UNITED STATES

ELECTION ASSISTANCE COMMISSION

OFFICE OF INSPECTOR GENERAL

Administration of Payments Received 

Under the Help America Vote Act by 

the New Mexico Secretary of State

Report No. E-HP-NM-12-20
Find us here: EAC OIG Website

Toll free: 1- 866-552-0004 | e-mail: eacoig@eac.gov

Memorandum 

To: Mona Harrington

Executive Director

From: Patricia L. Layfield

Inspector General

Date: January 6, 2021

Subject: Final Performance Audit Report - Administration of Payments Received Under the 

Help America Vote Act by the New Mexico Secretary of State (Assignment Number EHP-NM-12-20) 

The Office of Inspector General (OIG) engaged McBride, Lock & Associates, LLC (MLA), an 

independent certified public accounting firm, to audit the administration of payments received 

under the Help America Vote Act (HAVA) by the New Mexico Secretary of State (NMSOS). The 

audit scope covered the grant funds received and disbursed by the NMSOS, from June 11, 2018 

through September 30, 2019. The $3.7 million in funds paid to the NMSOS represented New 

Mexico’s share of the appropriation of $380 million under the Consolidated Appropriations Act

of 2018 (P.L. 115-151). NMSOS expended approximately $2.7 million of those grant funds 

during the period covered by the audit.

Results of Audit 

Based on the audit procedures performed, except for the matters discussed below, MLA

concluded that the Office accounted for and expended the HAVA funds in accordance with the 

requirements mentioned above, properly accounted for and controlled property purchased, and 

used the funds in a manner consistent with the budget plan for the period from June 11, 2018 

through September 30, 2019. However, the following exceptions were identified:

1. As noted in the two most recent Single Audit reports of the New Mexico Secretary of 

State’s Office (Office) for the years ended June 30, 2019 and 2018, the Office has not 

been performing periodic physical inventories of fixed assets (items costing $5,000 or 

more with a useful life of more than one year). 

OFFICE OF THE INSPECTOR GENERAL

US ELECTION ASSISTANCE COMMISSION

633 3RD STREET, NW, SUITE 200

WASHINGTON, DC 20001
2 

2. Program income reported on the Federal Financial Reports (FFR) for the federal fiscal 

years ended September 30, 2019 and 2018 did not agree to the general ledgers 

provided by the Office. Interest earned for the months of August 2019, July 2019 and 

June 2018 totaling $21,805 was not included in the program income reported on the 

Federal Financial Reports (FFRs). 

NMSOS generally agreed with the report’s findings and recommendations. The EAC responded 

that they are reviewing the NMSOS planned actions. The NMSOS’ complete response is included 

as Appendix A-1 and the EAC’s complete response as Appendix A-2.

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 March 15, 2021. Your response should include 

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

responsible for implementation.

Evaluation of Brown’s Audit Performance 

To fulfill our responsibilities under Government Auditing Standards, the Office of Inspector 

General:

• Reviewed MLA's approach and planning of the audit;

• Evaluated the qualifications and independence of the auditors;

• Monitored the progress of the audit at key points;

• Reviewed MLA’s audit report, to ensure compliance with Government Auditing Standards; 

and

• Coordinated issuance of the audit report.

MLA is responsible for the attached auditor’s report and the findings and conclusions 

expressed in the report. The work the EAC OIG performed in evaluating MLA’s conduct of the 

audit was not sufficient to support an opinion on the effectiveness of internal control or 

compliance with laws and regulations, thus EAC OIG does not express any opinion on EAC’s 

internal controls or compliance.

The Inspector General Act of 1978, as amended, requires semiannual reporting to Congress on 

all reports issued, actions taken to implement recommendations, and recommendations that 

have not been implemented. Therefore, we will report the issuance of this audit report in our 

next semiannual report to Congress. The distribution of this report is not restricted and copies 

are available for public inspection. Pursuant to the IG Empowerment Act of 2016, the EAC OIG 

will post this audit report on the OIG website within 3 days of its issuance to EAC management. 

The OIG will also post the report to Oversight.gov.

