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Uniform Chart of Accounts for Texas Counties

October 2002

Appendix B
Public Comments

The following public comments were received by the FDAC following the publication of the First Draft of the Uniform Chart of Accounts for Texas Counties published in the Texas Register on May 31, 2002.

Per your request, I have reviewed the committee draft of the Proposed Uniform Chart of Accounts for Texas Counties. I believe that the committee has done a very good job of providing a breakdown of the various functions of County government. However many of the Texas counties are small, such as Calhoun County. We have a population of 20,000 and my office consists of myself and three other very capable employees. I do not believe that we would have any trouble recording the information by functions as shown in your chart. We would, however, have a problem in accumulating the information to record.

An example would be the Justice System. You have this broken down by Criminal Justice, Civil Justice and Indigent Defense. We have three District Courts that operate in a six-county area, we have a county court at law in our county, five justices of the peace and a county court. These courts all handle civil cases, criminal cases and indigent cases. To properly break down the expenditures by function each of these judges, court reporters, clerks, bailiffs and etc. would be required to keep accurate time records of the time spent on each case. There may be occasions where a district court could handle 25 cases per day. Some of these cases may be criminal, some may be civil and some may be indigent. I believe that the workload on these people would be considerably increased and therefore the production of the courts decreased. In larger counties where there are people available to keep these types of time records, I believe this would be a good procedure, however, in our county, I am afraid that we would not be able to obtain accurate information.

Perhaps the functions should be different for large counties, medium-sized counties and small counties. I am sure that this information would be very useful, however the cost to obtain the information and the time involved in keeping the records may outweigh the usefulness of the information. A similar problem would exist in Corrections and Rehabilitation between Housing and Booking and Supervision. In our county there are times when only one jailer is on duty. If the jailer is required to keep track of his time in booking prisoners and supervising prisoners he may have to have additional help. Juvenile Services also pose the same problem. The same people involved in the Justice System are involved in the Juvenile Service.

I hope that these comments are useful to you.

Arlene N. Marshall, County Judge

Ben H. Comiskey, Jr. CPA
Calhoun County Auditor

I just received the information packet from the Committee today and the first concern that comes to mind is whether or not the Uniform Chart of Accounts will be compatible with the budgetary accounting system software package we have. I am forwarding a copy of the Committee’s information to Mr. Jim Stateczny with Hill Country Software and Support to see if he thinks his system will be able to adapt to whatever changes this will entail.

My recommendation would be that software companies specializing in county governmental accounting software be involved, to some extent, in the development process to be sure their systems will be able to adapt to the new chart of accounts.

If the new chart would not be compatible with our accounting software (and if no comparably priced alternative was made available), I see that as a major stumbling block in Bailey County’s ability to adopt the new format.

Donna M. Kirk
Bailey County Treasurer
(806) 272-3239

In response to the draft for a uniform chart of accounts, it looks pretty good. In our small rural county we would probably adopt to parts of it, although some of the functions would not be applicable to us.

Ruth Ann Young,
Garza County Treasurer

I am the county auditor in Kerr and Bandera; the existing chart of accounts in each of these counties are similar and each is detailed enough to comply with the preliminary uniform function as drafted. I had already built an Excel model to export each account into the CAFR in compliance with GASB 34. That was a relatively easy process that took only two days to complete. The functions that I included for our CAFR are not exactly the same; however the functions that the committee has drafted are logical so I do not have a problem with the draft.

I appreciated the work of the committee. I think that the result of this process will be a very valuable tool for many counties trying to comply with GASB 34.

You get an OK from me on the draft.

Tommy Tomlinson
Kerr and Bandera County Auditor

I have already sent you an e-mail indicating that our county would adopt this format. I am requesting that the Comptroller adopt this before 10-1-02 as most counties could begin the fiscal year with the new format. If we do make a change, the beginning of our fiscal year is the most logical time.


