U.S. ELECTION ASSISTANCE 

COMMISSION 

OFFICE OF INSPECTOR GENERAL 

FINAL REPORT: 

Election System of the Virgin Islands' 

Compliance with the Help America Vote 

Act of 2002 

Report No. 

E-HP-VI-01-13 

October 2013 
 

 

 

 

 

 

 

 

 

U.S. ELECTION ASSISTANCE COMMISSION
 

OFFICE OF INSPECTOR GENERAL
 

1335 East West Highway - Suite 4300
 

Silver Spring, MD 20910
 

Acting Executive Director 

Memorandum 

October 31, 2013 

To:	 Alice Miller 

From:	 Curtis W. Crider 

Inspector General 

Subject: Final Performance Audit Report – Election System of the Virgin Islands' 

Compliance with the Help America Vote Act of 2002 (Assignment Number 

E-HP-VI-01-13) 

Attached for your review and comment is the report entitled Election System of the 

Virgin Islands' Compliance With the Help America Vote Act of 2002, dated August 2013. The 

review was conducted by the U.S. Department of the Interior, Office of Inspector General 

(DOIOIG) on behalf of the U.S. Election Assistance Commission, Office of Inspector General. 

In its audit, the DOIOIG found that Election System of the Virgin Islands' (ESVI) lax 

posture on internal controls put $3.3 million in HAVA funds and other funding at risk of fraud, 

waste, or mismanagement. The audit found: 

•	 no supporting documentation or certification for payroll activities; 

•	 circumvention of procedures established to prevent the abuse of work time; 

•	 no written justification or comparison quotes for small purchases; 

•	 inaccurate and late Federal Financial Reports, including financial reports due months ago 

that still have not been submitted; 

•	 no supporting documentation for funds spent and transferred between bank accounts; 

•	 poor accounting for fees collected, making program income vulnerable to fraud, waste, 

and mismanagement; 

•	 a petty cash account for the Office that is susceptible to misuse because it is managed by 

one person; 

•	 no inventory records for Office property, leaving voting and office equipment
 

unaccounted for;
 

•	 noncompliance with HAVA-required expenditure levels for local elections for 4 fiscal 

years; and 

•	 noncompliance with administrative complaint procedures, resulting in voters’ grievances 

not being addressed. 
 

 

 

 

 

 

As a result, DOIOIG questioned the ESVI’s Office of Supervisor of Election (Office) 

ability to properly account for any of the HAVA funds it received. DOIOIG specifically 

questioned approximately $1.1 million associated with payroll and procurement deficiencies, 

inaccurate and late financial reporting, unsecured equipment, and unreported program income. 

In its September 30, 2013 response to the draft report (Attachment A-1), the Government 

of the Virgin Islands provided comments to the findings and corrective actions, as applicable, to 

address the recommendations. Also included in the report, is the EAC response to the draft 

report (Appendix A-2), which indicated that the EAC would work with the Government of the 

Virgin Islands to ensure corrective action. 

We would appreciate being kept informed of the actions taken on our recommendations 

as we will track the status of their implementation. Please respond in writing to the findings and 

recommendation included in this report by December 31, 2013. Your response should include 

information on actions taken or planned, targeted completion dates, and titles of officials 

responsible for implementation. 

The legislation creating the Office of Inspector General requires that we report to 

Congress semiannually on all audit reports issued, actions taken to implement our 

recommendations, and recommendations that have not been implemented. 

If you have any questions regarding this report, please call me at (202) 734-3104. 

Attachments 

cc: Director of Grants and Payments 
 

 

-

ELECTION SYSTEM OF THE VIRGIN 

AUDIT 

ISLANDS’ COMPLIANCE WITH THE
 

HELP AMERICA VOTE ACT OF 2002 

Report No.: VI-RR-OIG 0001-2013 August 2013
OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

Curtis Crider 	 AUG 0 8 2013 

Inspector General 

U.S. Election Assistance Commission 

Office of Inspector General 

1201 New York Avenue, NW. 

Suite 300 

Washington, DC 20005 

Re: 	 Final Audit Report - Election System of the Virgin Islands' Compliance With the Help 

America Vote Act of 2002 

Report No. VI-RR-OIG-0001-2013 

Dear Mr. Crider: 

This report presents the results of our audit of the Election System of the Virgin Islands' 

(ESVI) compliance with the requirements of the Help America Vote Act of2002 (HAVA). 

Our audit revealed an absence of basic internal controls at ESVI's Office of the 

Supervisor of Elections (Office). This environment has led to the mismanagement and poor 

administration ofHAVA funds . Our findings included deficiencies in payroll and procurement, 

internal controls, and property management, as well as inaccurate and late financial reporting and 

unreported program income. We also found that ESVI did not meet all ofHAVA's 

administrative requirements. 

ESVI's lax posture on internal controls has put $3.3 million in HAVA funds and other 

funding at risk of fraud, waste, or mismanagement. We offer 20 recommendations designed to 

improve the Office' s internal controls and its implementation ofHAVA. 

We appreciated the opportunity to work with you on this project. If you have any 

questions concerning this report, you may contact me at 202-208-5745 or Hannibal Ware, 

Eastern Regional Manager, at 703-487-8058. 

Mary L. 


Deputy Inspector General 


Office of Inspector General I W ashington. DC 
 

 

 

 

Table of Contents 

Results in Brief ....................................................................................................... 1
 

Introduction ............................................................................................................. 2
 

Objective ......................................................................................................... 2
 

Background ..................................................................................................... 2
 

Findings................................................................................................................... 4
 

Payroll and Procurement Deficiencies ............................................................ 4
 

Inaccurate and Late Financial Reporting......................................................... 5
 

Unreported Program Income ........................................................................... 6
 

Deficiencies With Internal Controls for Imprest Fund Checking Account ..... 8
 

Property Management Deficiencies................................................................. 9
 

ESVI Did Not Meet All of HAVA’s Administrative Requirements............. 10
 

Conclusion and Recommendations....................................................................... 13
 

Conclusion ..................................................................................................... 13
 

Recommendations Summary......................................................................... 13
 

Appendix 1: Scope and Methodology................................................................... 15
 

Scope ............................................................................................................. 15
 

Methodology.................................................................................................. 15
 

Appendix 2: Monetary Impact.............................................................................. 16
 
 

 

 

Results in Brief 

We received a request from the U.S. Election Assistance Commission (EAC) 

Office of Inspector General to review the Election System of the Virgin Islands’ 

(ESVI) compliance with the Help America Vote Act of 2002 (HAVA). In 

response, we audited ESVI’s compliance with HAVA and other applicable 

administrative requirements. 

We found a reluctance to adhere to even the most basic internal controls at 

ESVI’s Office of the Supervisor of Elections (Office). This environment has led 

to the mismanagement and poor administration of HAVA funds by the Office. 

During our audit, we found— 

•	 no supporting documentation or certification for payroll activities; 

•	 circumvention of procedures established to prevent the abuse of work 

time; 

•	 no written justification or comparison quotes for small purchases; 

•	 inaccurate and late Federal Financial Reports, including financial reports 

due months ago that still have not been submitted; 

•	 no supporting documentation for funds spent and transferred between 

bank accounts; 

•	 poor accounting for fees collected, making program income vulnerable to 

fraud, waste, and mismanagement; 

•	 a petty cash account for the Office that is susceptible to misuse because it 

is managed by one person; 

•	 no inventory records for Office property, leaving voting and office
 

equipment unaccounted for;
 

•	 noncompliance with HAVA-required expenditure levels for local elections 

for 4 fiscal years; and 

•	 noncompliance with administrative complaint procedures, resulting in 

voters’ grievances not being addressed. 

As a result, we question the Office’s ability to properly account for any of the 

HAVA funds it received. We specifically question approximately $1.1 million 

associated with payroll and procurement deficiencies, inaccurate and late financial 

reporting, unsecured equipment, and unreported program income. 

1 
 

 

 

 

 

Introduction 

Objective 

The objective of this audit was to determine whether the Election System of the 

Virgin Islands (ESVI) expended Help America Vote Act of 2002 (HAVA) 

payments in accordance with the act and related administrative requirements, and 

whether it complied with the HAVA requirements for replacing punch card or 

lever voting machines, establishing an election fund, and maintaining Virgin 

Islands expenditures for elections at a level not less than what was expended in 

fiscal year (FY) 2000. We performed this audit at the request of the U.S. Election 

Assistance Commission’s (EAC) Office of Inspector General. 

See Appendix 1 for the full scope and methodology we followed to perform this 

audit. 

Background 

HAVA was enacted to set minimum election administration standards for State 

and local governments. As part of this goal, HAVA established a program that 

provides funds to State and local governments to— 

• meet specific voting requirements; 

• improve the administration of Federal elections; 

• educate voters; 

• train election officials and poll workers; 

• develop State plans; and 

• improve, acquire, or replace voting equipment. 

The program also provides funds to improve the accessibility and quality of 

polling places and to set up hotlines for voters so that they can obtain election 

information or report fraud or voting rights violations. 

In addition, HAVA established EAC to— 

• issue guidelines; 

• make grant awards; 

• provide oversight, monitoring, and technical assistance; and 

• review the use of HAVA funds. 