If you have any questions regarding this report, please call me at (202) 853-2760.
3 

cc: Commissioner Benjamin W. Hovland, Chair

Commissioner Donald L. Palmer, Vice-Chair

Commissioner Thomas Hicks

Commissioner Christy McCormick

The Honorable Maggie Toulouse Oliver, New Mexico Secretary of State

Sharon Pino, Deputy Secretary of State

Veronica Albin, Chief Financial Officer, Office of the New Mexico Secretary of State

Attachment 
McBRIDE, LOCK & ASSOCIATES, LLC

Certified Public Accountants

Established 1980

Performance Audit Report

Administration of Election Security Payments Received Under the Help 

America Vote Act by the New Mexico Secretary of State

Prepared for

The United States Election Assistance Commission (EAC) 

Office of Inspector General

By 

McBride, Lock & Associates, LLC

November 2020

4151 N. Mulberry Drive, Suite 275

Kansas City, Missouri 64116

p. 816-221-4559

f. 816-221-4563

admin@mcbridelock.com

www.mcbridelock.com
Performance Audit Report

Administration of Election Security Payments Received Under the Help 

America Vote Act by the New Mexico Secretary of State

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY 1 

BACKGROUND 2 

AUDIT OBJECTIVES 3 

SCOPE AND METHODOLOGY 3 

AUDIT RESULTS 5 

APPENDICES:

Appendix A-1: Response of the New Mexico Secretary of State to the Draft Report

Appendix A-2: Response of the U.S. Election Assistance Commission

to the Draft Report 

Appendix B: Audit Scope and Methodology 

Appendix C: Expenditures by Budget Category and Program Category 

Appendix D: Monetary Impact as of September 30, 2019 
1 

U.S. Election Assistance Commission

Performance Audit Report

Administration of Election Security Payments Received Under the Help 

America Vote Act by the New Mexico Secretary of State

EXECUTIVE SUMMARY

McBride, Lock & Associates, LLC was engaged by the United States Election Assistance 

Commission (EAC) Office of the Inspector General to conduct a performance audit of the election 

security funds the New Mexico Secretary of State’s Office (Office) received between June 11, 

2018 and September 30, 2019. The objective of the audit was to determine whether the Office used 

payments authorized by Sections 101 of the Help America Vote Act of 2002 (the HAVA) in 

accordance with HAVA and applicable requirements; properly accounted for and controlled the 

funds and property purchased with HAVA payments; and, used the funds in a manner consistent 

with the budget plans provided to EAC. 

In addition, the Commission requires states to comply with certain financial management 

requirements, specifically: 

• Expend payments in accordance with Federal cost principles established by the Office of 

Management and Budget (OMB) – (2 CFR 200). 

• Submit detailed annual financial reports on the use of Title I payments. 

• Maintain documents and records subject to audit to determine whether payments were used 

in compliance with HAVA. 

 

We conducted this performance audit in accordance with Generally Accepted Government 

Auditing Standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained provides a reasonable basis 

for our findings and conclusions based on the audit objectives. 

Based on the audit procedures performed, except for the matters discussed below, we concluded 

that the Office generally accounted for and expended the Grant funds in accordance with the 

requirements mentioned above for the period from June 11, 2018 through September 30, 2019. 

The exceptions are as follows:

1. Physical inventory inspections of assets were not performed as required by state and federal 

regulations. Also, the Office’s listing of capital assets did not include 2 items purchased 

with election security funds and the listing included 26 items which were purchased with 

election security funds but were not identified as being federally funded on the listing. 

2. The Federal Financial Reports for the years ended September 30, 2019 and 2018 did not 

report all interest income that had been allocated to the election fund. 
2 

We have included in this report as Appendix A, the Secretary of State’s written response to the 

draft report. Such response has not been subjected to the audit procedures and, accordingly, we do 

not provide any form of assurance on the appropriateness of the response or the effectiveness of 

the corrective actions described therein.

BACKGROUND

The Help America Vote Act of 2002 (HAVA) created the U.S. Election Assistance Commission 

(Commission) to assist States and insular areas (hereinafter referred to as States) with improving 

the administration of federal elections and to provide funds to States to help implement these 

improvements. The Commission administers grants to States authorized by HAVA under Title I, 

as follows: 

• Title I, Section 101 payments are for activities such as complying with Title III of HAVA 

for uniform and nondiscriminatory election technology and administration requirements;

improving the administration of elections for Federal office; educating voters; training 

election officials and poll workers; developing a state plan for requirements payments;

improving, acquiring, leasing, modifying, or replacing voting systems and methods for 

casting and counting votes; improving the accessibility and quantity of polling places; and 

establishing toll-free telephone hotlines that voters may use. 