Tommy Tomlinson
Kerr County Auditor

I have reviewed the preliminary uniform functions/programs drafted by the committee and have only one problem that Comal County would have in complying with such a breakdown. This would be in the area of the justice system and breaking down expenses between criminal and civil endeavors. We are a small/medium-sized county with a population of approximately 80,000; as such our courts/attorney/clerks offices are not separated/specialized and handle all case types through combined offices. Thus, any split between criminal and civil would be a prorating based on civil vs. criminal revenues or case load stats. Furthermore, I’m not sure how useful this information would then be to our commissioners court in management and decision making for the county.

My second comment is a general concern, not specifically directed at the list mailed. The second to the last paragraph of transmittal letter emphasizes that “compliance with a uniform chart of accounts be voluntary and require no additional costs to Texas counties.” I would hope the committee, the Legislature and the Comptroller keep this in mind now, and in the future. I would hope that this project does not evolve into a mandatory system similar to the PEIMS system for Texas school districts, who receive a substantial amount of funding from the state, which is really not the case for counties.

David Renken, CPA
Comal County Auditor

The proposed uniform chart of accounts for Texas Counties would serve my office well and I would be willing to adopt this format.

Suzanne Kucera
Matagorda County Treasurer

I am in receipt of the above-mentioned Chart of Accounts. Our auditor will respond to this issue.

James Kitten
Lubbock County Commissioner

I have looked over the “Uniform Chart of Accounts” sent to me by Susan A. Spataro.

The draft seems to cover a broad enough spectrum of functions/program descriptions to be workable in most counties.

Most important to me was the fact that the Legislature would not require compliance only ask for voluntary participation and that no additional cost would be passed on to the Texas Counties.

If I can be of further help...

Beth Wisenbaker
Hopkins County Commissioner

My comments are as follows:

  1. Corrections is a separate function. Why is this not a sub-function under sheriff or law enforcement? There is a need for separating jail costs out however. I’m not sure about including CSCD with correction or jail expenses. These are generally seen as two separate areas, one judicial and one law enforcement, and there are many cases where these functions need to be separated in costs.

  2. Juvenile services are separate and this group considers themselves Judicial or justice, as does CSCD. Why is this not a sub-group under Justice?

    Were corrections and juvenile separated in this manner because it is believed some software programs would not be able to handle the separations? If so, what about the other breakdowns in the sub-groups?
  3. In the Justice function, there is a separation of expenses by criminal and civil. This will be the most difficult part for a lot of counties. Although I see a need for this information, in many cases there will be no way to do such a separation, as employees and the office are not segregated enough for such a breakdown. Even if they are, it will likely cause the greatest change in the budget and chart of accounts, however, it could be done if need be if it is only a matter of budgeting. To do this accurately would require software with a program function, particularly that could be applied in payroll/HR to individual employees.

  4. In General Government, separating County Judge and County Clerk functions will be the most difficult for a lot of counties, in the other areas the consideration would be civil vs. criminal, but here you are actually crossing functional lines between general government and justice, etc. You should have a rule of one way or the other (probably general government) if it cannot be broken down. Or you could decide e.g., that if the County Judge certifies that he works 40 percent on judicial to the state in order to receive the salary supplement, that his office is divided by a determined percentage to Judicial.
My main question concerns treatment of the jail, particularly inclusive of CSCD, and then the need to address separation of job functions within departments, particularly the County Judge and County Clerk, which may not be traditionally separated.

These are my comments that are not meant to raise questions for discussion, not necessarily against the format.

Winston Duke
Henderson County Auditor
(903) 675-6145
(903) 675-7246 (fax)

I have reviewed the Uniform Chart of Accounts for Texas Counties. Oldham County has a Chart of Accounts, much like the sample you sent, though not as much detail.

We have general administration, and all departments are included within that title, and roads, which includes all functions of road maintenance. We do not have a unit system for roads.

Our system works for us, but should adapt easily to the standards you are proposing.

Helen Wyly
Oldham County Auditor

After going through our budget and getting with our auditor, our present accounts fits into the draft so there would be no recommendations from Liberty County. Good luck in your process!

Commissioner Todd M. Fontenot

We would be supportive of Cooke County’s need to report expenditures and receipts consistent with a Uniform Chart of Accounts. Please let us know where we can be of assistance.

