OFFICE OF INSPECTOR GENERAL

U.S. Election Assistance Commission

AUDIT OF THE HELP AMERICA VOTE ACT GRANTS 

AWARDED TO THE STATE OF DELAWARE

Report No. G22DE0010-22-06

September 21, 2022
HIGHLIGHTS

Report No. G22DE0010-22-06

What OIG Audited 

The Office of Inspector General, through the 

independent public accounting firm of McBride, Lock 

& Associates, LLC, audited funds received by the 

State of Delaware under the Help America Vote Act 

(HAVA), including state matching funds and interest 

earned, totaling $20 million. This included Election 

Security and Coronavirus Aid, Relief, and Economic 

Security (CARES) Act grants.

AUDIT OF THE HELP AMERICA VOTE 

ACT GRANTS AWARDED TO THE STATE 

OF DELAWARE

What OIG Recommended

The OIG made eight recommendations:

September 21, 2022

What OIG Found

The Office of Inspector General found that the 

Delaware Commissioner of Elections generally 

accounted for HAVA funds in accordance with 

applicable requirements and used the funds in a 

manner consistent with the informational plans 

submitted. 

However, the Commissioner’s office (1) provided 

inadequate documentation to support 14 

transactions resulting in $629,248 of unallowable 

costs; (2) did not provide required asset listings; (3) 

lacked complete internal control and asset 

management policies; and (4) has not filed required 

financial reports for the Section 251 funds since 2014 

and did not report interest income properly on the 

Election Security and CARES financial reports.

The objectives of the audit were to determine 

whether the State of Delaware: 

(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 funds in a manner consistent with the

informational plans provided to EAC.

Delaware also received $13 million in reissued 

Section 251 funds. The firm reviewed the state’s 

financial reporting efforts for these funds. 

U.S. Election Assistance Commission | Office of Inspector General
OFFICE OF INSPECTOR GENERAL

U.S. Election Assistance Commission

DATE: September 21, 2022

TO: U.S. Election Assistance Commission, Interim Executive Director, Mark Robbins

FROM: U.S. Election Assistance Commission, Inspector General, Brianna Schletz

SUBJECT: Audit of the Help America Vote Act Grants Awarded to the State of Delaware

(Report No. G22DE0010-22-06)

This memorandum transmits the final report on Help America Vote Act grants awarded to the 

state of Delaware. The Office of Inspector General contracted McBride, Lock & Associates, LLC, 

an independent certified public accounting firm, to conduct the audit. The contract required 

that the audit be performed in accordance with U.S. generally accepted government auditing 

standards. We monitored the firm’s work to ensure that it adhered to those standards. 

Please keep us informed of the actions taken on the report’s eight recommendations, as we will 

track the status of their implementation. 

We appreciate the assistance you and your staff provided to us during this audit. 

cc: Commissioner Thomas Hicks, Chair

Commissioner Christy McCormick, Vice Chair

Commissioner Benjamin W. Hovland

Commissioner Donald L. Palmer
McBRIDE, LOCK & ASSOCIATES, LLC

Certified Public Accountants

Established 1980

Performance Audit Report

Administration of Payments Received Under the Help America Vote Act by 

the Delaware Commissioner of Elections

Prepared for

The United States Election Assistance Commission (EAC) 

Office of Inspector General

By 

McBride, Lock & Associates, LLC

July 2022

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 Payments Received Under the Help America Vote Act by 

the Delaware Commissioner of Elections

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY 1

BACKGROUND 2

AUDIT OBJECTIVES 4

SCOPE AND METHODOLOGY 4

AUDIT RESULTS 6

APPENDICES:

Appendix A-1: Response of the Delaware Commissioner of Elections 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-1: Election Security Expenditures by Budget Category and Program 

Category

Appendix C-2: CARES Act Expenditures by Cost Category

Appendix D: Monetary Impact as of September 30, 2020 for Election Security Grant

and as of December 31, 2020 for CARES Act Grant
1

U.S. Election Assistance Commission

Performance Audit Report

Administration of Payments Received Under the Help America Vote Act by 

the Delaware Commissioner of Elections

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 of the 

administration of payments received under the Help America Vote Act (HAVA or the Act) by the 