The 2018 HAVA Election Security Grant also requires that states must: 

• Provide matching funds equal to 5 percent of the total federal funds within two years of the 

award to be spent for activities for which Election Security Grants are made.

• Maintain all federal funds and state cash matching funds in the state election fund, as 

described in Section 104 (d) of HAVA, along with interest earned on the award’s funds.

States may also track eligible funds/activities from their state and local general operating 

budgets to meet the match obligations. State and local funds used for match must be 

different from funds used to meet Maintenance of Effort or state match associated with 

HAVA Requirements Payments.

The Awardee – The New Mexico Secretary of State

The HAVA funds were awarded to the New Mexico Secretary of State (the Office). The mission 

of the Office of the Secretary of State is to administer elections and government ethics in 

accordance with state and federal law and to maintain and provide access to the laws, official acts, 

and other instruments vital to the efficient operation of statement government. 

The Secretary of State’s Bureau of Elections has a wide variety of responsibilities in administering 

elections in New Mexico, including: Certifying the official lists of candidates running for state 

offices; coordinating the tabulation of votes from each county on election night; producing election 

related rules; providing election data; producing voter registration forms and the ability for voters 
3 

to update or register to vote online or cancel an existing voter registration; and investigating 

complaints related to elections and ethics under New Mexico law.

Help America Vote Act State of New Mexico State Plan

The State of New Mexico’s HAVA budget letter was prepared by the Secretary of State. The main 

objectives of the project funded by HAVA, as set forth in the budget letter, were to expend a 

portion of the funding for immediate improvements prior to the 2018 General Election and then 

use the remainder over the five year grant period. A majority of the funds were to be used on 

initiatives that will directly benefit New Mexico counties with a focus on equipment and other 

improvements. 

AUDIT OBJECTIVES

The objectives of our audit were to determine whether the Office: 

1. Used funds for authorized purposes in accordance with Section 101 of HAVA and other 

applicable requirements; 

2. Properly accounted for and controlled property purchased with HAVA payments; and 

3. Used the funds in a manner consistent with the budget plan provided to EAC. 

In addition to accounting for Grant payments, the Grant requires states to maintain records that are 

consistent with sound accounting principles that fully disclose the amount and disposition of the 

payments, that identify the project costs financed with the payments and other sources, and that 

will facilitate an effective audit. The Commission requires states receiving Grant funds to comply 

with certain financial management requirements, specifically: 

• Expend payments in accordance with Federal cost principles established by the Office of 

Management and Budget (OMB) – (2 CFR 200). 

• Submit detailed annual financial reports on the use of Title I payments. 

• Maintain documents and records subject to audit to determine whether payments were used 

in compliance with HAVA.

SCOPE AND METHODOLOGY

We audited the Grant funds received and disbursed by the Office, from June 11, 2018 through 

September 30, 2019. These funds are related to the appropriation of $380 million under the 

Consolidated Appropriations Act (CAA), 2018 (P.L. 115-151). The scope of activity audited is 

shown in the following table: 
4 

Election

Description Security Funds

Funds Received from EAC $ 3,699,470

State Matching Funds - 

Program Income 109,685

Total Funds $ 3,809,155

Less Disbursements (1,107,747)

Fund Balance $ 2,701,408

The Office’s expenditures detailed by budget and program category are included as Appendix C. 

In planning and performing our audit, we identified the following internal control components and 

underlying internal control principles as significant to the audit objective: 

Objective Component Principle

1 Control Activities Selects and develops control activities

Selects and develops general controls over technology

Deploys through policies and procedures

Information and Communication Uses Relevant Information

Communicates Internally

2 Control Activities Selects and develops control activities

Selects and develops general controls over technology

Deploys through policies and procedures

Information and Communication Communicates Externally

3 Control Activities Selects and develops control activities

Selects and develops general controls over technology

Deploys through policies and procedures

We assessed the design, implementation, and operating effectiveness of these internal controls and 

identified deficiencies that we believe could affect the Office’s ability to use funds for authorized 

purposes and properly account for and control property. The internal control deficiencies we found 

are discussed in the Audit Results section of this report. 

Additionally, for the components and principles which we determined to be significant, we 

assessed the internal controls and compliance with laws and regulations necessary to satisfy the 

audit objective. 