Tony Maddox
Executive Director
MHMR Services of Texoma

Bell County, after making some modifications to our current system, would be able to adopt the proposed format for our county.

Jon Burrows,
Bell County Judge

Bell County is currently working with consultants on our financial system to update for GASB 34, including modification of our current chart of accounts. We will consider this draft of preliminary uniform functions/programs when creating the changes. Our goal will be to build a chart of accounts that will allow for flexibility and future growth.

Donna Eakin
Bell County Auditor

We have reviewed the chart of accounts that was mailed to our office and we would not have a problem adopting this format since our current system basically reports the same way. With very few exceptions our structure is set the way the committee is proposing. Anything different, our system could be modified. If you have any questions, please contact us.

Thank you,
Teresa Molinar
El Paso County

Just a follow-up to Mrs. Molinar’s email. This response relates to El Paso County. If we can be of further assistance, please let me know.

Edward A. Dion, CPA, CIO
El Paso County Auditor
(915) 546-2040, Ext 3482
(915) 546-8172, Fax

My name is Joella McPherson and I am the Randall County Auditor. Our population is about 104,000.

My concerns are that several items that you have broken out among different functions and sub-functions/programs are not split that way in most counties.

For example Randall County has one county court at law judge. He hears Civil, Criminal, Juvenile, and Family Matters. He has one budget. Yet according to your suggestion his budget 2- Functions: a- Justice b-Juvenile; in the Justice Function his budget would have to be broken down among all three sub-functions.

The District Clerk would have to be broken down between two sub-functions.

I am concerned that this would cause a great deal of extra work for small to medium counties in the allocation process.

Joella McPherson
Randall County Auditor

Thank you for requesting my comments on the proposed Uniform Chart of Accounts. The brief period allowed for study and reply may affect the tone and content of my remarks. I received your request on Tuesday, May 28.

Cochran County has used the Comptroller’s Standard Financial Management System for Texas Counties (the “Red Book”) since the early 80s. Compliance with this system and chart of accounts is voluntary, also. Although not perfect, the “red book” has served the county well. I don’t know how many counties are using it, but I suspect there are about as many as will use any ‘voluntary’ chart. Perhaps I have become cynical, but I fail to see the value in reinventing the wheel to come up with yet another system most counties won’t use.

There are many of us out here working pretty hard to keep all our plates spinning, now. Under this proposed chart of accounts, we will need to split our one and only District Judge between Criminal Justice, Civil Justice, and Indigent Defense. The same would apply to our combined County and District Clerk, County Attorney, Constable, etc. What real difference does it make? There will still be crime. There will still be divorce. The State Legislature will still pass unfunded mandates. And each state grant will still have different accounting rules.

Danny Wiseley
Cochran County Auditor

In reviewing the proposed Uniform Chart of Accounts, I believe the group has done an excellent job in making an assessment about what County Government is really all about. This is an excellent start.

I offer the following questions and suggestions:

1. It would seem that fundamental to developing this chart would be determining the real objective of the task. While it is admirable to make the data comparable across all 254 counties, that is really a secondary objective to making the data meaningful and then comparable.

I believe the root objective to be accomplished is to allow each County to accurately determine (at a minimum) the total cost of service for each of the elements included as Sub-Function/Program along with a corresponding unit of measure to determine a cost per some common unit of measurement.

If this objective is appropriate, then a couple of changes to the chart might be advisable:

  • Facilities management should not be a Sub-Function/Program but rather a component of each program.

    Building and maintaining buildings is not a general governmental function.

    Building and maintaining court buildings is a part of the cost of service for operating the justice system.

    Building and maintaining correction facilities is a part of the cost of operating a correction system.

    And so on.

  • The District Attorney – Civil Section (County Attorney – Civil Section) is not actually a part of the Justice System. This function normally represents other county officials in general; operational issues and thus should either be classified as a part of General Government (like Human Resources) or specifically identified to the function of government that they serve.

    My suspicion is that the civil section may have much more dealing with the operation of the jail than they do with the operation of the election department. It simply comes down to the question of how “accurate” do you want the distribution of costs to be and the level of effort required to get there.

