U.S. ELECTION ASSISTANCE COMMISSION 

OFFICE OF INSPECTOR GENERAL
 

FINAL REPORT 

ADMINISTRATION OF GRANT FUNDS RECEIVED 

UNDER THE HELP AMERICA VOTE COLLEGE PROGRAM 

BY PROJECT VOTE 

AUDIT REPORT NO. 

E-HP-SP-05-10
 

NOVEMBER 2010 
U.S. ELECTION ASSISTANCE COMMISSION
 

OFFICE OF INSPECTOR GENERAL 

NOVEMBER 2010 

AUDIT REPORT 

ADMINISTRATION OF GRANT FUNDS RECEIVED UNDER THE HELP 

AMERICA VOTE COLLEGE PROGRAM BY PROJECT VOTE 

HIGHLIGHTS 

AUDIT REPORT NO. 

E-HP-SP-05-10 

SUBJECT

We audited Project Vote’s use of 

$33,750 provided through two grants 

issued in 2006 by the U.S. Election 

Assistance Commission (EAC) under 

the Help America Vote College 

Program (College Program). 

Our audit objectives were to determine 

whether the costs claimed under the 

grants were allowable, supported, and 

in accordance with applicable laws, 

regulations, guidelines, and terms and 

conditions of the grants. 

RECOMMENDATIONSAND

COMMISSIONRESPONSE

We found that Project Vote did not 

possess cost records sufficient to 

support expenditures related to the two 

grants issued to Project Vote in 2006. 

We recommended that the EAC work 

with Project Vote to obtain cost records 

and if such records can not be obtained 

to recover the $33,750 in grant funding 

provided to Project Vote. 

In its response to the draft report 

(Appendix 2), the EAC indicated that it 

generally concurred with the results of 

the review and the recommendations. 

The response indicated that the EAC 

would work with Project Vote to 

recover any unsupported or 

unallowable costs. 

RESULTSINBRIEF

The Help America Vote College Program is a discretionary grant 

program run by the EAC to encourage college students to serve 

as poll workers. Grants are distributed to non-profit 

organizations and institutions of higher learning to recruit and 

train college students to serve as poll workers. 

In 2006, Project Vote was awarded two grants, $16,875 each, to 

develop and implement recruitment and training programs in 

Michigan and Delaware. According to information provided by 

Project Vote, they contracted with the Association of Community 

Organizations for Reform Now (ACORN) to conduct the grant 

work. The final reports issued regarding these grant programs 

states that Project Vote used the grant funding to recruit 105 and 

75 students, respectively, in Delaware and Michigan, and that 

105 and 40 students, respectively, were trained in Delaware and 

Michigan to serve as poll workers. 

Upon making repeated requests for cost and accounting records, 

we were informed by Project Vote in April 2010 that Project 

Vote could not locate any cost or accounting records to support 

its or ACORN’s expenditures under the grants. What is more, 

Project Vote could not demonstrate that a contract existed 

between itself and ACORN to perform the grant services. 

EAC requested that payment be made to Project Vote under this 

grant in August 2009. Based upon the records provided by EAC, 

it had no cost records or expenditure details at the time of 

payment. 

We found that the grant costs were unsupported and questioned 

all $33,750. We recommended that the Commission (1) work 

with Project Vote to identify any supporting costs records and 

make a determination as to whether any costs related to the grant 

were supported, (2) conduct a thorough search to determine if 

EAC has any additional records from Project Vote that support its 

costs, (3) recover any unsupported or unallowable costs from 

Project Vote, and (4) follow policies and procedures established 

in the grant award regarding obtaining and retaining required 

reporting documents. 
 

U.S. ELECTION ASSISTANCE COMMISSION
 

OFFICE OF INSPECTOR GENERAL
 

1201 New York Ave. NW - Suite 300 

Washington, DC 20005
 

November 8, 2010 

Memorandum 

To: The Commission 

From: Curtis Crider 

Inspector General 

Subject: Final Audit Report – “Administration Of Grant Funds Received Under 

The Help America Vote College Program By Project Vote” 

This memorandum transmits the U.S. Election Assistance Commission Office of 

Inspector General’s final report on its audit of Project Vote’s use of funding distributed 

by the U.S. Election Assistance Commission (EAC) under the Help America Vote 

College Program (College Program). The Office of Inspector General was requested by 

the U.S. Election Assistance Commission to audit the two Help America Vote College 

Program grants issued in 2006 to Project Vote of Delaware and Project Vote of 

Michigan. Project Vote of Delaware received $16,875 and Project Vote of Michigan 

received $16,875. The objective of the audit was to determine whether the costs claimed 

under the grants were allowable, supported, and in accordance with applicable laws, 

regulations, guidelines, and the terms and conditions of the grants. 