Delaware Commissioner of Election’s Office (Office). The payments received by the Office are 

identified as Election Security, and the CARES Act. The scope of the audit includes: Election 

Security administration from inception on November 1, 2018 through September 30, 2020; Section 

251 federal financial reporting efforts through September 30, 2020; CARES Act administration 

from inception on May 6, 2020 through December 31, 2020, including matching fund expenditures 

made after December 31, 2020. The objective of the audit was to determine whether the Office

used payments authorized by Sections 101 and 251 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 plan 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 and Title II 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 and for the periods mentioned above. The exceptions are as 

follows:

1. The Office did not provide adequate documentation to support 14 of the 39 transactions 

sampled. For one transaction, no invoice was provided. For four transactions, the cost 
2

exceeded the open market threshold of $10,000, but no evidence of quotations or a formal 

bid was provided by the Office. For 13 transactions, a purchase order was not provided 

when the purchase exceeded $10,000. The total of the 14 unsupported transactions was 

$629,248.

2. The Office did not provide a non-capital asset record or State capital asset listing. In our 

testing, we identified ten invoices totaling $3,876,410 with line items in excess of the 

$5,000 federal capitalization threshold, which would need to be included on a non-capital 

asset record per State of Delaware policy. Additionally, six of the ten invoices had line 

items in excess of the $25,000 threshold, which would need to be maintained in the State’s 

capital asset listings. Some of these items were distributed to Delaware counties. Four of 

the invoices, totaling $341,547, were determined to be unsupported and included in Finding 

No. 1. The remaining six invoices had sufficient documentation to support their 

allowability, allocability, and reasonableness.

3. The Office lacks complete, documented policies with respect to internal controls and asset 

management.

4. Interest income of the Election Security and CARES Act grants were not reported on the 

Federal Financial Reports (FFRs) by the Office. The total interest income earned for the 

Election Security and CARES Act grants, as stated in correspondence with the Office, was 

$19,742 and $6,315, respectively. The Office has not filed an FFR for the Section 251 

funds since 2014.

We have included in this report as Appendix A, the Commissioner’s written response to the draft 

report. Such response has not been subjected to 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

and Title II, 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.
3

• Title II, Section 251 requirements payments are for complying with Title III requirements 

for voting system equipment; and addressing provisional voting, voting information, 

Statewide voter registration lists, and voters who register by mail.

The HAVA Election Security, Section 251 and CARES Act grants also require that states must:

• Maintain funds in a state election fund (as described in Section 104 (d) of HAVA).

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

Management and Budget (OMB) – (2 C.F.R. § 200).

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

must include a summary of expenditures aligned with budget categories in the grantee’s 

plan, a list of equipment obtained with the funds, and a description of how the funded 

activities met the goals of the plan.

• Provide matching funds of the Federal funds within a period stipulated by the award to be 

documented on the annual SF-425 submission

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

in compliance with HAVA.

The Awardee – The Delaware Commissioner of Elections

The HAVA funds were awarded to the Delaware Commissioner of Elections. The administration 

of elections in Delaware is a state responsibility. Four state agencies are involved: the 

Commissioner of Elections and the Department of Elections for each of Delaware’s three counties. 

The Commissioner of Elections is appointed by the Governor and confirmed by the State Senate. 

The Commissioner of Elections is responsible for establishing and assuring election management 

standards incorporating uniformity in the conduct of elections, the application of election 

standards, and voting equipment, among other duties. The Department of Elections for each county 

report to respective Boards of Election that are appointed by the Governor. The Department 

conducts elections in accordance with the Delaware Code and with standards and operating 

procedures established by the Commissioner.

Help America Vote Act State of Delaware State Plans

The State of Delaware’s HAVA budget narrative was prepared by the State Election 

Commissioner.

Election Security 2018 and 2020

The main objective of the 2018 project funded by HAVA, as set forth in the budget letter, was to 

purchase a new voting system that included electronic poll books, election management and voter 

registration systems, and absentee systems.