However, because our review was limited to these internal control components and underlying 

principles, it may not have disclosed all internal control deficiencies that may have existed at the 

time of this audit.
5 

AUDIT RESULTS

We conducted this performance audit in accordance with Generally Accepted Government 

Auditing Standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained provides a reasonable basis 

for our findings and conclusions based on the audit objectives. 

Based on the audit procedures performed, except for the matters discussed below, we concluded 

that the Office accounted for and expended the HAVA funds in accordance with the requirements

mentioned above, properly accounted for and controlled property purchased, and used the funds 

in a manner consistent with the budget plan for the period from June 11, 2018 through September 

30, 2019. The exceptions to applicable compliance requirements are described below. 

Finding No. 1 – Recording and Tracking of Election Equipment

As noted in the two most recent Single Audit reports of the New Mexico Secretary of State’s Office

(Office) for the years ended June 30, 2019 and 2018, the Office has not been performing periodic 

physical inventories of fixed assets (items costing $5,000 or more with a useful life of more than 

one year). 

During our audit, we performed a comparison of invoices to the Office’s asset listing. Of the 173 

Image Case Evolution (ICE) tabulators purchased with election security grant funds, the serial 

numbers of two of the items purchased and delivered to Otero County were not included on the 

Office’s asset listing. The serial number of 26 items purchased were on the Office’s asset listing 

but were not identified as being HAVA funded in the “Funding Source” column. The ICE 

tabulators had a unit price of $7,300 each (the Office paid $4,300 each after discount). We selected 

two counties, which had a total of 81 of the 173 ICE tabulators, for viewing and found that all 

items were in the possession of the county and were adequately safeguarded. 

The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal 

Awards (Uniform Guidance) at 2 CFR 200.302(b) states that, “The financial management system 

of each non-Federal entity must provide for the following: ...(4) Effective control over, and 

accountability for, all funds, property, and other assets. The non-Federal entity must adequately 

safeguard all assets and assure that they are used solely for authorized purposes.” The State of New 

Mexico Department of Finance & Administration Manual of Model Accounting Practices, section 

FIN 6.6.D.1 states that, “State agencies shall perform a physical inventory of capital assets no later 

than the end of each fiscal year in compliance with the annual inventory statutory requirement for 

property and equipment.” FIN 6.7.D.3 states that, “State agencies shall maintain a record of all 

capital assets they own. The record shall contain at a minimum: i. Source of funding when 

applicable.”

The Office indicated that physical sightings of equipment from the listings have not been 

performed due to staffing issues. The inventory listing errors were inadvertent. The Office relied 

on the election equipment vendor and the counties receiving the equipment to report the serial 

number and asset tag identifier that was placed on each item as the items were sent directly to the 
6 

Counties. The HAVA funded purchases were made at the same time as other non-HAVA funded 

purchases from the same vendor. The Office verified with Otero County that the two units missing 

from the listing are in good working condition and they have been added to the listing.

Proper tracking and recording of property purchased with federal funds ensures that the equipment 

is being used and disposed of in accordance with federal regulations. 

Recommendation 

We recommend that the EAC address and resolve the following recommendation that the Office: 

 

1. conduct and document a physical inventory on at least a biannual basis in accordance with 

federal regulations and existing state policies, and 

2. implement procedures to ensure that all items purchased with federal funds are properly 

included and identified on the asset listing as being purchased with federal funds. 

Secretary of State Response: 

The Office agrees that this exception exists. The list that is maintained in Excel has been revised 

to include all tabulators purchased and identified as being federally funded. The Office has also 

purchased asset tags that are a different color than the standard asset tags to indicate equipment 

that has been purchased with federal funds. While it was the expectation that in fiscal year 2020 

the Contracts and Assets Manager and an IT Security Undergraduate Intern would have the 

opportunity to physically inspect and record the assets in each county, it was not an option to travel 

throughout the state during the COVID‐19 pandemic. It is planned to conduct a physical inventory 

to verify the location, condition, and ensure that machines are properly recorded and tagged with 

asset tags during fiscal year 2021. These efforts will be done under the direction of the Chief 

Financial Officer.

Auditor’s Response:

The proposed corrective actions, if implemented, would be sufficient to resolve the findings. 

Finding No. 2 – Financial Reporting of Interest Income

Program income reported on the Federal Financial Reports (FFR) for the federal fiscal years ended 

September 30, 2019 and 2018 did not agree to the general ledgers provided by the Office. Interest 

earned for the months of August 2019, July 2019 and June 2018 totaling $21,805 was not included 

in the program income reported on the FFR’s. 