In the U.S. Virgin Islands, HAVA is administered by ESVI’s Office of the 

Supervisor of Elections (Office). The Office fulfills ESVI’s day-to-day 

administration. ESVI’s policymaking bodies are the Joint Board of Elections, the 

St. Thomas-St. John District Board of Elections, and the St. Croix District Board 

of Elections. Our audit focused primarily on the Office’s HAVA-related activities. 

2 
 

 

 

 

 

 

In July 2003, a committee of Virgin Islands representatives developed a State plan 

to implement HAVA requirements. ESVI received $3.3 million in funds under 

Titles I and II of HAVA to carry out the improvements outlined in the plan. As of 

December 2011, ESVI had expended $1.8 million of these funds. Title I funds 

were awarded for election administration improvements and for replacement of 

punch card and lever voting machines. Title II funds were awarded to meet Title 

III requirements for voting system standards, provisional voting, and 

implementing a computerized voter registration list. 

In accordance with HAVA, the Virgin Islands Election Fund was established by 

Act 6584 of the Virgin Islands Legislature. Act 6584 requires the Commissioner 

of Finance to administer the Election Fund as a separate and distinct fund in the 

Government’s treasury. The Election Fund should consist of amounts 

appropriated by the Legislature, all HAVA payments made to the Virgin Islands, 

and interest earned on HAVA funds, which is used to carry out more HAVA 

activities. HAVA funds are transferred from the Election Fund, which is a savings 

account, to a fund known as the “Special and Other Fund,” which is a checking 

account used by ESVI and other Virgin Islands Government agencies. Both funds 

are managed by the Virgin Islands Department of Finance (DOF). 

3 
 

 

 

 

 

 

Findings 

We found that the Office disregarded the basic tenet of internal controls, which 

protects the integrity of any organization. Specifically, we found major 

deficiencies in the administration of payroll, procurement, financial reporting, 

program income, imprest (petty cash) fund, and property. Moreover, ESVI did not 

meet all of HAVA’s administrative requirements for fiscal year funding levels 

and administrative complaint procedures. 

Of the $1.8 million in HAVA funds ESVI expended, we question over $1.1 

million—approximately 60 percent—because of the discrepancies we found in 

these areas (see Appendix 2). 

Payroll and Procurement Deficiencies 

Federal salary and wage standards require payroll charges to be supported by 

proper documentation and periodic certification of hours worked. We found, 

however, that the Office could not provide documentation to identify employees 

who worked on HAVA projects or the pay periods and hours for which 

employees were paid with HAVA funds. It also could not certify the amount of 

time employees spent on HAVA-related activities. 

The Office spent $438,452 of HAVA Title I funds for salaries from September 

2003 to December 2007. According to Office officials, three employees were paid 

with HAVA funds; however, we received documentation to support payroll costs 

for just two employees. Because the Office could not provide complete supporting 

documentation, we question $221,129 of the amount it claimed. 

Furthermore, the Office could not provide documentation certifying the hours 

worked on HAVA-related activities. Office officials told us that they used 

logbooks to record time and attendance, but when we requested the logbooks to 

support the payroll costs charged to HAVA, they could not provide them. 

We also found that the Office circumvents the Government of the Virgin Islands’ 

biometric punch clock system, which uses employees’ fingerprints to log their 

arrival and departure times. This system, implemented Governmentwide to 

prevent the abuse of work time, was installed at the Office in June 2012, but most 

of the Office’s employees have never used it. Because the Office did not provide 

time and attendance records and the system was not being used, there was no 

assurance that Office employees were not abusing time. This potential for abuse 

could affect not only HAVA funds, but also any other funding the Office uses for 

payroll. 

Finally, the Office did not follow procurement rules and regulations for small 

purchases, which require comparison quotes from vendors and written 

justification letters to support purchases up to $50,000. We reviewed five small 

purchases for services and equipment, totaling $17,149, and discovered that none 

4 
 

 

 

 

 

were supported by comparison quotes or written justification. We therefore 

question the entire $17,149. 

Recommendations 

We recommend that EAC require the Office to: 

1. Maintain documentation to support all payroll costs related to HAVA; 

2. Certify payroll costs to ensure that HAVA funds are used properly; and 

3. Follow procurement requirements for small purchases. 

Inaccurate and Late Financial Reporting 

Federal regulations require that a State’s financial management system include 

accounting procedures to ensure accurate, current, and complete financial 

reporting. These procedures should identify the source and application of funds 

and include accounting records supported by source documents. 

The Office could not provide supporting documents for $123,166 in Title I funds 

to procure voting machines and services such as advertising, printing, training, 

and travel. It also transferred $1,974,111 from the Election Fund to the Special 

and Other Fund between July 2004 and October 2011. Of this amount, the Office 

could not provide supporting documentation for $161,593. Because the Office did 

not provide supporting documentation for these two amounts, we question the 

total, $284,759. 

In addition to Federal regulations over accounting procedures, EAC requires the 

Office to file annual Federal Financial Reports detailing all HAVA-related 

activities. Financial activities for Title I and II funds are reported on separate 

forms and must be submitted by the end of each calendar year. We found several 

inaccuracies in the Office’s reports. For example, the Office— 

• over-reported $238,898 in Title II funds in FY 2010; 

• did not report $878 in Title I funds spent in calendar year 2005; and 

• did not report $331 in interest income during the period we reviewed. 

Moreover, the Office submitted its Federal Financial Reports late eight times— 

with an average delay of over 6 months—and, as of March 2013, it still had not 

prepared its reports for FY 2012. The Office also arbitrarily changed its reporting 

period from fiscal year to calendar year without EAC’s approval. The Office’s 

inaccurate and late financial reporting brings into question the reliability of the 

information that EAC uses to carry out its responsibility for oversight and 

monitoring of HAVA funds. 

5 
 

 

 

 

 

Recommendations 

We recommend that EAC require the Office to: 

4. Provide documentation to support HAVA funds expended; and 

5. File accurate, on-time Federal Financial Reports and submit the FY 2012 

report. 

Unreported Program Income 

Under Federal regulations, program income includes income from fees collected 

by an agency for services it performs. HAVA program income comes from fees 

collected for late campaign disclosures, voter registration lists, and other electionrelated services. EAC requires that the Office’s program income be dedicated to 

uses permitted under HAVA and that it be reported on its Federal Financial 

Reports. 

The Office collected program income for different purposes and deposited those 

fees into two separate accounts. Fees collected to replace voter identification 

cards were deposited into the Special and Other Fund, which is maintained by the 

Department of Finance (DOF). Fees collected for late campaign disclosures, voter 

registration lists, and other election-related services were deposited into the 

Office’s Imprest Fund Checking Account (Account), a petty cash account 

maintained solely by the supervisor of elections. 

The Office claimed it collected $113,345 in program income during the period we 

reviewed and that it deposited the funds into the accounts. Because the Office did 

not provide basic accounting records to support its claim, however, we could not 

ensure that all of the fees it collected had been deposited. 

For example, the Office’s St. Thomas location did not give us any cashier receipts 

and deposit slips to verify fees collected and deposited. The only documentation 

St. Thomas provided was interoffice memoranda to the supervisor and summaries 

to DOF prepared from October 2006 to December 2012. During that time, the 

Office reported collecting fees of $52,946. 

The St. Croix location provided more supporting documentation for its claim of 

$60,399 in collections. Due to discrepancies in reports, cashier receipts, and 

deposit slips, however, we question whether all fees collected had been deposited. 

For example, we found the following: 

•	 In eight instances, fee collectors did not maintain the required number of 

copies of receipts for voided transactions. In one of these instances, the 

amount recorded on a voided receipt was also reported as collected and 

deposited. 

6 
 

 

 

• In two instances, dates on cashier receipts were changed to reflect fee 

collections and deposits made later (see Figure 1): 

Figure 1. Altered dates on cashier receipts (dates circled). 

•	 In some instances, cashier receipts totaled more than the amounts
 

deposited; other receipts totaled less.
 

These examples are potential fraud indicators, exposing an environment of poor 

collection practices and an absence of internal controls. 

In addition, although EAC requires that program income be used only for HAVArelated activities, we found that the Office instead used the $113,345 it claimed to 

have collected for its operating expenses, such as office supplies. The Office also 

did not report any program income on its Federal Financial Reports. 

7 
 

 

 

 

 

 

 

 

Recommendations 

We recommend that EAC: 

6. Require the Office to accurately determine the total amount of 

unreported program income collected; 

7. Require the Office to amend its Federal Financial Reports to include 

program income earned from FY 2003 to FY 2011; 

8. Require the Office to report program income earned for FY 2012 and 

future reporting periods; 

9. Work with the Office to resolve the unreported program income of 

$113,345; 

10. Require the Office to establish adequate controls by maintaining 

reports, cashier receipts, and deposit slips to ensure that the amounts 

collected for program income are reported and deposited; and 

11. Require the Office to deposit all program income into the Election 

Fund. 

Deficiencies With Internal Controls for Imprest 

Fund Checking Account 

In June 1998, the Virgin Islands Legislature passed Act No. 6239, establishing the 

Imprest Fund Checking Account (Account) for the Office. The act gave the 

supervisor of elections sole authority to write checks from the Account. The act 

also established the Voter Identification and Registration Fund, which consists of 

all sums appropriated by the Legislature and all fees collected by the Office to 

replace voter identification cards. 