The main objective of the 2020 project funded by HAVA, as set forth in the budget letter, was to 

improve physical security at offices and warehouses, enhance cybersecurity on election systems, and 

fund security enhancements for the new voting system.
4

Section 251 Reissued

Delaware has Section 251 funds to be reissued. However, the State has not provided a federal

financial report since 2014, so the EAC has not reissued the Section 251 funds.

CARES Act

The objective of the 2020 CARES Act project funded by HAVA, as set forth in the budget letter, was 

to use the funds to prevent, prepare for, and respond to coronavirus domestically or internationally, for 

the 2020 Federal election cycle. To address the effects of the coronavirus on the election through costs 

already incurred for cleaning materials for voting equipment, protective equipment for election 

officers, and additional absentee voting supplies. Costs were anticipated to include additional 

cleaning/disinfecting supplies for voting equipment, additional protective equipment for election 

officers, and additional equipment, software, and supplies for printing/mailing/scanning/tabulating 

absentee ballots due to anticipated increased absentee voting volume.

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 informational plans 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 and Title II payments.

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

in compliance with HAVA.

SCOPE AND METHODOLOGY

We audited the Election Security grant funds received and disbursed by the Office from November 

1, 2018 through September 30, 2020. These funds are related to the appropriation of $380 million 

under the Consolidated Appropriations Act (CAA), 2018 (P.L. 115-151) and $425 million under 

the CAA, 2020 (P.L. 115-141). We reviewed the Office’s Section 251 federal financial reporting 

efforts through September 30, 2020. We audited the CARES Act grant funds received and 

disbursed by the Office from May 6, 2020, through December 31, 2020. These funds are related 
5

to the $400 million authorized by the U.S. Congress under the Coronavirus Aid, Relief and 

Economic Security Act (P.L. 116-136). The scope of activity audited is shown in the following 

table:

Election Section 251 CARES

Description Security Funds Reissued Funds Act Funds

Funds Received from EAC $ 6,036,503 $ 13,021,803 $3,000,000

State Matching Funds 10,333,685 (B) 600,000

Program Income (A) 19,742 (B) (A) 6,315

Total Funds $ 16,389,930 (B) $3,606,315

Less Disbursements (14,727,337) (B) (3,598,965)

Fund Balance $ 1,662,593 (B) $ 7,350

Note (B): The Office has not provided a Section 251 FFR since 2014.

Note (A): Program income earned per the Office. A transaction detail of this amount was 

not provided.

Program income in the above table consists entirely of interest earned on the federal funds as

reported in the program income section of the federal financial reports.

The Office’s Election Security expenditures detailed by budget and program category and CARES 

Act expenditures detailed by cost 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

Communicates Externally

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
6

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.

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, we concluded that the Office generally accounted for 

HAVA funds in accordance with the requirements mentioned above and used the funds in a manner 

consistent with informational plans submitted during the audit period. However, the Office did not 

properly account for property purchases with HAVA payments. The exceptions to applicable 

compliance requirements are described below.

Finding No. 1 – Unsupported Costs

The Office did not provide adequate documentation to support 14 of the 39 transactions sampled. 

For one transaction, no invoice was provided. For four transactions, the cost of materiel exceeded 

the open market purchase threshold of $10,000, but no evidence of quotations or a formal bid was 

provided by the Office. For 13 transactions, a purchase order was not provided when the purchase 

exceeded $10,000. The total of the 14 unsupported transactions was $629,248.

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

Awards (Uniform Guidance) at 2 CFR 200.403 states that, “Except where otherwise authorized by 

statute, costs must meet the following general criteria in order to be allowable under Federal 

awards: (g) Be adequately documented.” 

The State of Delaware, Office of Management and Budget (OMB), Budget and Accounting Policy, 

Chapter 5 – Procurement requires State of Delaware offices to procure goods and services through 

the Mandatory Use Contracts (MUC) negotiated by Government Support Services, or if the good 

or service cannot be obtained through an MUC, purchases are to be made according to the 

following: Purchases of materiel less than $10,000 can be made from an open market purchase; 

from $10,000 to $49,999 require three written quotes; and in excess of $50,000 require a formal 
7

bid. Further, Chapter 7 – Purchasing and Disbursements, requires a purchase order for purchases 

exceeding $10,000.