The terms and conditions of the Election Security grant awards require the submission of an 

accurate and complete Federal Form 425 (Federal Financial Report) which reflect the uses of 

award funds and the interest and program income generated from those funds. HAVA Title IX, 

Section 902. AUDITS AND REPAYMENT OF FUNDS, Part (a) – Recordkeeping Requirement 

states, “Each recipient of a grant or other payment made under this Act shall keep such records 

with respect to the payment as are consistent with sound accounting principles, including records 
7 

which fully disclose the amount and disposition by such recipient of funds, the total cost of the 

project or undertaking for which such funds are used, and the amount of that portion of the cost of 

the project or undertaking supplied by other sources, and such other records as will facilitate an 

effective audit.”

The omission of the three months of interest was caused by confusion in identifying election fund 

activity between state and federal fiscal years when generating the pivot tables used by the Office 

to complete the FFRs. The State has a fiscal year ending June 30, while the FFRs are based on the 

federal government fiscal year end of September 30. 

Proper reporting of program income generated by federal funds ensures that the funds are tracked 

and spent in accordance with federal regulations. 

Recommendation

3. We recommend that the EAC require the Office perform a reconciliation of the grant 

activity to ensure that all program income earned is fully disclosed in the financial reports.

Secretary of State Response:

The Office agrees that this exception exists. As corrective action, the underreported interest income 

will be included in the fiscal year 2020 report. Further corrective action includes the creation of a 

job aid for running the financial system query to ensure it includes complete information and 

relevant budget periods. These corrections will be done under the direction of the Chief Financial 

Officer.

Auditor’s Response:

The proposed corrective actions, if implemented, would be sufficient to correct the finding. 

We provided a draft of our report to the appropriate individuals of the Office of the New Mexico

Secretary of State. We considered any comments received prior to finalizing this report.

The Office responded on December 11, 2020 and generally agreed with the report’s findings and 

recommendations. The EAC responded on December 17, 2020 and stated that they are reviewing 

the Office’s planned actions. The Office’s complete response is included as Appendix A-1 and the 

EAC’s complete response as Appendix A-2. 

McBride, Lock & Associates, LLC performed the related audit procedures between December 6, 

2019 and November 23, 2020. 

McBride, Lock & Associates, LLC

Kansas City, Missouri

November 23, 2020 
Appendix A-1 

Response of the New Mexico 

Secretary of State to the Draft Report
Via Electronic Transmission

December 11, 2020

Patricia L. Layfield, Inspector General

Office of the Inspector General

US Election Assistance Commission

633 3rd Street NW, Suite 200

Washington, DC 20001

Dear Ms. Layfield,

The New Mexico Secretary of State (the Office) has received the Performance Audit Report conducted 

by McBride, Lock & Associates on the funds received under the Help America Act Vote for the period of 

June 11, 2018 and September 30, 2019. The office acknowledges that there are two exceptions

identified, and addresses those findings here. 

1. Physical inventory inspections of assets were not performed as required by state and federal 

regulations. Also, the Office’s listing of capital assets did not include 2 items purchased with 

election security funds and the listing included 26 items which were purchased with election 

security funds but were not identified as being federally funded on the listing.

Response: The Office agrees that this exception exists. The list that is maintained in Excel has 

been revised to include all tabulators purchased and identified as being federally funded. The 

Office has also purchased asset tags that are a different color than the standard asset tags to 

indicate equipment that has been purchased with federal funds. While it was the expectation 

that in fiscal year 2020 the Contracts and Assets Manager and an IT Security Undergraduate 

Intern would have the opportunity to physically inspect and record the assets in each county, it

was not an option to travel throughout the state during the COVID‐19 pandemic. It is planned to 

conduct a physical inventory to verify the location, condition, and ensure that machines are 

properly recorded and tagged with asset tags during fiscal year 2021. These efforts will be done 

under the direction of the Chief Financial Officer.

2. The Federal Financial Reports for the years ended September 30, 2019 and 2018 did not report 

all interest income that had been allocated to the election fund.

Response: The Office agrees that this exception exists. As corrective action, the underreported 

interest income will be included in the fiscal year 2020 report. Further corrective action includes 

the creation of a job aid for running the financial system query to ensure it includes complete 

information and relevant budget periods. These corrections will be done under the direction of 

the Chief Financial Officer.
2 

Thank you for the opportunity to provide a response to these exceptions. Please contact me if there are 

questions or additional information is needed.