Monies in the Voter Identification and Registration Fund are disbursed into the 

Account by the Commissioner of DOF. Although DOF is responsible for 

maintaining a record of all monies deposited and disbursed from the Account, 

DOF officials confirmed that the Office was managing this Account—and doing 

so separately from DOF’s financial system. 

We attempted to review the transactions in the Account. Beginning in January 

2013, we made many requests to the Office for the 123 bank statements covering 

the period from October 2002 to December 2012. The Office eventually provided 

6 statements in April 2013, and DOF also provided the 24 bank statements it had 

received from the supervisor—altogether, less than a quarter of the statements we 

requested. The 30 statements we reviewed had deposits totaling $22,250. Because 

we did not receive all of the statements and many of the statements we received 

8 
 

 

 

 

 

 

 

 

had pages missing, we were unable to determine the entire amount deposited into 

the Account. Furthermore, we were unable to determine whether the funds were 

used for legitimate purposes. 

In addition to our difficulties obtaining the Account’s bank statements, we are 

concerned about the Account’s transactions. In the 30 statements we reviewed, we 

found 5 instances in which the supervisor wrote checks to himself. The checks’ 

memo lines simply stated that the payments were reimbursements. In addition to 

writing checks, the supervisor was the only one making deposits into the Account. 

Moreover, the Account was not reconciled internally, but by an external 

contractor—a contractor who reported directly to the supervisor. 

A fundamental element of strong internal controls is the segregation of certain key 

duties. Segregation of duties, including making deposits, writing checks, and 

reconciling accounts, reduces the likelihood of undetected fraud, waste, and 

mismanagement. Because duties surrounding the Account were not segregated, 

the Account was left susceptible to misuse. We referred this issue to our Office of 

Investigations for further review. 

Recommendations 

We recommend that EAC: 

12. Require the Office to stop depositing HAVA-related fees into the 

Imprest Fund Checking Account; and 

13. Require the Joint Board of Elections to establish safeguards to mitigate 

the potential fraudulent use of the Imprest Fund Checking Account. 

Property Management Deficiencies 

The Code of Federal Regulations (41 C.F.R. § 105-71.132) states that a property 

control system must have adequate safeguards to prevent loss, damage, or theft of 

property. Property records should include property descriptions, serial numbers, 

identification numbers, sources, acquisition dates, locations, cost, and condition. 

In addition, a physical inventory of property must be taken and the results 

reconciled with the records at least once every 2 years. 

We found that the Office did not maintain detailed property records to properly 

account for all of the equipment it purchased with HAVA funds. We were able to 

verify that the Office spent $550,189 for voting machines, e-poll books, servers, 

and other items, but we could not locate the items on the Office’s inventory lists. 

We also received incomplete inventory lists, which prevented us from tracing 

pieces of equipment from the lists to their physical location or vice versa. The 

absence of property records makes it impossible to ascertain the location and 

9 
 

 

 

 

 

 

 

 

 

condition of the equipment. For these reasons, we question the $550,189 the 

Office spent on equipment. 

Moreover, the Office did not conduct any of the required physical inventories of 

equipment. None of the officials we interviewed could remember the last time a 

physical inventory had been conducted. 

When equipment is no longer needed for the original project or program, an 

agency must request disposition instructions from the awarding agency. Office 

officials informed us that they did not know the Federal procedures for disposing 

of equipment. Although the Office’s St. Croix location gave us a 2010 list of 

disposable items, Office officials did not know if the items had actually been 

disposed of. 

Recommendations 

We recommend that EAC require the Office to: 

14. Immediately conduct a physical inventory to gain control of and 

account for equipment. The inventory should include property 

descriptions, serial numbers, identification numbers, source of 

property, acquisition dates, property locations, cost, and condition; 

15. Conduct physical inventories at least once every 2 years and reconcile 

them to property records; and 

16. Reconcile any equipment previously disposed of and adhere to Federal 

guidelines for future disposals. 

ESVI Did Not Meet All of HAVA’s Administrative 

Requirements 

HAVA requires States using Title II funds to maintain expenditures at least at the 

amount expended in FY 2000. The requirement was intended to prevent State 

governments from using HAVA funds instead of local funds. For ESVI, this 

expenditure level was $1.4 million. 

We found that the Government of the Virgin Islands did not comply with the 

expenditure requirement during FYs 2003, 2004, 2012, and 2013, for a total 

shortage of $1,028,303 (see Figure 2). According to EAC guidance, when States 

fail to meet the established expenditure requirement, the issue is to be addressed 

through EAC’s audit resolution process. 

10 
 

 

 

Maintenance of Expenditures 

*Indicates FYs Underfunded 

$2,500,000 

$2,000,000 

$1,500,000 

$1,000,000 

$500,000 

$0 

Current FY Expenditure 

Figure 2. ESVI expenditures from FY 2003 to FY 2013. The black dotted line indicates FY 

2000 expenditure levels of $1.4 million. 

HAVA also requires that States establish administrative complaint procedures as a 

condition of receiving funds. The procedures must be uniform and 

nondiscriminatory; any person who believes that there is a violation of any 

provision of Title III may file a written, notarized complaint. The complainant 

may also request a hearing. If a violation is found, the State is required to provide 

the appropriate remedy. If the complaint is dismissed, the results should be 

published. According to the procedures, the State must make a final determination 

about the complaint within 90 days from the date it is filed. 

We found that the Office did not adequately follow HAVA’s administrative 

complaint procedures. We reviewed all 13 notarized complaints recorded for 2 

election cycles and found that the Office had not responded to 12 of them. For the 

one complaint the Office did respond to, we did not find any documentation to 

prove that the issue had been resolved. 

We also found that complaint files were incomplete and disorganized. Complaints 

recorded in logbooks were not found in complaint files. Further, complaints were 

loosely filed and detached from their supporting documents; resolutions were not 

kept with original complaints; and we were not provided complaints addressed to 

board members, which are logged separately from complaints to the Office. 

These issues concerning the administrative complaint procedures and maintaining 

complaint files indicate that ESVI did not follow HAVA administrative 

requirements, resulting in voters’ grievances not being addressed. 

2003* 2004* 2005 2006 2007 2008 2009 2010 2011 2012* 2013* 

11 
 

 

 

 

 

 

Recommendations 

We recommend that EAC: 

17. Require the Government of the Virgin Islands to maintain expenditures 

at the FY 2000 expenditure level as required by HAVA § 254(a)(7); 

18. Address the failure to meet established expenditure requirements 

through its audit resolution process; 

19. Require the Office to adhere to administrative complaint procedures in 

accordance with HAVA § 402(a); and 

20. Require the Office to maintain a complete complaint file that includes, 

at a minimum, all complaints, responses, records of hearings, and 

outcomes. 

12 
 

 

 

 

Conclusion and Recommendations 

Conclusion 

Internal controls promote efficiency, reduce fraud risks, and help ensure the 

integrity of operations and compliance with applicable laws and regulations. To 

be effective, internal controls require the maintenance of proper records for the 

flow of timely, relevant, and reliable information. 

A sound internal control environment would have mitigated the deficiencies we 

found in the Office’s administration of payroll, procurement, financial reporting, 

program income, imprest fund, and property. In addition to these deficiencies, 

basic HAVA requirements for maintaining a funding level and adhering to 

administrative complaint procedures were not attained. ESVI’s lax posture on 

internal controls has put $3.3 million in HAVA funds and other funding at risk of 

fraud, waste, or mismanagement. 

We have forwarded information about the Imprest Fund Checking Account to our 

Office of Investigations for further examination. 

Recommendations Summary 

We recommend that EAC: 

1.	 Require the Office to maintain documentation to support all payroll costs 

related to HAVA; 

2.	 Require the Office to certify payroll costs to ensure that HAVA funds are 

used properly; 

3.	 Require the Office to follow Federal and local requirements for small 

purchases; 

4.	 Require the Office to provide documentation to support HAVA funds 

expended; 

5.	 Require the Office to file accurate, on-time Federal Financial Reports and 

submit the FY 2012 report; 

6.	 Require the Office to accurately determine the total amount of unreported 

program income collected; 

7.	 Require the Office to amend its Federal Financial Reports to include 

program income earned from FY 2003 to FY 2011; 

8.	 Require the Office to report program income earned for FY 2012 and 

future reporting periods; 

13 
 

 

 

9.	 Work with the Office to resolve the unreported program income of 

$113,345; 

10. Require the Office to establish adequate controls by maintaining reports, 

cashier receipts, and deposit slips to ensure that the amounts collected are 

reported and deposited; 

11. Require the Office to deposit all program income into the Election Fund; 

12. Require the Office to stop depositing HAVA-related fees into the Imprest 

Fund Checking Account; 

13. Require the Joint Board of Elections to establish safeguards to mitigate the 

potential fraudulent use of the Imprest Fund Checking Account; 

14. Require the Office to immediately conduct a physical inventory to gain 

control of and account for equipment. The inventory should include 

property descriptions, serial numbers, identification numbers, source of 

property, acquisition dates, property location, cost, and condition; 

15. Require the Office to conduct physical inventories at least once every 2 

years and reconcile to property records; 

16. Require the Office to reconcile any equipment previously disposed of and 

adhere to Federal guidelines for future disposals; 

17. Require the Government of the Virgin Islands to maintain expenditures at 

the FY 2000 expenditure level as required by HAVA § 254(a)(7); 

18. Address the failure to meet established expenditure requirements through 

its audit resolution process; 

19. Require the Office to adhere to administrative complaint procedures in 

accordance with HAVA § 402(a); and 

20. Require the Office to maintain a complete complaint file that includes, at a 

minimum, all complaints, responses, records of hearings, and outcomes. 