The Office has not provided adequate documentation to support the allowability of 14 expenditures 

charged to the HAVA grant.

Proper documentation of purchases helps to ensure that expenditures charged to federal funds are 

allowable, allocable and reasonable.

Recommendation

We recommend that the EAC require the Office to:

1. Transfer to the election fund $629,248 for the unsupported costs cited above.

2. Implement policies and procedures or training to ensure adequate documentation is 

maintained to support the allowability of expenditures charged to the HAVA grant, 

including maintaining copies of invoices paid, contracts from which purchases were made 

and purchase orders for purchases exceeding $10,000.

Commissioner of Election’s Response:

The Delaware Department of Elections (DoE), Office of the State Election Commissioner (SEC)

is working closely with the Election Assistance Commission (EAC) to provide the required

supporting documentation for expenditures in question as unsupported costs. To date, SEC has

supplied EAC with copies of invoices, purchase orders, and the State Division of Accounting’s

(DoA) Budget and Accounting manual regarding procurement procedures and purchase order

process flow. SEC will be working with the Division of Accounting to establish policies and

procedures specific to DoE, considering that the Department is generally exempt from standard

State procurement procedures, but attempts to follow these established procedures as frequently

as possible. The DoE will continue to work with EAC to answer any outstanding questions

regarding any transactions.

Auditor’s Response:

The resolution of the unsupported costs and the appropriateness of procedures to resolve future 

findings will be determined during the resolution process between the Office and EAC. 

Finding No. 2 – Property Records

The Office did not provide a non-capital asset record or State capital asset listing. In our testing, 

we identified ten invoices totaling $3,876,410 with line items in excess of the $5,000 federal 

capitalization threshold, which would need to be included on a non-capital asset record per State

of Delaware policy. Additionally, six of the ten invoices had line items in excess of the $25,000 

threshold, which would need to be maintained in the State’s capital asset listings. Some of these 

items were distributed to Delaware counties. Four of the invoices, totaling $341,547, were 

determined to be unsupported and included in Finding No. 1. The remaining six invoices had 

sufficient documentation to support their allowability, allocability, and reasonableness.
8

The Uniform Guidance at 2 CFR 200.313(b) states that, “A state must use, manage and dispose of 

equipment acquired under a Federal award by the state in accordance with state laws and 

procedures.” Equipment is defined at 2 CFR 200.1 as “tangible personal property (including 

information technology systems) having a useful life of more than one year and a per-unit 

acquisition cost which equals or exceeds the lesser of the capitalization level established by the 

non-Federal entity for financial statement purposes, or $5,000.” 

State of Delaware, OMB, Budget and Accounting Policy, Chapter 13 – Asset Management states 

that, “Organizations are responsible for (1) maintaining schedules of assets purchased with federal 

funds according to grant agreements, and (2) ensuring that all assets purchased under $25,000 with 

federal funds are properly accounted for in the Organization’s non-capital asset records. Assets 

valued above $25,000 that are purchased with federal funds are maintained in the State’s capital 

asset listings.” 

The Office states that the IT Department keeps an inventory listing of all the Office’s computers, 

printers, laptops and accessories, and each county is responsible for keeping an inventory listing 

of pollbooks, machines, printers and accessories. However, the Office has not provided these 

listings.

Proper tracking of property purchased with federal funds ensures that equipment is being used and 

disposed of in accordance with federal regulations and state laws and procedures.

Recommendation

We recommend the EAC require the Office to:

3. Provide the inventory listing maintained by the IT Department and each County.

4. Implement policies and procedures or training to ensure that assets are managed in 

accordance Uniform Guidance and the State of Delaware’s policy.

Commissioner of Election’s Response:

The DoE is in the process of gathering updated voting equipment inventory lists, working in

collaboration with the DoE’s county offices, as well as with the DoE IT team to compile the list

of technology-related items, and will be working with the State DoA to develop policies and

procedures for maintaining inventories of equipment that meet asset/non-asset equipment listing

requirements pertaining to equipment purchased with federal funds. The DoE anticipates

completing these actions by December 31, 2022.

