1

OFFICE OF INSPECTOR GENERAL

U.S. Election Assistance Commission

DATE: June 17, 2022

TO: U.S. Election Assistance Commission, Chairman, Thomas Hicks

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

State of Georgia, Secretary of State, Brad Raffensperger

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

SUBJECT: Cancellation: Audit of the Administration of Help America Vote Act (HAVA) 

Funds by the State of Georgia

The Office of Inspector General (OIG) is an independent division of the U.S. Election Assistance 

Commission (EAC) and operates under the authorities vested in it by the Help America Vote Act 

(HAVA) and the Inspector General Act of 1978, as amended. Part of OIG’s statutory mandate is 

to conduct audits of EAC and its programs, including audits of states receiving EAC funds. On 

July 14, 2021, the EAC OIG announced an audit of the administration of HAVA funds by the 

State of Georgia. An entrance conference was held with officials from the Georgia Secretary of 

State, and fieldwork commenced. Meanwhile, in March 2022, the Georgia Department of Audits 

and Accounts issued a report, which also covered the office’s administration of HAVA funds.

1

The auditors found the Secretary of State (SOS) office needs to improve compliance with federal 

grant requirements and implement an adequate system of internal controls related to its 

contracting and procurement activities.2

We are informing you of the decision to cancel the EAC OIG audit. Rather than duplicate the 

work of the State auditors, we reduced the cost of the audit contract, which resulted in cost 

savings for the government. EAC OIG will perform an audit next year to ensure the Georgia 

SOS implemented corrective actions that address the deficiencies noted in the March 2022 

Georgia Department of Audits and Accounts report. We urge EAC to review the report 

recommendations and follow up with SOS as it implements corrective actions. We also 

commend EAC for holding Georgia’s $1.8 million allotment of 2022 Election Security grant 

funds until it is compliant with reporting requirements.

1 SECRETARY OF STATE GRANT ADMINISTRATION: REQUESTED INFORMATION ON HELP AMERICA VOTE ACT FUNDS 

AND COMPLIANCE, SPECIAL EXAMINATION, REPORT NUMBER 21-11, GA. DEP’T OF AUDITS & ACCTS., (Mar. 2022),

https://www.audits.ga.gov/ReportSearch/download/27901. 2 The examination scope included approximately $11 million in 2020 Coronavirus Aid, Relief, and Economic 

Security Act (CARES Act) funds.
2

Background and Considerations for Cancellation

The independent public accounting (IPA) firm that EAC OIG contracted to conduct the audit

encountered delays and a general lack of responsiveness to requests for information from the 

SOS. After the EAC OIG audit was announced, an entrance conference was held on July 21, 

2021, and the IPA firm’s audit team arrived for fieldwork during the week of October 4, 2021. 

Although there was advance notice of the visit, audit progress was hindered when the IPA team 

learned after arriving that the main point of contact would not be available until the end of the 

week. Georgia officials provided a portion of the requested audit documentation during the 

onsite fieldwork, but several documents and explanations for financial variances were not 

received, even after follow-up requests were made on December 8, 2021, and January 10, 2022. 

At the end of January, Georgia officials responded that the requests were being worked on. After 

not receiving the requested documents, the audit team followed up with the SOS office again on 

February 15, 2022, but did not receive a full response. 

In March, the EAC OIG learned of the Georgia Department of Audits and Accounts special 

report. After meeting with the State auditors to get an understanding of the scope of their work 

and determining there was a significant overlap in effort, we decided to avoid duplication and

refocus our time and resources. We promptly issued a stop work order resulting in approximately

$30,000 in cost savings for the government that will provide the opportunity for the Georgia SOS 

to correct the significant gaps identified in the State auditor’s report. We intend to perform an 

audit next year to ensure the Georgia SOS implemented corrective actions for the high-risk areas 

identified below.

Findings Related to Internal Controls and Procurement

When spending HAVA funds on goods and services, the SOS must comply with both federal 

grant requirements and state procurement guidance and laws. However, the State auditors 

identified that (1) the SOS was not participating in Georgia’s required purchase card program, 

(2) SOS employees were paying business expenses with personal credit cards, (3) the SOS did 

not use mandatory statewide contracts for public relations and cybersecurity services, (4) SOS 

officials did not comply with the SOS purchase order policy, and (5) emergency procurement 

procedures were not properly followed. The auditors found that “almost half of the grant 

transactions examined had at least one noncompliance issue related to state purchasing 

requirements.”3 In addition to the matters investigated by the Georgia Office of the State 

Inspector General, the State auditors identified issues involving business transactions that the 

SOS had with an employee. 

The State auditors made four recommendations to address the gaps in internal controls identified.

The recommendations are for SOS to (1) discontinue the use of credit cards outside of the state 

program, (2) participate in and comply with the statewide purchase card program, (2)

immediately comply with state purchasing requirements, and (4) not transact business with its 

employees. 4

3 SECRETARY OF STATE GRANT ADMINISTRATION: REQUESTED INFORMATION ON HELP AMERICA VOTE ACT FUNDS 

AND COMPLIANCE, SPECIAL EXAMINATION, REPORT NUMBER 21-11, GA. DEP’T OF AUDITS & ACCTS., (Mar. 2022),

https://www.audits.ga.gov/ReportSearch/download/27901. 4 See Id. at 23.
3

Findings Related to Federal Grant Requirements

Federal grant recipients must comply with certain requirements. However, the State auditors 

found that the SOS was unable to provide adequate documentation to support $576,000 of 

sampled expenditures. Moreover, the auditors found that the SOS spent $1,600 on goods and 

services that were ineligible under the grants, the SOS failed to submit the required progress and 

financial reports to the EAC, and that the property purchased by the SOS with grant funds was 

not properly inventoried.

In response to these deficiencies, the State auditors made four recommendations for addressing 

the SOS’s noncompliance with the federal grant requirements. The recommendations are for 

SOS to (1) maintain documentation for goods and services purchased with grant funds, (2) limit 

the use of HAVA funds to those allowable, (3) submit required progress and financial reports for 

active grants by the required due date, and (4) record equipment associated with the statewide 

voting system in the inventory system and conduct an inventory every two years. 5

We understand that a new Chief Financial Officer with financial experience has been hired at the 

SOS. As SOS works to correct the noted deficiencies, we encourage the office to maintain 

qualified candidates in key financial positions to reduce the risk of further internal control 

deficiencies and noncompliance with federal grant requirements.

Conclusion

We remain committed to ensuring that EAC funds are used properly. While the deficiencies 

identified by the State auditors raise serious concerns about the Georgia SOS’s ability to 

responsibly administer EAC funds, we are confident that the noted issues can be corrected with 

proper attention, and we look forward to working with the Georgia SOS in the future. EAC OIG

will continue to conduct oversight of any improper use of EAC funds that is brought to our

attention. 

5 See Id. at 28.