14 
 

 

 

 

 

Appendix 1: Scope and Methodology 

Scope 

We conducted this 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. 

Our scope included a review of activities and transactions that occurred from 

October 2002 to December 2012. We performed our work from December 2012 

to April 2013. Our scope was limited by Office officials’ inability to provide all 

records for payroll, program income collected, the Imprest Fund Checking 

Account, and complaints. To accomplish our audit objective, we reviewed records 

and interviewed Election System of the Virgin Islands (ESVI) officials. We also 

conducted site visits of ESVI offices in the St. Thomas-St. John and St. Croix 

Districts, and the Departments of Finance and Property and Procurement. We also 

interviewed officials at the Office of Management and Budget and the Bureau of 

Information Technology. 

During the audit, several obstacles arose that limited the scope of our work. The 

Office was unable to supply documentation for almost everything we asked to 

review, including supporting documentation or certifications for payroll, written 

justification or comparison quotes for small purchases, support for funds spent 

and transferred between bank accounts, and inventory records for Office property. 

As a result, we were unable to review all transactions and determine the full 

extent of the discrepancies we noted. 

Methodology 

To accomplish our objective, we reviewed the entire universe of Help America 

Vote Act payroll charges, Federal Financial Reports, Election Fund transfers, 

program income, Imprest Fund Checking Account bank statements, and ESVI’s 

annual budgets. We also selected a judgmental sample in the area of procurement 

and reviewed all of the administrative complaints on file at the Office. 

We also reviewed computer-processed data provided by the Virgin Islands 

Department of Finance for calendar years 2003 to 2009. We assessed the 

reliability of the data as part of our review and noted major discrepancies. We did 

not use the data for the purpose of our review; thus, the data did not affect the 

performance of our audit steps. 

15 
 

 

 

 

 

 

 

 

Appendix 2: Monetary Impact
 

Questioned Costs 

Unsupported Costs: 

Payroll and Procurement Deficiencies $238,278 

Inaccurate and Late Financial Reporting $284,759 

Unsecured Equipment $550,189 

Total Questioned Costs $1,073,226 

Funds To Be Put to Better Use 

Unreported Program Income $113,345 

Total Funds To Be Put to Better Use $113,345 

Overall Monetary Impact $1,186,571 

16 
 

 

 

 

 

 

 

 

 

 

 

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and Mismanagement 

Fraud, waste, and mismanagement in 

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of Inspector General staff, departmental 

employees, and the general public. We 

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and mismanagement related to 

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and operations. You can report 

allegations to us in several ways. 

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By Phone: 24-Hour Toll Free: 

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APPENDIX A-1

THE THE Tm UNITED UNITED Uxrrsp STATES STATES Surns V VIRGIN Vrncrn IRGIN IISLANDS Isllr.los SLANDS

OOFFICE OFFICE FFICE OOFTHE FF THE THE GOVERNOR GOV€RNOR 

GGOVERNMENT OVE OVERNMENT RNMENT HHOUSE OUUSE SE

Char Charlotte Charlotte lotte AAmalie, Amalie, malie, VV.I. V.I. .I. 00802 00802 00802

340-774-000 3434-77+0iJ,0l 0-774-0001I

September September September 30, 30, 30, 2013 2013 2013

Mr. Mr Mr.. Curtis Curtis Curtis Crider Crider Crider

Inspector Inspector Inspector General General General

UU.S. U.S. .S. Election Election Election Assistance Assistance Assistance Commission Commission Commission

Office Office Office of of of Inspector Inspector Inspector General General General

1201 1201 l20l New New New York York York Ave. Ave. Ave. NW NW Suite Suite Suite 300 300 300

Washington, Washington, Washington, DC DC 20005 20005 20005

Dear Dear Dear Inspector Inspector Inspector General General General Crider: Crider: Crider:

This This This correspondence correspondence acknowledges acknowledges acknowledges receipt receipt of of of your your letter letter letter dated dated dated August August August 1616,2013 ,, 2013 2013 seeking

my my review review and and and comments comments on on the the proposed proposed report report entitled entitled Election Election System System of of ofthe the the Virgin Virgin Islands Islands' ''

Compliance Compliance with with the the Help Help America America 4m"r;.u Vote Vote Uote Act Act of of 2002 2002 (HA (HAVA). VVA). A).

On On behalf behalf of of the the Government Government Govemment of of the the Virgin Virgin Islands Islands (GVI) (GVl) (GVI),,, and and the the Election Election System System of of of the the the 

Virgin Virgin virgin Islands Islands (ESVI) (EsvI), ,, 1 II would would like like toto thank thank the the U.s. U.S. U.S. Department Department Department of of the the Interior, Interior,, office Office Office of of of the the

Inspector Inspector Inspector General General and and the the u.S. UU.S. .S. Election Election Assistance Assistance commission Commission Commission (EAC), (EAC), (EAC), Office Office oflice of of of t}le Inspector the the Inspector 

General General for for itsits review review of of the the Election Election System System of of the the virgin Virgin Virgin Islands' Islands'' proposed proposed report, report report, , and and also also for for for

itsits continued continued support support and and willingness willingness willingness toto work work collaboratively collaboratively with with ESVI ESVI ESVI tototo ensure ensure that that that corrective corrective 

actions actions are are implemented implemented that that that sufiiciently suffic sufficiently iently address address the the deficiencies deficiencies and and recommendations. recommendations. recommendations.

The The Election Election System System of ofthe the Virgin Virgin Virgin Islands Islands Islands has has has aaa new new new Supervisor Supervisor Supervisor ofthe of ofthe the Board Board Board of ofElections Elections

and and and aaa newly newly newly elected elected elected board. board. board. The The Supervisor Supervisor along along along with with with her her her team team team isisis working working working feverishly feverishly feverishly tototo comply comply comply 

with with with the the the recommendations recommendations recommendations of of of the the the U.s. U.S. U.S. Election Election Election Assistance Assistance Assistance commission. Commission Commission.. Enclosed, Enclosed,, for for for your your

review review review and and and acceptance, acceptance, acceptance, isisis the the the ESVI's ESVI's ESVI's rcsponse response response tototo each each each of of of the the the recommendations, recommendations recommendations,, and and and the the the person person

responsible responsib responsible le and and and the the the due due due date, date,, and,/or and/or and/or implementation implementation implementation date. date. date. 

Thank Thank Thank you you you for for for the the the opportunity opportunity opportunity afforded afforded afforded the the the GVI GVI GVI toto to review review review and and and comment comment comment onon on the the the Draft Draft Draft 

Audit Audit Audit Report. Report. Report. II I amamam confident confident confident that that that the the the Supervisor Supervisor Supervisor and and and ESVI ESVI ESVI will will will continue continue continue tototo proactively proactive proactively ly pursue pursue pursue 

firll full full compliance compliance compliance inin in accordance accordance accordance with with with the the the Help Help Help America America America Vote Vote Vote Act Act Act of of2002 2002 2002 (IIAVA). (HAVA). VA).

Sincerely. KflI ~1t~ ~p.

Q"fJ".a"\ P.. de 19ll~/Jr ':fGl;~/JI Govemor Governor
APPENDIX A-1

Election Election System System of of of the the the Virgin Virgin Islands Islands 


Response Response Response to to the the the Draft Draft Draft Letter Letter Letter Audit Audit Audit Report Report 
 Report

lslands 

Ofthe Ofthe Of the Office Office Oflice ofthe ofthe of the U.S. U.S. U.S. Department Department Department ofInterior, of Interior, 

Office Office Oflice of of of the the the Inspector Inspector Inspector General General General on on behalf behalf behalf of of of the the

U.S. U.S. U.S. Election Election Assistance Assistance Commission Commission

(Report (Report (Report No. No. No. VI-RR-OIG-0001-2013, VI-RR-OIG-0001-2013, VI-RR-OIG-0001-2013, August August August 2013) 2013) 2013)

FINDINGS FINDINGS

•

o Payroll Payroll Payroll and and and Procurement Procurement Procurement Deficiencies Deficiencies 
 Deficiencies

•

o Inaccurate Inaccurate Inaccurate and and and Late Late Late Financial Financial Financial Reporting 
 Reporting

•. Unreported Unreported Uffeported Program Program Income Income

•r Deficiencies Deficiencies Deficiencies With With Internal Internal Intemal Controls Controls Controls for for for Imprest Imprest Imprest Fund Fund Checking Checking Checking Account Account

•. Property Property Management Management Management Deficiencies Deficiencies 
 Deficiencies

•

o ESVI ESVI ESVI Did Did Not Not Not Meet Meet Meet ALL ALL ofHAVA's of HAVA's Administrative Administrative Requirements Requirements 
 Requirements

Election Election Systems Systems Systems of of of the the Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) disregarded disregarded disregarded the the basic basic tenet tenet tenet of of of internal internal controls, controls, controls,

which which protects protects the the integrity integrity of of of any any any organization. organization. organization. Specifically, Specifically, Specifically, major major major deficiency deficiency deficiency inin in the the

administration administration administration of of of payroll, payroll, payroll, procurement, procurement, procurement, financial financial financial reporting, reporting, reporting, program program income, income, income, imprest imprest imprest (petty (petty (petty cash) cash) cash)

fund, fund, fund, and and and property property were were found. found. found.

tslection intemal 

Recommendations Recommendations Recommendations (Election (Election (Election Assistance Assistance Commission Commission Commission (EAC» (EAC» (EAC))

I.L Require Require Require the the Office Office Office to to maintain maintain documentation documentation documentation to to support support support all all all payroll payroll payroll costs costs costs related related to to Help Help

AcI America America Vote Vote VoteAct Act of of of 2002 2002 2002 (HA (HAVA). VA). A). 