Auditor’s Response:

The resolution of the finding and appropriateness of the equipment inventory procedures 

developed by the Office to resolve future findings will be determined during the resolution process 

between the Office and EAC. 
9

Finding No. 3 – Documentation of Policies and Procedures

The Office lacks complete, documented policies with respect to internal controls and asset 

management.

The State of Delaware OMB, Budget and Accounting Policy, Chapter 2 – Internal Controls states, 

"Documentation is required to demonstrate the design, implementation, and operational 

effectiveness of an Organization’s internal control system.” Further it states, “Management is 

responsible for maintaining and communicating written policies and procedures to ensure an 

effective system of internal controls exists within each agency. Effective policies and procedures 

help ensure management directives are carried out and necessary actions are taken to address risks 

to the achievement of the agency’s objectives."

The State of Delaware OMB Budget and Accounting Policy, Chapter 13 – Asset Management 

states, “Organization officials must establish internal written procedures and controls necessary to 

implement and monitor applicable asset management accounting and reporting policies, 

guidelines, and standards.”

The Office states that they are working with the State of Delaware Division of Accounting to get 

written policies and procedures and internal controls in place. It is the Office’s procedure to follow 

the State of Delaware Budget and Accounting Manual.

Inadequate documented policies and procedures may result in a lack of awareness and compliance 

with management's directives and could allow noncompliance with grant terms and conditions to 

occur and not be detected.

Recommendation

5. We recommend the EAC require the Office to ensure that documented policies and

procedures related to internal controls and asset management are established and 

implemented in accordance with the State of Delaware’s policy. Implementation should 

include policies to review and update the procedures on a regular basis.

Commissioner of Election’s Response:

The DoE is small agency as compared to other State agencies and, as such, generally adapts

existing State policies in use by other, larger agencies, as is the case in this instance. DoE follows

the general policies and procedures laid out by the State’s DoA and, more specifically, follows the

provisions of the State Budget and Accounting Manual. The DoE will be working with the

Division of Accounting to establish policies and procedures specific to our department. We

anticipate completing this process by December 31, 2022.

Auditor’s Response:

The proposed corrective actions, if implemented, would be sufficient to resolve the finding. 
10

Finding No. 4 – Financial Reporting 

Interest income of the Election Security and CARES Act grants were not reported on the Federal 

Financial Reports (FFRs) by the Office. The total interest income earned for the Election Security 

and CARES Act grants, as stated in correspondence with the Office, was $19,742 and $6,315, 

respectively. The Office has not filed a FFR for the Section 251 funds since 2014.

The terms and conditions of the 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 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 Office was made aware of the requirement to earn and report interest income on the FFR by 

the EAC in February 2019. However, the Office has not provided detail of the interest income 

earned or reported the program income on the FFRs. The Office is working with the State’s grant 

team to complete the Section 251 FFR. However, the Office has not provided a timeline for 

completion of the Section 251 FFR.

Proper and timely reporting of uses of award funds and the interest income generated by federal 

funds ensures that the funds are tracked and spent in accordance with federal regulations.

Recommendation

We recommend that the EAC require the Office to:

6. Provide transaction detail of interest income earned for the Election Security and CARES 

Act grants.

7. Complete and file FFRs for the Section 251 funds or if the Office is unable to complete the 

Section 251 FFR, obtain financial services to support the completion of the filings.

8. Implement procedures and training to properly fill out the required FFRs, which reflect the 

uses of award funds and the interest income generated from those funds for all HAVA 

grants.

Commissioner of Election’s Response:

To bring the required financial reports current, the SEC will be working with the State Treasurer’s 

office and the State DOA’s Grants Management Team to accomplish this. The DoE will be 

addressing the matter of currently outstanding financial reports to be filed, and the open item of 

earned interest for all DoE grant funds. The Department will be working with EAC to ensure that 

each grant is made current in all aspects. DoE anticipates completing these tasks by December 31, 

2022.
11

Auditor’s Response:

The resolution process needs to ensure that accurate Federal Financial Reports are submitted for 

the Election Security, CARES Act, and Section 251 grants, as well as determining the 

appropriateness of procedures to prevent future findings. 

