility inspections, and
• Performance of animal sterilizations.

Furthermore, access to both the High Value Pet Partner (HVPP) building at the ACS campus
and the Chameleon system was excessive.

We provided recommendations to management to strengthen controls and resolve identified

issues. ACS management agreed with the audit findings and has developed positive action plans
to address them. Management’s verbatim response is in Appendix B on page 11.

2
 Audit of Animal Care Services
Rescue Group Contracts

Background
Animal Care Services’ (ACS) mission is to encourage responsible pet ownership by promoting
and protecting residents and pets of San Antonio through education, enforcement, and
community partnership. One of ACS’ community partnerships is the Rescue Program which
contracts with rescue partners to provide care and shelter for animals pulled from ACS while
actively seeking adopters. The program consists of two partner types:

• Low Volume Rescue Partners: Partners that pull a low volume of animals from ACS. These
contracts are awarded through a Request for Application (RFA) process for which they apply
every year.
• High Volume Pet Partner (HVPP): A single partner that pulls a high volume of animals from
ACS. The HVPP is currently San Antonio Pets Alive and the contract is approved by City
Council for one year and eligible for three one-year renewals. The HVPP facility is also
located at ACS’ Highway 151 location at the HVPP building.

Low Volume Rescue Partners were compensated as follows during FY 2023 based on the
number, age, weight, and type of animals pulled from ACS:
• $75.00 per:
o dog that is under 40lbs and over 8 weeks or
o cat over 8 weeks
• $100.00 per cat or dog that is under 7 weeks of age
• $125.00 per dog that is over 40lbs and over 8 weeks
Their compensation will increase to a flat rate of $200 per animal pulled from ACS for FY 2024.

For FY 2023, the HVPP was compensated $75 per animal rescued, despite age, weight, or type
of animal. The HVPP’s compensation will remain the same for FY 2024.

To receive compensation from ACS, the rescue partners must review an outcome report
provided by ACS monthly and confirm its accuracy. Once in agreement, the rescue partner is
required to send an invoice to ACS in order to receive payment. Chameleon, a kennel
management system, is used to pull these monthly outcome reports. In addition, ACS uses
Chameleon to track all animals that come into ACS’ custody, along with their medical history
and relevant notes. See Table 1 on page 4 for a list of rescue partners along with contract
amounts, compensation paid, and number of animals rescued for FY 2023.

3
 Audit of Animal Care Services
Rescue Group Contracts
Table 1: FY 2023 Rescue Partners and Compensation
Number of
Partner Contract Amount Remaining
Partner Name Animals
Type Amount Paid Balance
Rescued
High Volume
San Antonio Pets Alive (SAPA) $300,000 $270,450 $29,550 3,644
Pet Partner
SNIPSA $35,000 $29,825 $5,175 364
San Antonio Humane Society $32,000 $17,525 $14,475 210
God’s Dogs Rescue, Inc. $27,500 $20,250 $7,250 211
Low Volume They Have the Right to Live
Rescue $15,000 $14,500 $500 129
Rescue
Partners Texas Chihuahua Rescue, Inc. $7,500 $500 $7,000 20
Footbridge Foundation $5,000 $2,425 $2,575 22
Vermont English Bulldog
$5,000 $4,650 $350 84
Rescue
Totals $427,000 $360,125 $66,875 4,684
Source: FY 2023 Rescue Partner Contracts, Chameleon, and SAP

During FY 2022, a total of 5,203 animals were pulled from ACS by paid rescue partners.

4
 Audit of Animal Care Services
Rescue Group Contracts

Audit Scope and Methodology

The audit scope was ACS rescue group contracts for FY 2023 and included contract monitoring
efforts, animal availability, sterilization & vaccination requirements, invoicing, insurance
coverage, and access controls.

To gain an understanding of department operations, we interviewed ACS personnel and

conducted walkthroughs over contract monitoring, invoicing, and access controls (for
Chameleon & the HVPP building). The rescue partner contracts were our primary criteria for this
audit.