2.2. Require Require Require the the Office Office Office to to certify certify certify payroll payroll payroll costs costs costs to to ensure ensure ensure that that that HAVA HAVA funds funds funds are are are used used properly. properly. properly.

3.3. Require Require Require the the Office Office Office to to follow follow Federal Federal Federal and and and local local local requirements requirements requirements for for for small small small purchases. purchases. purchases.

4.4. Require Require Require the the Office Office Office to to provide provide documentation documentation documentation to to support support support HAHAVAVV AA funds funds funds expended. expended. expended.

5.5. Require Require Require the the Office Office Office to to file file file accurate, accurate, accurate, on-time on-time on-time Federal Federal Federal Financial Financial Financial Reports Reports Reports and and and submit submit submit the the FY FY

2012 2012 report. report. report.

6.6. Require Require Require the the Office Office Office to to accurately accurately accurately determine determine determine the the total total total amount amount amount of of of unreported unreported program program

income income income collected. collected. collected.

7.7. Require Require Require the the Office Office Office to to amend amend amend itsits its Federal Federal Federal Financial Financial Financial Reports Reports Reports to to include include include program program income income income

earned earned eamed fonn fonn form FY FY 2003 2003 to to FY FY 2011. 201 1. 

8.8. Require Require the the Office Office Office to to report report report program program income income income earned earned eamed for for for FY FY 2012 2012 and and and future future future reporting

periods. periods. periods.

9.9. Work Work with with the the Office Office Office to to resolve resolve the the unreported unreported unrepofied program program income income income of$113,345. of $113,345. 

10. 10. 10. Require Require Require the the Office Office Office to to establish establish establish adequate adequate adequate controls controls controls by by maintaining maintaining reports, reports, reports, cashier cashier cashier receipts, receipts, receipts,

and and and deposit deposit deposit slips slips slips to to ensure ensure ensure that that that the the amounts amounts amounts collected collected collected are are are reported reported and and and deposited. deposited. deposited.

11. 11. 11. Require Require Require the the Office Office Office to to deposit deposit deposit all all all program program income income income into into into the the Election Election Fund. Fund. Fund.

12. 12. 12. Require Require Require the the Office Office Office to to stop stop stop depositing depositing depositing HAVA HAVA -

-
related related fees fees fees into into into the the Imprest Imprest Imprest Fund

Checking Checking Checkins 
Account. Account. Account.
APPENDIX A-1

13. 13. 13.Require Require Require the the the Joint Joint Joint Board Board Board of of ofElections Elections Elections toto toestablish establish establish safeguards safeguards safeguards toto tomitigate mitigate mitigate the the the potential potential

fraudulent fraudulent fraudulent use use use of of ofthe the the Imprest Imprest lmprest Fund Fund Fund Checking Checking Checking Account. Account. Account.

14. 14. 14.Require Require Require the the the Office Office Office toto to immediately immediately immediately conduct conduct conduct aa physical physical physical inventory inventory inventory toto to gain gain gain control control control of and and 

account account account for for for equipment. equipment. equipment. The The The inventory inventory inventory should should should include include include property property property descriptions, descriptions, descriptions, serial serial serial

numbers, numbers, numbers, identification identification identification numbers, numbers, numbers,source source source of of of property, property, property, acquisition acquisition acquisition dates, dates, dates, property property property location, location, location,

cost, cost, cost, and and and condition. condition. condition.

a ofand 

15. 15. 15.Require Require Require the the the Office Office Office toto to conduct conduct conduct physical physical physical inventories inventories inventories at at at least least least once once once every every every two two two (2) (2) (2) years years years and and and

reconcile reconcile reconcile toto to property property property records. records. records.

16. 16. 16. Require Require Require the the the Office Office Office toto to reconcile reconcile reconcile any any any equipment equipment equipment previously previously previously disposed disposed disposed of of of and and and adhere adhere adhere toto to

Federal Federal Federal guidelines guidelines guidelines for for for future future future disposals. disposals. disposals.

17. 17. 17. Require Require Require the the the Government Government Govemment of of olthethe the Virgin Virgin Virgin Islands Islands Islands toto to maintain maintain maintain expenditures expenditures expenditures at at at the the the FYFY FY 2000 2000 2000

expenditure expenditure expenditure level level level asas as required required required byby by HAVA HAVA HAVA 254(a)(7). 25a@)Q). 

18. 18. 18. Address Address Address the the the failure failure failure toto to meet meet meet established established established expenditure expenditure expenditure requirements requirements requirements through through through itsits its audit audit audit

resolution resolution resolution process. process. process.

19. 19. 19. Require Require Require the the the Office Office Office toto to adhere adhere adhere toto to administrative administrative administrative complaint complaint complaint procedures procedures procedures inin in accordance accordance accordance with with with

HAVA HAVA HAVA 402(a): 402(a): 402(a): and and and

20. 20. 20. Require Require Require the the the Office Office Office toto to maintain maintain maintain aa a complete complete complete complaint complaint complaint file file file that that that includes, includes, includes, at at at aa a minimum, minimum, minimum, all all all

complaints, complaints, complaints, responses, responses, responses, records records records of of ofhearings, hearings, hearings, and and and outcomes outcomes

Election Election Election Systems Systems Systems of of of the the the Virgin Virgin Virgin Islands Islands Islands Response Response Response

Recommendation Recommendation No.1 No.1 No. l

The The The Election Election System System of of ofthethe the Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs.

Action Action Plan: Plan: Plan: ESVI ESVI ESVI will will will develop develop develop procedures procedures to to address address address hiring hiring employees employees employees with with the the HAHAVAVAA 

funds, funds, certification, certification, file file management management and and the the maintenance maintenance of of supporting supporting

documentation documentation relative relative to to pawoll payroll payroll costs. costs.

Due Due Date: Date: January January 31, 31, 31,2014 2014

Person Person Responsible: Responsible: Deputy Deputy Supervisor Supervisor of of Elections Elections

Recommendation Recommendation Recommendation No. No.2 No.2 2

The The Election Election System System ofthe of of the the Virgin Virgin Islands Islands (ESVI) (ESVI) concurs. concurs. concurs. 

Action Action Plan: Plan: once Once Once anan employee employee isis hired, hired, hired, certification certification of payroll payroll payroll will will will bebe implemented implemented tototo ensure ensure 

compliance compliance with with the the HAVA HAVV AA program. program.

Due Due Due Date: Date: Date: January January January 31, 31, 31, 2014 2014 2014 

Person Person Person Responsible: Responsible: Responsible: Deputy Deputy Deputy Supervisor Supervisor Supervisor of ofElections Elections Elections 
APPENDIX A-1

Recommendation Recommendation No. No.33 

The The Election Election System System of ofthe ofthe the Virgin Virgin Islands Islands (ESVI) (ESVI) concurs. concurs.

Action Action Plan: Plan: 	 ESVI ESVI will will will obtain obtain and and naintain maintain maintain aa copy copy of the the Property Property && Procurement Procurement Procurement and and the the 

federal federal guidelines guidelines onon small small purchases. purchases. purchases. ESVI ESVI will will will inform inform all all employees employees of of the the 

procedures procedures procedures and and ensure ensure these these guidelines guidelines are are adhered adhered toto for for all all small small purchases. purchases. purchases. 

ESVI ESVI will will will institute institute aaa management management management quality quality control control check check byby reviewing reviewing all all 

purchases purchases purchases requests requests monthly. monthly. 

Due Due Date: Date: October October 30, 30, 2013 2013

Person Person Responsible: Responsible: Deputy Deputy Supervisor Supervisor of of Elections Elections

monthlY. 

Recommendation Recommendation NO.4 No. 4 

The The Election Election System System of of ofthe the the Virgin Virgin Islands Islands (ESVI) (ESVI) concurs.

Action Action Plan: 	 Plan: ESVI ESVI will will develop develop internal internal fiscal fiscal control control measures measures and and adhere adhere to to

the the Department Department of of Finance Finance regulations regulations on on purchase purchase orders. orders. ESVI ESVI will will

ensure ensure all all documentation documentation is is attached attached with with requests, requests, i.e. i.e. receipts, receipts, invoice, invoice,

and and and approved approved approved contract contract contract with with signature signature signature page. page. page. Files Files Files will will will be be maintained maintained asas as per per per

intemal 

HAVV AA guidelines. guidelines. guidelines. ESVI ESVI ESVI will will will conduct conduct conduct quarterly quarterly quarterly inspection. inspection. inspection.

Due Due Due Date: Date: Date: November November November 30, 30, 30, 2013 2013

Person Person Responsible: Responsible: Responsible: Deputy Deputy Supervisor Supervisor Supervisor & & Administrative Administrative Assistant Assistant Assistant

HAVA 

Recommendation Recommendation No.5 No. 5 

The The The Election Election System System ofthe ofthe ofthe Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs.