The Office responded on August 30, 2022, and generally agreed with the report’s findings and 

recommendations. The EAC responded on August 26, 2022, and stated they will work with the 

Delaware Commissioner of Elections to implement and complete appropriate corrective action on 

the findings. 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 July 8, 2021, 

and July 20, 2022. 

McBride, Lock & Associates, LLC

Kansas City, Missouri 

July 20, 2022 
APPENDIX A-1

Response of the 

Delaware Commissioner of Elections

to the Draft Report
STATE OF DELAWARE

DEPARTMENT OF ELECTIONS

https://ivote.de.gov

STATE ELECTION COMMISSIONER

905 S GOVERNORS AVE STE 170 

DOVER DE 19904

PHONE: (302) 739-4277 

NEW CASTLE COUNTY OFFICE

CARVEL STATE OFFICE BLDG

820 N FRENCH ST STE 400 

WILMINGTON DE 19801

PHONE: (302) 577-3464

KENT COUNTY OFFICE

100 ENTERPRISE PL STE 5

DOVER DE 19904

PHONE: (302) 739-4498 

SUSSEX COUNTY OFFICE

119 N RACE ST 

PO BOX 457

GEORGETOWN DE 19947 

PHONE: (302) 856-5367

STGP001 v1.1 7/7/2015

August 30, 2022

Brianna Schletz, Inspector General

U.S. Election Assistance Commission

Office of Inspector General

633 3rd Street NW, Suite 200

Washington, DC 20001

Re: Response to EAC OIG Draft Report: Audit of the Help America Vote Act Grants Awarded to the State 

of Delaware

Dear Ms. Schletz:

The Department appreciates the opportunity to offer our responses to the findings of the draft audit 

report of HAVA funds awarded to the State of Delaware. We hope that the responses provided will 

provide sufficient details on our planned actions to address findings presented. The Department will be 

happy to further elaborate on these responses, if needed.

The Department wishes to thank Grants Consultant Peg Rosenberry for her continued invaluable 

assistance with this process, as well.

Finding No. 1 – Unsupported Costs

Adequate documentation not provided to support sampled transactions

State Election Commissioner’s Response:

The Delaware Department of Elections (DoE), Office of the State Election Commissioner (SEC) is working 

closely with the Election Assistance Commission (EAC) to provide the required supporting 

documentation for expenditures in question as unsupported costs. To date, SEC has supplied EAC with 

copies of invoices, purchase orders, and the State Division of Accounting’s (DoA) Budget and Accounting 

manual regarding procurement procedures and purchase order process flow. SEC will be working with 

the Division of Accounting to establish policies and procedures specific to DoE, considering that the 

Department is generally exempt from standard State procurement procedures, but attempts to follow 

these established procedures as frequently as possible. The DoE will continue to work with EAC to 

answer any outstanding questions regarding any transactions.

Finding No. 2 – Property Records

A non-capital asset record or State capital asset listing not provided

State Election Commissioner’s Response:

The DoE is in the process of gathering updated voting equipment inventory lists, working in 

collaboration with the DoE’s county offices, as well as with the DoE IT team to compile the list of 

technology-related items, and will be working with the State DoA to develop policies and procedures for 
maintaining inventories of equipment that meet asset/non-asset equipment listing requirements 

pertaining to equipment purchased with federal funds. The DoE anticipates completing these actions by 

December 31, 2022.

Finding No. 3 – Documentation of Policies and Procedures

Need for documented policies with respect to internal controls and asset management

State Election Commissioner’s Response:

The DoE is small agency as compared to other State agencies and, as such, generally adapts existing 

State policies in use by other, larger agencies, as is the case in this instance. DoE follows the general 

policies and procedures laid out by the State’s DoA and, more specifically, follows the provisions of the 

State Budget and Accounting Manual. The DoE will be working with the Division of Accounting to 

establish policies and procedures specific to our department. We anticipate completing this process by 

December 31, 2022.