We discovered that Project Vote did not possess cost records to support its 

expenditures under the two grants issued to Project Vote (Michigan and Delaware) in 

2006. As a result, the OIG is questioning the entire $33,750 provided to Project Vote 

under the grants. In a letter dated June 16, 2010, (Appendix 3) Project Vote maintains 

that the work outlined in the grants was successfully completed. The letter further 

indicated that Project Vote no longer has any working relationship with ACORN. A 

copy of the draft report was provided to Project Vote for its review and comment. 

Project Vote did not respond to our request for comments. 

In its response to the draft report (Appendix 2), the EAC indicated that it 

generally concurred with the results of the review and the recommendations. The 

response indicated that the EAC would work with Project Vote to recover any 

unsupported or unallowable costs. 

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 finding and recommendation included in this report by January 4, 2011. 

Your response should include information on actions taken or planned, targeted 

completion dates, and titles of officials responsible for implementation. 

The legislation, as amended, creating the Office of Inspector General (5 

U.S.C. § App.3) requires semiannual reporting to Congress on all audit reports 
issued, actions taken to implement audit recommendations, and recommendations 

that have not been implemented. 

If you have any questions regarding this report, please call me at (202) 566-3125. 

We appreciate your prompt attention to this matter. 

cc: Executive Director 
TABLE OF CONTENTS 

Introduction 1 

Objectives, Scope, and Methodology 2 

Findings and Recommendations 3 

Appendix 1 – Monetary Impact 7 

Appendix 2- Commission Response 8 

Appendix 3- Letter from Project Vote 9 
INTRODUCTION 

The U.S. Election Assistance Commission (EAC) was created and empowered by the 

Help America Vote Act of 2002 (HAVA) to assist states with the improving the process 

of conducting elections for federal office. HAVA also provides funds to help encourage 

college students to be trained and serve as poll workers on election day. 

The Help America Vote College Program (College Program) permits grants to 

institutions of higher learning and nonprofit organizations to recruit and train college 

students to serve as poll workers on election day. Grants under this program were first 

distributed in 2004. The EAC has subsequently distributed grants in 2006, 2008, 2009 

and 2010. 

Under the College Program, the EAC awarded $33,750 to Project Vote in August 2006 in 

the form of two grants: one to Project Vote, Delaware, in the amount of $16,875; and 

one to Project Vote, Michigan, in the amount of $16,875. Project Vote submitted grant 

applications or proposals for both grants in June 2006. Those applications included 

budgets for the proposed projects. 

Project Vote’s final report was dated May 2007 for each grant project. According to 

those reports, interim reports were also submitted and the final reports covered the period 

from October 1, 2006 through December 31, 2006. As a part of the final reports, Project 

Vote provided a narrative of its expenditures. The narrative merely listed the categories 

or classes of things on which grant funds were spent, including salaries and wages for 

several employees, refreshments, supplies associated with the production of flyers, 

reminder phone calls, and travel expenses. The reports did not identify what amounts of 

money were spent on each of these activities. 

The final reports also provided information regarding the results of the grant projects 

undertaken by Project Vote, Michigan, and Project Vote, Delaware. According to the 

final reports, Project Vote, Michigan, recruited 75 students and 40 of those students were 

ultimately trained as poll workers. Project Vote reported that they were asked to suspend 

referrals to the Department when the Department had reached the needed number of 

qualified poll workers. Project Vote, Delaware recruited and trained 80 students. 

Students were recruited through two meetings: one on the University of Delaware 

campus and one on the Delaware Technical and Community College Campus. Training 

sessions were held on both campuses. In addition, 25 students contacted Project Vote 

regarding their interest and were directed to training sessions conducted by the New 

Castle Department of Elections at other locations. 