Action Action Plan: Plan: 	 Plan: ESVI ESVI ESVI will will will complete complete complete FY FY 2012 2012 2012 Federal Federal Federal Financial Financial Financial Report Report Report and and and follow follow the the the HAVAVA 

scheduled scheduled scheduled reporting reporting periods. periods. periods.

HAVA 

Due Due Due Date: Date: Date: November November November 1, 1, 1,2013 2013

Person Person Person Responsible: Responsible: Responsible: Deputy Deputy Deputy Supervisor Supervisor Supervisor && & Supervisor Supervisor Supervisor of of ofElections Elections

Recommendation Recommendation Recommendation No.6 No. 6 

The The The Election Election Election System System System of of of the the the Virgin Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs.
APPENDIX A-1

Action Action ActionPlan: Plan: Plan: a of EAC M arch 20,200'1 ­ ESVI ESVI ESVI has has has obtained obtained obtainedaa copy copy copy ofEAC ofEAC Advisory Advisory Advisory 07-002 07-002 07-002 dated dated datedMarch March 20, 20, 2007 2007 -­

"Program "Program "ProgramIncome Income Income and and and Set Set -off -off of of ofCost Cost CostIncident Incident toto to Program Program ProgramIncome" Income" Income" and and andwill will will

accurately accurately accurately determine determine determine the the thetotal total total amount amount amount of of of unreported unreported unreportedprogram program program income income income going going going

forward. forward. forward. ESVI ESVI ESVI will will will obtain obtain obtain all all all bank bank bank statements statements statements for for for FYFY FY2012 2012 2012toto todetermine determine determine the the the

Set-off lncident 

amount amount amount of of of program program program income income income collected collected collected and and and then then thencomplete complete complete the the the HAIIAVA VAA Report. Repo(. 

Henceforth, Henceforth, Henceforth, ESVI ESVI ESVI will will will comply comply comply with with with HAVV AA requirements requirements requirements and and and submit submit submit timely timely timely

Reports. Reports. Reports.

HAVA 

Due Due Due Date: Date: I)ate: December December December 1,2013 1,2013

Person Person Person Responsible: Responsible: Responsible: Supervisor Supervisor Supervisor of of of Elections Elections Elections

Recommendation Recommendation Recommendation No.7 No.7 No. 7

The The The Election Election Election System System System of of ofthethe the Virgin Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs.

Action Action Action Plan: Plan: 	 Plan: ESVI ESVI ESVI will will will review review review and and and amend amend amend the the the Federal Federal Federal Financial Financial Financial Reports Reports Reports from from from FYFY FY 2003- 2003­ 2003-

2011 2011 toto to include include include program program program income income income asas as applicable. applicable. applicable. ESVI ESVI ESVI will will will obtain obtain obtain copies copies copies of of all all 

relevant relevant relevant financial financial financial reports, reports, reports, and and and bank bank bank statements statements statements toto to assist assist assist inin in the the the preparation preparation preparation of of of

201 I 	 ofall 

these these these reports. reports. reports. ESVI ESVI ESVI will will will coordinate coordinate coordinate with with with the the the HAVV AA point point point of of of contact contact contact toto to

receive receive receive any any any additional additional additional guidance guidance guidance onon on the the way way forward. forward. forward. ESVI ESVI ESVI will will will submit submit submit

HAVA 

corrected corrected corrected FY FY 03- 03-FY FYFY 1111 1 I reports reports reports once once once this this this process process isis is completed. completed. completed.

Due Due Date: Date: Date: August August August 31, 31, 31,2014 2014 2014 

Person Person Responsible: Responsible: Supervisor Supervisor of of Elections Elections

Recommendation Recommendation No. No.8 No.8 8

The The Election Election System System of the the Virgin Virgin Islands Islands (ESVI) (ESVI) concurs. concurs. concurs. 

Action Action Plan: Plan: 	 ESVI ESVI will will will obtain obtain copies copies ofthe ofthe interest interest interest earned earned financial financial reports reports reports from from the the 

Department Department Department of Finance Finance and and the the current current current bank bank statement statement from from First First First Bank Bank tototo 

verify verify verify the the the amount amount amount of offunds funds funds applicable applicable applicable tototo this this this report. report. report. ESVI ESVI ESVI will will will 

prepare prepare prepare the the the FYFYFY 2012 2012 report report tototo reflect reflect reflect program program program income. income. income. ESVI ESVI ESVI will will will ensure ensure ensure 

program program program income income income isisis reported reported reported accurately accurately accurately ononon all all all reports reports reports going going going forward. forward. forward. 

of the eamed 

Due Due Due Date: Date: Date: November November November 15,2013 15,2013 15,2013 

Person Person Person Responsible: Responsible: Responsible: Deputy Deputy Deputy Supervisor Supervisor Supervisor &&& Supervisor Supervisor Supervisor 

Recommendation Recommendation Recommendation No. No.9 No.9 9

The The The Election Election Election System System System of ofthe the the Virgin Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs. 
APPENDIX A-1

Action Action Action Plan: Plan: Plan: ESVI ESVI ESVI will will will work work work with with with the the the HAHA HAVAVAVA Point Point Point of of of Contact Contact Contact toto to resolve resolve resolve the the the unreported unreported unreported

program program program income income income of of of $113,345. $113,345. ESVI ESVI ESVI will will will conduct conduct conduct extensive extensive extensive research, research, research, review review review

and and and reconcile reconcile reconcile the the the unreported unreported unreported program program program income. income. income. Next Next Next step, step, step, ESVI ESVI ESVI will will will prepare prepare prepare

and and and submit submit submit the the the reports reports reports with with with the the the accurate accurate accurate amount amount amount of of of program program program income. income. income.

$ I 13,345. 

Due Due Due Date: Date: Date:June June Jlur:re 22, 22, 22.2014 2014 2014 

Person Person Person Responsible: Responsible: Responsible: Deputy Deputy Deputy Supervisor Supervisor Supervisor && & Supervisor Supervisor Supervisor

Recommendation Recommendation Recommendation No. No. No. 1010 l0

The The The Election Election Election System System System of of ofthethe the Virgin Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs.

Action Action Action Plan: Plan: Plan: ESVI ESVI ESVI will will will purchase purchase purchase QuickBooks QuickBooks QuickBooks software software software and and and install install install the the the program program the the the program program

onon on the the the server server server toto to provide provide provide accessibility accessibility accessibility toto to all all all employees. employees. employees. ESVI ESVI ESVI will will will utilize utilize utilize the the the

Enterprise Enterprise Enterprise Resource Resource Resource Plarming Plarming Planning module module module which which which isis is hosted hosted hosted byby by the the the Department Department Department of of of

Finance Finance Finance toto to track track track HAFIAVAVV AA and and and the the the Election Election Election System System System funds. funds. funds. ESVI ESVI ESVI will will will segregate segregate segregate the the the

roles roles roles and and and responsibilities responsibilities responsibilities relevant relevant relevant toto to the the the receipt receipt receipt and and and processing processing processing of of of cash. cash. cash. ESVI ESVI ESVI will will will

establish establish establish adequate adequate adequate controls controls controls for for for the the the processing processing processing of of of cashier cashier cashier receipts receipts receipts and and and deposit deposit deposit slips. slips. slips.

ESVI ESVI ESVI will will will maintain maintain maintain the the the applicable applicable applicable files files files and and and reports reports reports and and and conduct conduct conduct monthly, monthly, monthly,

quarterly quarterly quarterly and and and armual armual arnual reviews. reviews. reviews. ESVI ESVI ESVI will will will develop develop develop internal internal intemal fiscal fiscal fiscal control control control measures measures

to to ensure ensure ensure this this this deficiency deficiency deficiencv isis is not not not repeated. repeated. reneated.

Due Due Due Date: Date: Date: December December December 31, 31, 31, 2013 2013 2013

Person Person Responsible: Responsible: Supervisor Supervisor of of Elections Elections

Recommendation Recommendation No. No. No. IIIl 

The The Election Election System System of of ofthethe the Virgin Virgin Islands Islands (ESVI) (ESVI) concurs. concurs.

Action Action Plan: Plan: Plan: ESVI ESVI will will will obtain obtain aa copy copy ofthe ofthe September September Bank Bank Statement Statement and and begin begin the the process process process 

ofdepositing of of depositing depositing all all program program income income into into the the Election Election Fund Fund Account. Account. Account. ESVI ESVI will will will 

develop develop procedures procedures procedures toto ensure ensure this this process process process isis implemented implemented and and followed followed ininin the the 

future. future. ESVI ESVI will will will review review bank bank statement statement monthly monthly and and prepare prepare aaa quarterly quarterly report report report 

for for the the Joint Joint Joint Board Board toto review. review. review. 

Due Due Date: Date: Date: October October 30. 30, 30, 2013 2013 

Person Person Person Responsible: Responsible: Responsible: Deputy Deputy Deputy Supervisor Supervisor Supervisor and and and Election Election Election Assistant Assistant Assistant 
APPENDIX A-1

Recommendation Recommendation Recommendation No. No. No. 1212 I 2

The The The Election Election Election System System System of of of the the the Virgin Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs.