Finding No. 4 – Financial Reporting

Grant reports for Section 251 not current

State Election Commissioner’s Response:

To bring the required financial reports current, the SEC will be working with the State Treasurer’s office 

and the State DOA’s Grants Management Team to accomplish this. The DoE will be addressing the mater 

of currently outstanding financial reports to be filed, and the open item of earned interest for all DoE 

grant funds. The Department will be working with EAC to ensure that each grant is made current in all 

aspects. DoE anticipates completing these tasks by December 31, 2022.

Sincerely,

Anthony Albence

State Election Commissioner
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: Brianna Schletz, Inspector General 

FROM: Kinza Ghaznavi, Grants Director

DATE: August 26, 2022 

RE: Response to Draft Audit Report of Grants Awarded to the Delaware 

Commissioner of Election’s Office

This is the EAC’s response to the OIG draft audit of HAVA funds awarded to the 

Delaware Commissioner of Election’s Office (Office) and serves as the EAC’s 

management decision. The scope of the audit included HAVA Sections 251, 101 Election 

Security and 101 CARES grants. The EAC agrees with the recommendations and 

describes our management decisions related to each one below. 

Finding #1 and Recommendations #1 and #2, Unsupported Costs: The auditors 

questioned $629,248 in costs as unsupported because the Office could not provide proper 

invoices or purchase orders for the expenditures or provide evidence the Office had 

followed required competitive bidding processes. The auditors recommend the EAC

require the Office to: 

1. Transfer to the election fund $629,248 for the unsupported costs cited above. 

2. Implement policies and procedures or training to ensure adequate documentation is 

maintained to support the allowability of expenditures charged to the HAVA grant, 

including maintaining copies of invoices paid, contracts from which purchases were 

made and purchase orders for purchases exceeding $10,000. 

Management Decision: The Office has provided adequate supporting 

documentation for many of the questioned costs related to procurements as well as 

state regulations that allow exceptions to state procurement requirements for the 

Election Office. The EAC grants staff will review that supporting documentation by 

September 30 to determine which expenditures are supported, including why the 

purchase orders were not provided during the audit. For Recommendation #2, Office 

staff indicated that they generally follow state procurement policies despite the 

exception they have from certain state procurement procedures. The EAC notes that 

they have not established a consistent policy for when state procurement requirements 

will apply and when they will not. We are requiring the Office to work with the 

Division of Accounting to develop such policies and to document consistent

procedures for applying them to procurements. They expect to have the new policies 

in place by December 31, 2022. 
2

Finding #2 and Recommendations #3 and #4, Property Records: During the audit, 

the Office could not provide a non-capital asset record or State capital asset listing. State 

policies require equipment in excess of $25,000 to be recorded on a State capital asset 

listing. In addition, to meet requirements under 2 CFR 200 related to equipment with per

unit costs in excess of $5,000 purchased with federal funds, such equipment should have 

been recorded on the State non-capital asset record. The auditors recommended that the 

EAC require the Office to:

3. Provide the inventory listing maintained by the IT Department and each County.

4. Implement policies and procedures or training to ensure that assets are managed in

accordance Uniform Guidance and the State of Delaware’s policy.

Management Decision: The Office is currently working with the counties to supply 

their lists and with its IT department to update the inventory the IT department 

supplied. They are also working with the State’s Division of Accounting to develop 

policies and procedures for maintaining inventories of equipment that meet asset and 

non-asset listing requirements and requirements for equipment purchased with federal 

grant funds, as appropriate. They expect to have the county and IT department 

listings up to date and the policy and procedures in place by December 31, 2022.

Finding #3 and Recommendation #5, Documentation of Policies and Procedures: 

The auditors found the Office lacked complete, documented policies with respect to 

internal controls and asset management. They recommended that the EAC require the 

Office to ensure that documented policies and procedures related to internal controls and 

asset management are established and implemented in accordance with the State of 

Delaware’s policy. Implementation should include policies to review and update the 

procedures on a regular basis.