Sincerely,

Veronica Albin

Chief Financial Officer

Cc: McBride, Lock & Associates
APPENDIX A-2 

Response of the

U.S. Election Assistance Commission

to the Draft Report
U.S. ELECTION ASSISTANCE COMMISSION

633 3rd Street, NW Suite 200 

Washington, DC 20001 

TO: Patricia Layfield

 Inspector General

FROM: Mona Harrington 

Executive Director

DATE: December 17, 2020 

RE: Response to the Draft Performance Audit Report, Administration of 

Payments Received under the Help America Vote Act by the New Mexico 

Secretary of State 

Thank you for the opportunity to respond to the draft performance audit report of EAC’s 

grant funds to New Mexico. 

We appreciate the auditor’s findings and recommendations and are reviewing the New 

Mexico Secretary of State’s planned actions. The Secretary of State’s office expects to 

conduct a physical inventory of election equipment in 2021 and is making adjustments to 

its financial system queries to ensure data is accounted for in the correct budget period. 

With these actions, the findings in the draft report will be addressed and EAC can provide 

its final management decision to the OIG soon after the audit report is issued as final. 
11

Appendix B

AUDIT SCOPE AND METHODOLOGY

Our audit methodology included:

• Assessing audit risk and significance within the context of the audit objectives.

• Obtaining an understanding of internal control that is significant to the administration of 

the HAVA funds and of relevant information systems controls as applicable.

• Identifying sources of evidence and the amount and type of evidence required.

• Determining whether other auditors have conducted, or are conducting, audits of the 

program that could be relevant to the audit objectives.

As part of our audit, we gained an overall understanding of the internal control environment at the 

Office. Based on this understanding, we identified certain internal controls that we considered to 

be significant (or key controls) to achieving each objective. All components of internal control are 

relevant, but not all may be significant. Significance is defined as the relative importance of a 

matter within the context in which it is being considered, and is a matter of professional judgment. 

We made the following determination as to the significance of the underlying internal control 

principles:
12

1 2 3

Control Environment

1. Demonstrates Commitment to integrity and ethical values No No No

2. Exercises oversight responsibility No No No

3. Establishes structure, authority, and responsibility No No No

4. Demonstrates commitment to competence No No No

5. Enforces accountability. No No No

Risk Assessment 

6. Specifies suitable objectives No No No

7. Identifies and analyzes risk No No No

8. Assesses fraud risk No No No

9. Identifies and analyzes significant change No No No

Control Activities 

10. Selects and develops control activities Yes Yes Yes

11. Selects and develops general controls over technology Yes Yes Yes

12. Deploys through policies and procedures Yes Yes Yes

Information and Communication 

13. Uses relevant information Yes No No

14. Communicates internally Yes No No

15. Communicates externally No Yes No

Monitoring 

16. Conducts ongoing and/or separate evaluations No No No

17. Evaluates and communicates deficiencies No No No

Objective

The significance was determined as follows:

Objective 1: Control Activities and its underlying principles were deemed to be significant to our 

determination of the awardee’s compliance with the objective. The Control Activities component 

includes the design and implementation of specific tasks performed by individuals within the entity 

to fulfill their duties and responsibilities and to respond to identified risks. These principles address 

the design and implementation of activities related to management review, segregation of duties 

(including restriction of access with the information system), and documentation of internal 

controls and transactions. We determined these principles to be the most significant to the state’s 

proper use of funds and compliance with award requirements.

The Information and Communication principles of Use Relevant Information and Communicate 

Internally were deemed to be significant to our determination of the awardee’s compliance with 

the federal financial reporting portion of this objective. These principles address the quality of the 

information and the internal communication processes used to compile the data necessary to meet 

the state’s reporting objectives.
13

Objective 2: Control Activities and its underlying principles were deemed to be significant to our 

determination of the awardee’s compliance with the objective. The Control Activities component 

includes the design and implementation of specific tasks performed by individuals within the entity 

to fulfill their duties and responsibilities and to respond to identified risks. These principles address 

the design and implementation of activities related to management review, segregation of duties 

(including restriction of access with the information system), and documentation of internal 

controls and transactions. We determined these principles to be the most significant to the state’s 

proper accounting and control over equipment purchased with HAVA funds.