Action Action Action Plan: Plan: 	 Plan: ESVI ESVI ESVI will will will immediately immediately immediately cease cease cease depositing depositing depositing HAHAVAVV AA related related related fees fees fees into into into the the the Imprest Imprest Imprest

Fund Fund Fund Checking Checking Checking Account. Account. Account. ESVI ESVI ESVI will will will develop develop develop procedures procedures procedures toto to establish establish establish

proper proper proper protocol protocol protocol inin in designating designating designating distinct distinct distinct funding funding funding accounts. accounts. accounts. ESVI ESVI ESVI will will will conduct conduct conduct

monthly monthly monthly reviews reviews reviews and and and reconciliations. reconciliations. reconciliations.

Due Due Due Date: Date: Date: October October October 15, 15, 15,2013 2013 2013 

Person Person Person Responsible: Responsible: Responsible: Supervisor Supervisor Supervisor of of of Elections Elections Elections

Recommendation Recommendation Recommendation No. No. No. 1313 l3

The The The Election Election Election System System System of of of the the the Virgin Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs.

Action Action Action Plan: Plan: 	 Plan: ESVI ESVI ESVI will will will discuss discuss discuss at at at the the the Joint Joint Joint Board Board Board meeting meeting meeting scheduled scheduled scheduled for for for 3'd3'd 3'd October October October the the the

requirement requirement requirement and and and importance importance importance of of of establishing establishing establishing safeguards safeguards safeguards toto to mitigate mitigate mitigate the the the

potential potential potential fraudulent fraudulent fraudulent use use use of of of the the the Imprest Imprest Imprest Fund. Fund. Fund.

The The The Joint Joint Joint Board Board Board members members members needs needs needs to to prepare prepare aa a proposal proposal proposal to to the the the 30 Legislature thth Legislature Legislature 

to to amend amend amend Title Title Title 3333 33 of of of Virgin Virgin Islands Islands Islands Code Code Code to to have have this this this law law changed. changed. changed.

Once Once Once the the proposal proposal proposal isis is submitted submitted submitted to to the the Legislature, Legislature, Legislature, ESVI ESVI ESVI will will will follow follow upup up with with

the the Legislative Legislative Legislative Branch Branch until until until this this this law law isis is amended. amended. amended. Effective Effective Effective immediately, immediately, immediately,

ESVI ESVI ESVI will will will require require two two signatures, signatures, signatures, aa a Board Board Chair Chair Chair and and and the the Supervisor, Supervisor, Supervisor, prior prior prior toto to

30s 

the the withdrawal withdrawal rvithdrawal of of of any any any funds funds funds from from the the Imprest Imprest Imprest Account. Account. Account.

Due Due Date: Date: January January 1, l, 2015 2015

Person Person Responsible: Responsible: Joint Joint Board Board Chair Chair

Recommendation Recommendation No. No. 1414 I 4

The The Election Election System System of the the Virgin Virgin Islands Islands (ESVI) (ESVI) partially partially concurs. concurs. concurs. Last Last Last inventory inventory was was 

conducted conducted onon March March 5, 5, 2008 2008 byby Property Property and and Procurement. Procurement. Procurement. 

Action Action Plan: Plan: 	 ESVI ESVI will will will develop develop procedures procedures procedures for for receiving, receiving, receiving, inventorying, inventorying, inventorying, storage storage and and 

disposal disposal disposal of of local local local and and federal federal government government propefty, property, property, tototo gain gain control control of of of 

and and account account for for all all equipment. equipment. equipment. ESVI ESVI ESVI will will will conduct conduct conduct aaa physical physical physical inventory inventory of of of 

all all ESVI ESVI equipment equipment onon both both islands. islands. islands. ESVI ESVI will will will establish establish protocols protocols protocols for for for 

conducting conducting conducting periodic periodic periodic inventory inventory inventory going going going forward. forward. forward. 

Due Due Due Date: Date: Date: June June June 30" 30, 30, 2014 2014 2014 
APPENDIX A-1

Person Person Responsible: Responsible:Deputy DeputySupervisor Supervisorof of of Elections Elections Person 

Recommendalion Recommendation Recommendation No. No. No. I5 15

The The Election Election System System System of of the the Virgin VirginIslands Islands Islands (ESVI) (ESVl) (ESVl) concurs' concurs. The Election ofthe 

Action ActionPlan: Plan: Plan: 	ESVI ESVl ESVl will willconduct conductphysical physicalinventories inventoriesbiennially bienniallyand andreconcile reconciletotoproperty property

records. records. records. 

Due Due Date: Date: Date: December December December 31, 31, 2015 2015 

Person Person Responsible: Responsible: Responsible: Deputy Deputy Deputy Supervisor SupervisorofofElections Elections Elections 

Due 	 31.2015 

Person 

Recommendation Recommendation No. No. No. 16 Re commendation I6
 

The The The Election Election Election System System System ofthe of of the the Virgin Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs'
 concurs. concurs. 

Action Action Action Plan: Plan: Plan: 	 ESVI ESVI ESVI will will will obtain obtain obtain aa copy copy copy of of the the federal federal federal guidelines guidelines guidelines ononon disposal disposal disposal of ofequipment equipment equipment 

and and adhere adhere toto the the guidelines guidelines going going forward. forward. ESVI ESVI will will review review documentation documentation 

a ofthe 

andadheretotheguidelinesgoingforward.Esvlwillreviewdocumentation 

of of previously previously disposed disposed equipment, equipment, annotate annotate accordingly accordingly and and maintain maintain ofpreviously equipment' 
 the the the


relivant ESVI ESVI will will prepare prepare reports reports on on disposed disposed equipment, equipment, ififif applicable. applicable.
 files. relevant relevant files. gSVt equipment' applicable' 

Due Due Due 	Date: Date: Date: November November November 15,2013 15, 2013 

Person Person Responsible: Responsible: Responsible: Deputy Deputy Deputy Supervisor Supervisor Supervisor and and and Administrative Administrative Administrative Assistant Assistant Person 

Recommendation Recommendation Recommendation No. No. No. 
1717

The The Election Election Election System System System of of of (ESVI) concurs'
 the the the Virgin Virgin Virgin Islands Islands Islands (ESVl) (ESVl) concurs. The 


Action Action Action Plan: Plan: 	 Plan: ESVI ESVI ESVI will will will remind remind remind the the the Government Government Govemment
of of of the the the Virgin Virgin Virgin Islands Islands Islands of of of the the the requirement requirement requirement

toto comply comply comply with with withHAVA HAVA HAVA 254(a) 254(a) (7). (7). ESVI ESVI ESVI will will will ensure ensure ensure the the theAnnual Annual Annual Budget Budget Budget

report report report addresses addresses this this this federal federal federal mandate mandate mandate and and anditit itisis isconstantly constantly constantly onon on the the the forefront forefront forefront

to 	 25a@) Q)' 

ad'dresses 

Offrce & when when wfien briefing briefing briefing the the theLegislature. Legislature. Legislature. ESVI ESVI ESVI will will will inform inform inform the the theOffice Office of of ofManagement Management Management&

of this law' Budget Budget Budget and and andDepartment Department Department of of ofFinance Finance Financeofthis ofthis HAVA HAVA HAVA funding funding funding law. law. 

Due Due Date: Date: Date: January Due 
 January January 1,2014 1,2014

Person Person person 
Responsible: Responsible: Responsible:The The TheLegislature, Legislature, Legislature,Joint Joint JointBoard, Board, Board,and and andSupervisor Supervisor Supervisorof of ofElections Elections Elections

Recommendation Recommendation No. No. 18 Recommendation No. l8 
APPENDIX A-1

The The The Election Election System System of of ofthe 	 the the Virgin Virgin Islands Islands Islands (ESVl) (ESVl) (ESVI) concurs. concurs. concurs.

Action Action Plan: Plan: Plan: ESVI ESVI ESVI will will will address address address the the deficiencies deficiencies deficiencies with with our our our designated designated designated Election Election Assistance Assistance

Commission Commission Commission representative representative once once once the the final final final report report report isis is received. received. received. ESVI's ESVI's ESVI's goal goal goal isis is

to to correct correct correct the the deficiencies deficiencies deficiencies and and and not not not have have any any repeated repeated deficiencies. deficiencies. deficiencies.

Due Due Date: Date: Date: March March 31, 31, 31, 2014 2014

Person Person Responsible: Responsible: Responsible: Supervisor Supervisor Supervisor of of of Elections Elections Elections

Recommendation Recommendation No. No. No. 1919 19

The The The Election Election System System of of the the Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs.

Action Action Plan: Plan: 	 Plan: ESVI ESVI ESVI will will will adhere adhere adhere to to administrative administrative administrative complaint complaint complaint procedures procedures procedures inin in accordance accordance accordance with with

HAVA HAVA 402 402 (a). (a). (a). This This This policy policy isis is presently presently posted posted onon on our our our website; website; website; however, however, however, we we will will will

ensure ensure ensure the the citizens citizens citizens are are are aware, aware, aware, educated educated educated onon on itsits its use use and and and encourage encourage encourage the the utilizing utilizing of of of

ofthe 

this this this process. process. process. ESVI ESVI ESVI will will create create create or or or revise revise complaint complaint complaint forms forms forms to to establish establish establish the the proper proper proper

protocol protocol protocol use use of of of administrative administrative administrative complaints. complaints. complaints. ESVI ESVI ESVI will will will maintain maintain compliance compliance compliance with with

witl 

HAVV AA procedures procedures procedures and and and guidelines. guidelines. guidelines.