Management Decision: The Office follows the Division of Accounting budget and 

accounting manual and is reviewing it with them to identify areas in which the 

Election Office needs to establish specific policies and procedures for the Office 

following accounting department guidelines. They are holding information gathering 

sessions that began a few months ago and will continue when the accounting 

department completes its fiscal year wrap-up. They expect to complete the process 

and have policies and procedures in place by December 31, 2022.

Finding #4 and Recommendations #6, #7 and #8, Financial Reporting: The auditors 

found that the Office was not reporting interest earned on the Election Security and 

CARES grants and had not submitted an FFR on the 251 grant since 2014. The auditors 

recommended that the EAC require the Office to:

6. Provide transaction detail of interest earned for the Election Security and CARES Act 

grants.

7. Complete and file FFRs for the Section 251 funds or if the Office is unable to 

complete the Section 251 FFR, obtain financial services to support the completion of 

the filings.
3

8. Implement procedures and training to properly fill out the required FFRs, which 

reflect the uses of award funds and the interest generated from those funds for all 

HAVA grants.

Management Decision: The Office is working with the State Treasury and the 

grants management staff within the Division of Accounting and expects to have 

accurate interest calculated by September 30 for the Election Security and CARES 

grants and by December 31 for the 251 grant. Once the EAC staff has reviewed and 

approved the interest calculations, we will require them to revise FFRs as needed and 

bring the 251 FFRs up to date. Regarding Recommendation #8, they will work with 

the state grants management staff to develop procedures for completing accurate 

financial reports and for identifying interest earned and expended for reporting on the 

FFRs. They expect to have policies and procedures in place by December 31, 2022.

The EAC expects to review the actions and documentation provided by the state by 

January 31, 2023.
17

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:
18

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 Yes 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.

Information and Communication and its underlying principles were deemed to be significant to 

our determination of the awardee’s compliance with the FFR 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 and reporting 

requirements to the counties.
19

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 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 and interest income was properly accounted for and not remitted 

to the State’s general fund.
20

Appendix C-1

ELECTION SECURITY EXPENDITURES BY BUDGET CATEGORY AND PROGRAM CATEGORY

NOVEMBER 1, 2018 TO SEPTEMBER 30, 2020

Budget Categories

Voting 

Equipment

Election 

Auditing

Voter 

Registration 

Systems

Cyber 

Security Communications Other Total

Personnel (Including Fringe) $ - $ - $ - $ - $ - $ - $ -

Equipment 805,616 - 3,000,000 - - - 3,805,616

Subgrants - - - - 45,538 - 45,538

Training - - - - - - -

All Other Costs - - - 147,048 - 395,450 542,498

Total Direct Costs $ 805,616 $ - $ 3,000,000 $ 147,048 $ 45,538 $ 395,450 $ 4,393,652

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

Total Federal Expenditures $ 805,616 $ - $ 3,000,000 $ 147,048 $ 45,538 $ 395,450 $ 4,393,652

Non-Federal Match 10,201,404 - - 31,084 13,942 87,255 10,333,685

Total Program Expenditures $ 11,007,020 $ - $ 3,000,000 $ 178,132 $ 59,480 $ 482,705 $ 14,727,337

Program Categories
21

Appendix C-2

CARES ACT EXPENDITURES BY COST CATEGORY

MAY 6, 2020 TO DECEMBER 31, 2020

Cost Categories Federal Match Total

Voting Processes $ 2,343,642 $ 292,393 $ 2,636,035

Staffing 308,047 108,438 416,485

Security and Training 20,098 3,836 23,934

Communications 123,858 55,513 179,371

Supplies 203,320 38,580 241,900

Total CARES Expenditures $ 2,998,965 $ 498,760 $ 3,497,725

Expenditure Type

Note: Difference between match expenditures above and match spending of $600,000 in previous table is due to match expenditures 

charged after December 31, 2020.
22

Appendix D

MONETARY IMPACT AS OF SEPTEMBER 30, 2020 FOR ELECTION 

SECURITY AND AS OF DECEMBER 31, 2020 FOR CARES ACT GRANT 

Description

Questioned 

Costs

Unsupported 

Costs

Additional 

Funds for 

Program

Unsupported Costs $ - $ 629,248 $ -

Total $ - $ 629,248 $ -
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