The Information and Communication principle of Communicate Externally was deemed to be 

significant to our determination of the awardee’s compliance with the objective because the state 

communicated with and relied on information from the equipment vendor and the counties where 

the equipment is located as part of the control system for accounting and controlling equipment 

purchased with HAVA funds.

Objective 3: Control Activities and its underlying principles were deemed to be significant to our 

determination of the awardee’s compliance with the objective. The Control Activities component 

includes the design and implementation of specific tasks performed by individuals within the entity 

to fulfill their duties and responsibilities and to respond to identified risks. These principles address 

the design and implementation of activities related to management review, segregation of duties 

(including restriction of access with the information system), and documentation of internal 

controls and transactions. We determined these principles to be the most significant to the state’s 

use of funds in a manner consistent with the plans provided to EAC.

To implement our audit methodology, below are some of the audit procedures we performed.

• Interviewed appropriate Office employees about the organization and operations of the 

HAVA program.

• Reviewed prior single audit reports and other reviews related to the State’s financial 

management systems and the HAVA program for the period under review.

• Reviewed policies, procedures and regulations for the Office management and accounting 

systems as they relate to the administration of the HAVA program.

• Tested major purchases and the supporting documentation.

• Tested randomly sampled payments made with HAVA funds.

• Evaluated compliance with the requirements for accumulating financial information 

reported to the Commission on the financial status reports and progress reports, accounting 

for property, purchasing HAVA related goods and services, and using funds in a manner 

consistent with the budget plan provided to EAC.

• Verified the establishment and maintenance of an election fund.

• Observed the physical security/safeguards of selected equipment purchased with HAVA

funds and ensure compliance with federal regulation.

• Verified whether the matching requirement was met and, if so, that matching expenditures 

met the prescribed criteria and allowability requirements of HAVA.

• Verified program income was properly accounted for and not remitted to the State’s 

general fund.
14

Appendix C

EXPENDITURES BY BUDGET CATEGORY AND PROGRAM CATEGORY

JUNE 11, 2018 TO SEPTEMBER 30, 2019

Budget Categories

Voting 

Equipment

Election 

Auditing

Voter 

Registration 

Systems

Cyber 

Security Communications

Other - 

Minority 

Language 

Outreach Total

Personnel (Including Fringe) $ - $ - $ - $ 151,601 $ - $ 69,014 $ 220,615

Equipment 753,021 - - 6,545 - - 759,566

Subgrants - - - - - - -

Training - - - - - - -

All Other Costs - - - 87,047 - 40,519 127,566

Total Direct Costs $ 753,021 $ - $ - $ 245,193 $ - $ 109,533 $ 1,107,747

Indirect Costs (if applied) - - - - - - -

Total Federal Expenditures $ 753,021 $ - $ - $ 245,193 $ - $ 109,533 $ 1,107,747

Non-Federal Match - - - - - - -

Total Program Expenditures $ 753,021 $ - $ - $ 245,193 $ - $ 109,533 $ 1,107,747

Program Categories
15

Appendix D

MONETARY IMPACT AS OF SEPTEMBER 30, 2019

Description

Questioned 

Costs

Unsupported 

Costs

Additional 

Funds for 

Program

None $ - $ - $ -

Total $ - $ - $ -
OIG’s Mission

Prevent fraud, waste, and abuse; promote economy and efficiency in EAC programs; and support the mission of the EAC by reporting on current performance and accountability and by fostering sound program 

management to help ensure effective government operations.

Obtain Copies 

of OIG Reports

Retrieve OIG reports on the OIG website, https://www.eac.gov/inspectorgeneral/

Request copies by e-mail to: eacoig@eac.gov

Send mail orders to:

U.S. Election Assistance Commission

Office of Inspector General

633 3rd Street, NW, Second Floor

Washington, DC 20001

To order by phone: Voice: 1-866-552-0004 

Report Fraud, 

Waste or Abuse 

Involving the EAC 

or Help America 

Act Funds

By mail : U.S. Election Assistance Commission

Office of Inspector General

633 3rd Street, NW, Second Floor

Washington, DC 20001

By e-mail: eacoig@eac.gov

OIG Hotline 866-552-0004 (toll free)

On-line 

Complaint Form https://www.eac.gov/inspector-general/file-acomplaint/
Inspector General 

U.S. Election Assistance Commission

This report, as well as other OIG reports and testimony, are available on the internet at: 

EAC OIG Reports Page