Due Due Due Date: Date: Date: November November November 30, 30, 30, 2013 2013 2013

Person Person Responsible: Responsible: Responsible: Supervisor Supervisor Supervisor of of of Elections Elections Elections

HAVA 

Recommendation Recommendation No. No. No. 20 20

The The The Election Election System System ofthe ofthe Virgin Virgin Islands Islands Islands (ESVI) (ESVI) (ESVI) concurs. concurs. concurs.

Action Action Plan: Plan: 	 Plan: ESVI ESVI ESVI will will will maintain maintain aa a complete complete complete complaint complaint complaint file file file that that that includes includes includes all all all complaints, complaints, complaints, at at at aa a

minimum, minimum, minimum, all all all responses, responses, responses, records records records of of of hearings hearings hearings and and and outcomes. outcomes. outcomes. ESVI ESVI ESVI will will will emphasize emphasize emphasize

the the the importance importance importance of of of this this this requirement requirement requirement to to all all all staff staff staff members, members, members, Board Board members members members and and and

of the 

election election election part-time part-time workers. workers. workers. ESVI ESVI ESVI will will will maintain maintain compliance compliance compliance with with HAHAVAVAA 

procedures procedures procedures and and and guidelines. guidelines. guidelines.

Due Due Due Date: Date: Date: November November November 30, 30, 2013 2013 

Person Person Responsible: Responsible: Responsible: Supervisor Supervisor Supervisor of of of Elections Elections Elections

30,2013 
APPENDIX A-1

GOVERNMENT GOVERNMENT GOVERNMENTOF OF 
 OF

THE THE THEVIRGIN VIRGIN VIRGINISLANDS ISLANDS ISLANDSOFOF OFTHE THE THEUNITED UNITED UNITEDSTATES STATES 
 STATES

-S.Ie*isn $1gxttm nf t\e Sirgin prlarlr 

••
 -__=e- P.O. P.O. P.O.Box Box Box1499· 1499· 1499. K,NGSHILL' K,NGSHILL' Knosrrrr. ST. ST. Sr. CROIX' CROIX' Cnorx. U.S. U.S. U.S.V,RG,N V,RG,N VIBGN ISLANDS ISLANDS lsLANDs 00851·1499 00851-l4gg 

P.O. P.O. P.O.Box Box Box6038 6038 6038. •• ST. ST. Sr. THOMAS' THOMAS' Trorars. U.S. U.S. U.S.VIRGIN VIRGIN Vrncn ISLANDS ISLANDS lsur.ros 00801·6038 00801-6038 

Mr. Mr. Mr.Curtis Curtis CurtisCrider Crider Crider

Inspector Inspector Inspector General General Ceneral

U.S. U.S. U.S.Election Election ElectionAssistance Assistance Assistance Conunission Conunission Commission

Office Office Office of of of Inspector Inspector Inspector General General General

1201 1201 120I New New New York York York Ave. Ave. Ave. NW- NW- Suite Suite Suit€300 300 300

Washington, Washington, Washington, DCDC DC 20005 20005 20005

September September September 27,2013 27,2013 27, 2013

Re: Re: Draft Draft I)raft Audit Audit Audit Report Report Report -

* Election Election Election System System System of of of the the the Virgin Virgin Virgin Islands Islands Islands Compliance Compliance Compliance with with with

the the thc Help Help Help America America America Vote Vote Vote Act Act Act of of of 2002 2002 2002

Report Report Report No. No. No. VI-RR-OIG-001-2013 VI-RR-OIG-001-2013 VI-RR-OIG-OO1-201 3

Dear Dear Inspector Inspector General General Crider: Crider:

As As As the the new new Supervisor Supervisor supervisor of of the the Elections Elections Systems Systems of of the the Virgin Virgin virgin Islands Islands Islards (ESVI) (ESVI) effective effective August August August 

19,2013, 19,2013, II have have reviewed reviewed the the audit audit report report report findings findings and and provided provided responses responses responses toto each each deficiency deficiency inin 19,2013,I findings:rnd ro 

order order tototo maintain maintain compliance compliance with with federal federal regulations. regulations. regulations. Enclosed Enclosed please please fmd fmd details details outlining outlining 

ESVI ESVI ESVI responses responses responses tototo your your your proposed proposed proposed corrective corrective corrective action. action. action. The The The ESVI ESVI ESVI agree agree agree with with with the the the conclusion conclusion conclusion and and and will will will 

work work work tototo minimize minimize minimize the the the impact impact impact of ofany any any future future future audit audit audit findings. findings. findings. 

find 

'rhe The The Election Election Election System System System ofthe of of the the virgin Virgin Virgin Islands Islands Islands isisis dedicated dedicated dedicated tototo upholding upholding upholding ananan effective effective effective system system system of of of 

compliance compliance compliance concerning concerning the the the administration administration administration ofthe the HAHA VAVA funds, funds, funds, and and and tototo working working diligently diligently diligently tototo 

improving improving improving our our our operations. operations. operations. ESVI ESVI ESVI also also also are are are thankful thankful thankful for for for thethe the professional professional professional manner manner manner ininin which which which you you you and and 

conceming ofthe HAVA u.orking 

and 

your your your staffconducted staff staff conducted conducted thethe the review, review, review, thethe the granting granting granting ofan of of anan extension, extension, extension, and and and your your your readiness readiness readiness tototo share share share best best

Dractlces. practices. practices. 

Ttr: 773 1021 T~L: T~L: (340) (340) (340) 773·1021 773·1021 . - Fnx: FAx: FAx: (340) (340) (340) 773-4523 773-4523 773-4523 
APPENDIX A-1

IfIf Ifyou you you have have any any any questions questions questions or or or comments comments comments regarding regarding our our our response response to to the the audit audit audit report, report, report, please please contact contact

the the undersigned undersigned undersisned at at at 340-773-1021. 340-773-1021.

Sincerely, Sincerely. 

'1 	 ,4 t ,-1 / ../ 

'., 'e6(,t ,Je. .n 

Caroline Caroline Caroline F. F. F. Fawkes Fawkes Fawkes

Supervisor Supervisor Supervisor -- Election Election System System of of ofthe the the VI VI

Enclosure Enclosure Enclosure

Cc: Cc: 	 Cc: Ms. Ms. Ms. Alecia Alecia M. M. M. Wells, Wells, Wells, Joint Joint Joint Chairperson Chairperson Chairperson

Mr. Mr. Mr. Arturo Arturo Watlington, Watlington, Watlington, Jr. Jr. Jr. STT-STJ STT-STJ STT-STJ District District District Chairperson Chairperson Chairpenon

Mr. Mr. Mr. Adelbert Adelbert Adelbert M. M. M. Bryan, Bryan, Bryan, SIX SIX STX District District District Chairperson Chairperson
APPENDIX A-2

EAC EAC RESPONSE RESPONSE TOTO THE THE DRAFT DRAFT AUDIT: AUDIT:

OIG OIG Performance Performance Audit Audit Report Report onon the the Administration Administration of of 

Payments Payments Received Received Under Under the the Help Help America America Vote Vote Act Act byby the the 

Election Election System System of of the the Virgin Virgin Islands,, for for the the Period Period 

September September 2003 2003 through through December December 2007 2007. .

October October 29,, 2013 2013 

MEMORANDUM MEMORANDUM 

To: : Curtis Curtis Crider Crider 


Inspector Inspector General General 


From:: 	 Alice Alice P.. Miller,, chiefMJtinrli.OclOfficer fficer && 

Acting Acting Executive Executive f~f~ _.. .

Subject: Subject: 	 Draft Draft Performance Performance Audit Audit Report Report - "Administration Administration of of Payments Payments 

Received Received Under Under the the Help Help America America Vote Vote Act Act byby the the Election Election System System 

of of the the Virgin Virgin Islands"" 

Thank Thank you you for for this this opportunity opportunity toto review review and and respond respond to to the the draft draft audit audit report report for for

the the Election Election System System of of the the Virgin Virgin Islands Islands (ESVI). .

The The Election Election Assistance Assistance Commission Commission (EAC) (EAC) will will work work with with the the (ESVI) (ESVI) to to ensure ensure

appropriate appropriate corrective corrective action action. .
 

 

 

 

 

 

Help to ensure efficient, effective, and transparent EAC operations and OIG’s Mission 

programs 

Obtaining Copies 

of OIG Reports 

Copies of OIG reports are available on the OIG website, 

www.eac.gov/inspector_general/ 

Copies of OIG reports can be requested by e-mail: (eacoig@eac.gov). 

Mail orders should be sent to: 

U.S. Election Assistance Commission
 

Office of Inspector General
 

1335 East West Highway - Suite 4300
 

Silver Spring, MD 20910 

To order by phone: Voice: (301) 734-3104 

Fax: (301) 734-3115 

To Report Fraud, Waste 

and Abuse Involving the 

U.S. Election Assistance 

Commission or Help 

America Vote Act Funds 

By Mail: U.S. Election Assistance Commission 

Office of Inspector General 

1335 East West Highway - Suite 4300 

Silver Spring, MD 20910 

E-mail: eacoig@eac.gov 

OIG Hotline: 866-552-0004 (toll free)
 

On-Line Complaint Form: www.eac.gov/inspector_general/
 

FAX: (301)-734-3115