We assessed internal controls relevant to the audit objective. This included a review of
department policies and procedures, Chameleon system reports, City codes and ordinances,
Administrative Directives, and the Procurement Policy & Procedures Manual. In addition, as part
of our testing procedures we examined the following areas:
• Determined if rescue partners meet requirements defined in the FY 2023 RFA.
• Assessed whether ACS is adequately monitoring the safety of animals after they leave ACS
custody.
• Determined if rescue groups meet required insurance coverage.
• Confirmed whether ACS is providing rescue partners with documentation over animals’
vaccination and sterilization status and if rescue partners are subsequently providing
required vaccinations and sterilizations.
• Reviewed rescue partners’ compensation for allowability and accuracy.
• Confirmed appropriate personnel have badge access to the HVPP building.
• Determined if individuals with access to Chameleon are appropriate.

We relied on computer-processed data in the Chameleon system to confirm animals outcomed

by ACS to rescue partners, medical information, and obtain user access listings. Our reliance
was based on performing direct tests on the data rather than evaluating the system’s general
and application controls. We do not believe that the absence of testing general and application
controls had an effect on the results of our audit.

We conducted this performance audit in accordance with generally accepted government

auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objectives.

5
 Audit of Animal Care Services
Rescue Group Contracts

Audit Results and Recommendations

ACS is actively working with rescue partners to provide placement for animals in need. We
confirmed animals eligible for rescue were viewable by rescue partners. We reviewed a sample
of 25 available animals in ACS’ custody and verified all 25 animals were available on the ACS
website for the rescue partners’ viewing and pulling. Additionally, ACS provides periodic email
updates directly to rescue partners regarding animals that are available. We reviewed recent
emails between ACS and rescue partners and confirmed partners are being notified of available
animals.

Additionally, ACS personnel are providing vaccination/sterilization history to rescue partners. We

performed two in-person observations at ACS’ campus over transfers to rescue partners and
confirmed medical history was provided. In addition, we confirmed the medical documentation
provided matched the medical information stored in Chameleon.

Furthermore, rescue partner invoices were appropriately approved, and amounts paid were
allowable and accurate. We confirmed a sample of 20 invoices were appropriately approved by
ACS and the amounts matched the outcome report obtained from Chameleon.

However, the audit team identified areas in which controls could be improved.

A. Contract Monitoring

ACS lacks controls to ensure key contractual requirements are met. Examples include:
• Receipt of required RFA documents & monthly status reports from rescue partners,
• Evidence of adequate insurance coverage,
• Completion of inspections over rescue partner kennels and facilities, and
• Documentation of performance of animal sterilizations by rescue partners.

In addition, ACS lacks a central repository to ensure appropriate retention of rescue partner
support documentation.

Per the Procurement Policy & Procedures Manual, managing departments should develop a
Contract Administration Plan (CAP) as a tool for administration and monitoring purposes.
Furthermore, CAPs should highlight key provisions of the contract, the monitoring tasks to be
performed, and the frequency of actions to be taken. At this time, ACS only has a CAP in place
for the high volume pet partner, SAPA.

The following paragraphs provide specific contract monitoring issues identified.

6
 Audit of Animal Care Services
Rescue Group Contracts
A.1 Required Documentation

Per the FY 2023 RFA, low volume rescue partners were required to provide supporting
documentation to ACS. Examples include an operating budget, proof the executive
director/president resided in Bexar County or surrounding area, a recommendation letter from a
local veterinarian, protocols for transportation and foster orientation, and a foster contract. These
documents were required prior to contract execution.

However, rescue partners did not meet these requirements as defined in the RFA prior to
contract execution. We requested supporting documentation and determined for all low volume
rescue partners, one or more documents were either missing or inadequate. Without appropriate
documentation as required by the RFA, ACS risks contracting with unqualified organizations.

A.2 Insurance Coverage

Rescue groups did not meet and/or maintain required insurance coverage for all of FY 2023. We
reviewed certificates of insurance for each of the 8 rescue partners. For all rescue partners, one
or more of the following issues applied:
• Insurance coverage was lacking for all or part of FY 2023,
• Insurance coverage types were missing,
• City of San Antonio was not listed as additional insured, and/or
• Insurance companies that were not licensed to do business in the state of Texas were used.