  • I do not understand the need for a separate Function for Juvenile Service, rather than simply having this be a Sub-Function/Program under Corrections and Rehabilitation.

    I understand the need for being able to identify this function but does it need to be a different Function?

  • Similarly, Environmental Services seems to be a Sub-Function/Program under the Function of Health & Human Services. Or more specifically three sub-functions

  • Natural resources (not quite as clearly health but close enough)

  • Sanitation (clearly health issue)

  • Waste recycling (another health issue)

  • For the Tax Assessor, is there any relevance to categorizing the efforts/costs associated with the operation of the motor vehicle process in a different function (possibly transportation) since the fees generated in this process have some bearing on transportation issues?

2. Finally, if the concept of developing a meaningful system to allow accurate “apples to apples” comparisons is the path, the next step would be to establish the “uniform” unit of measure for each sub-function/program. Some possible examples would be:
  • Corrections
  • Criminal Justice
  • Tax Administration
  • Roads & Bridges
  • Prisoner days
  • Number of courts
  • Number of parcels
  • Number of road miles maintained

Ron Bertel
Tarrant County

I’m the Val Verde County Auditor. I have received your survey and have the following comments. Being from a small county it becomes very difficult to obtain funding for large capital expenditures, which would be the case for changing or updating our present system. I also see some problems in implementing such a program due to the fact there would be break out reporting by department. For example, all the court systems would be required to report based upon criminal, civil, and indigent defense. It would be very difficult and time consuming to report in this manner.

The overall system of reporting by function appears well laid out and would not be that difficult to implement if some of the break out detail were slim-lined.

Frank L. Lowe
Val Verde County Auditor

The Texas Department of Transportation’s Finance Division has reviewed the “Proposed Uniform Chart of Accounts for Texas Counties” developed by the Texas County Financial Data Advisory Committee. As part of the review and comment process, we would like to request that the sub-function “Roads and Bridges” be changed to “Roads and Bridges Construction” and “Roads and Bridges Maintenance”.

County road and bridge construction and maintenance expenditures are a major portion of the local highway finance data we collect and provide to the Federal Highway Administration (FHWA) as mandated by the U.S. Department of Transportation (USDOT). Information provided in these reports is used by Congress to develop part of a national highway database.

James M. Bass, Director
Finance Division TXDOT

Regarding the Uniform Chart of Accounts proposed by the Texas County Financial Data Advisory Committee, you should have received a request from the Texas Department of Transportation’s Finance Division to change the sub-function “Roads and Bridges” to “Roads and Bridges Construction” and “Roads and Bridges Maintenance.”

In addition, please consider revising the Uniform Chart of Accounts to encompass collection and reporting of motor vehicle title and registration fees by the County Tax Assessor-Collector, which includes the collection and use of County Road and Bridge Fees in accordance with Transportation Code, Sections 502.102, 502.103, and 502.108.

This could be accomplished by renaming and expanding the “Tax Administration” sub-function under General Government or by adding a “Vehicle Title and Registration” sub function under “Roads and Transportation.”

Thank you for your consideration of this request. If you have any questions, please contact me at 512-305-8984 or David Linzey, Director of Headquarters Operations, Vehicle Title and Registration Division, at 512-465-7719.

This request is also being mailed to you in a letter.

Steven Polunsky,
TxDOT Legislative Affairs Office
(512) 305-8984 fax (512) 463-9389

Please be advised that Andrews County has reviewed the objectives of the Committee and supports them enthusiastically.

It is my opinion that Andrews County is as close to compliance and attainment of the aforementioned objectives as can be at this time. Andrews County reporting system utilizing the various software packages from The Software Group, located in Plano, Texas identifies the compliance of the first step in standardizing the reporting process outlined in your letter of May 22, 2002.

At this point, my recommendation for further clarity and utilization would be: Include Community & Economic Development and Roads & Transportation with General Government. Combine Criminal Justice and Civil Justice as one Sub-Function. Combine Environmental Services with Health and Human Services as one Function.

The above suggestions and/or recommendations will not be decisive in Andrews County’s compliance; moreover, Andrews County is committed to the adoption of the proposed format.

R. R. Noble
Andrews County Auditor

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