Per each of the rescue partners’ contracts, they are required to provide insurance coverage for
the duration of FY 2023 with the appropriate amounts and types of insurance. The City risks
potential liability due to rescue partners’ lack of appropriate insurance coverage.

A.3 Rescued Animals Monitoring

ACS is not adequately monitoring the safety, outcome, and sterilization status of animals after
they leave ACS’ custody. While the ACS Advisory Board performs quarterly inspections over
SAPA’s facility at the HVPP building, currently ACS is not performing periodic inspections over
the low volume rescue partner facilities (for rescues located either within Bexar County
boundaries or out of state). Additionally, ACS is not requesting monthly status reports from
rescue partners (other than SAPA) to monitor the outcome of animals pulled from ACS.

We also reviewed a sample of 17 animals that left ACS’ custody and were unable to obtain proof
of sterilization from rescue partners for 3 of the animals. Additionally, we determined ACS staff
are not verifying that rescue partners attempting to pull animals from ACS do not have a large
number of overdue unsterilized animals prior to releasing additional animals into their care.

7
 Audit of Animal Care Services
Rescue Group Contracts
Per rescue partner contracts, ACS is authorized to inspect all rescue partner kennels and
facilities. As a best practice, ACS should perform inspections periodically for all rescue partners
to ensure the safety and well-being of animals pulled from ACS. In addition, all partners are
required to provide a monthly status report so ACS can monitor the outcome of the animals.
Lastly, rescue partners must ensure each animal is sterilized prior to the animal leaving their
care and sterilization documentation should be maintained.

Without appropriate monitoring, the health and safety of these animals may be at risk once they
leave ACS’ custody. In addition, without follow-up, ACS risks animals being adopted out to the
public prior to necessary sterilization.

Recommendations

ACS Director ensure:

• Key contractual requirements are monitored for compliance through the use of a CAP.
Key requirements include but are not limited to required RFA documents, insurance,
inspections, monthly status reports, and sterilizations,
• Periodic inspections (at least annually) are performed for all rescue partners, and
• Any issues identified be followed up on with the rescue partners.

B. Building and System Access

Access to the HVPP building and Chameleon system is excessive.

Per Administrative Directive 7.8d Access Control, access controls should be periodically
reviewed, and access should be limited based on the principle of least privilege. Currently, ACS
lacks procedures to ensure access is revoked upon separation and a periodic review for both
building and system access is performed.

The following paragraphs provide specific building and system access issues identified.

B.1 HVPP Building Access

Physical access to the HVPP building at ACS is not appropriate. We reviewed the badge listing
for the 401 individuals with access to the building and confirmed that 91 individuals had
inappropriate access:
• 5 individuals were inactive or withdrawn from the City and
• 86 individuals had inappropriate access to one or more entries at the HVPP building.

As of October 2023, ACS management began evaluating user need for these individuals.

8
 Audit of Animal Care Services
Rescue Group Contracts
B.2 Chameleon Access

System access to Chameleon is not appropriate. We reviewed the active user access listing for
all 264 Chameleon users and determined:
• 50 users were either inactive/withdrawn from the City, employed by other City
departments, or had user ID’s that were no longer in use and require removal,
• 24 general user accounts require further review.

In summary, 74 of 264 (28%) user accounts require further review for possible removal.
Additionally, 6 of 11 users with deletion privileges reviewed were determined to be inappropriate
and require modification.

ACS began reviewing user access during FY 2023; however, the process requires improvement.

Recommendations

ACS Director, in collaboration with ITSD:

• Delimit/modify building and system access as necessary,
• Establish a periodic review (at least annually) over access, and
• Develop an off-boarding process to delimit access upon employee separation/transfer.

9
 Audit of Animal Care Services
Rescue Group Contracts

Appendix A – Staff Acknowledgement

Abigail Estevez, CPA, CIA, CISA, Audit Manager
Loretta Faxlanger, Auditor in Charge
Rudy Carrasco, Auditor

10
 Audit of Animal Care Services
Rescue Group Contracts

Appendix B – Management Response

11
Audit of Animal Care Services
Rescue Group Contracts

12
Audit of Animal Care Services
Rescue Group Contracts

13
Audit of Animal Care Services
Rescue Group Contracts

14