The EAC distributed the $33,750 in grant funds to Project Vote in August 2009. The 

information provided with regard to this payment was a memorandum to the General 

Services Administration requesting disbursement of funds. That memorandum stated that 

EAC was awaiting final reports prior to disbursing payment to Project Vote. EAC did 

receive the final reports. 

1 
OBJECTIVES, SCOPE, AND METHODOLOGY 

The objective of our audit was to determine whether the costs claimed by Project Vote 

under the College Program grants were allowable, supported, and made in accordance 

with applicable laws, regulations, guidelines, and terms and conditions of the grants. 

We examined records related to the College Program grants issued to Project Vote that were 

provided by the EAC as well as Project Vote. We also examined standards for reporting as 

contained in the terms and conditions of the grant, the grant award letters, HAVA, and applicable 

Office of Management and Budget circulars. 

We performed our audit in accordance with generally accepted government auditing standards. 

2 
FINDINGS AND RECOMMENDATIONS 

At the beginning of this audit, the OIG requested access to records related to the grants 

distributed to and administered by Project Vote. These requests were made of Project 

Vote officials as well as the EAC. The EAC provided documents to support the grant 

solicitation, Project Vote’s applications, as well as the selection and award of grants to 

Project Vote. In addition, EAC provided documentation for the request for payment or 

disbursement of funds to Project Vote. The EAC also provided copies of the final reports 

submitted by Project Vote. On January 21, 2010, the EAC confirmed that they did not 

have any additional records related to the Project Vote grants. 

Project Vote provided copies of the final reports submitted for both grants. In addition, 

Project Vote provided a spreadsheet with the names of students as well as contact and 

tracking information for persons involved with the Delaware effort. Last, Project Vote 

provided an activity report for the Michigan grant project. By email dated April 20, 

2010, Project Vote officials stated that they did not have any additional records. 

According to information provided by Project Vote officials during a conference call held 

on March 5, 2010, Project Vote contracted with ACORN to conduct the work under these 

grant agreements. Project Vote officials stated that they could not produce contract 

documents supporting this working relationship and that no funds had been disbursed to 

ACORN due to the lack of contract documentation. In its April 20, 2010 email, Project 

Vote officials stated that Project Vote requested documents from ACORN relative to 

their work on these projects and that ACORN had not produced any records. 

The award letters issued to Project Vote set forth the record keeping and audit 

requirements on grants made under the Help America Vote College Program. The 

conditions specifically required compliance with Office of Management and Budget 

(OMB) Circular A-122 and referenced the provisions of HAVA regarding recordkeeping 

by recipients of HAVA funding. In addition, the reporting schedule provided to Project 

Vote with the award letters for the grants required the submission of a Cash Transactions 

Report (SF 272) on October 15, 2006, and a Financial Status Report (SF 269) on March 

31, 2007. 

3 
FY 2006 Help America Vote College Program Grant 

Reporting Schedule 

Due Date Reporting Period Report 

October 15, 2006 August 7, 2006 – September 30, 2006 SF 272 Federal Cash 

Transaction Report 

October 30, 2005 August 7, 2006 – September 30, 2006 Performance Report 

March 31, 2007 

(Final Report) 

October 1, 2006 – December 31, 2006 

(unless the period of the grant is extended) 

SF 269 Financial 

Status Report and 

Performance Report 

The grant award letters to Project Vote, Michigan and Project Vote, Delaware were dated 

August 4, 2006. 

Circular A-122 requires that costs are “adequately documented” in order to be considered 

allowable. See OMB Circular A-122, Cost Principles for Non-Profit Organizations (2 

C.F.R. Part 230). The circular also specifies the types of records that are needed to 

support certain charges. For example, time sheets or certifications are required to 

support salary costs charged to a grant. Section 902 of HAVA requires that grant 

recipients maintain records consistent with sound accounting principles. 

“(a) Recordkeeping Requirement. – Each recipient of a grant or other 

payment 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.” 

42 U.S.C. § 15542 (a). 

After several requests to both the EAC and to Project Vote, neither could provide records 

of actual expenditures by Project Vote on this grant. Project Vote could not produce any 

cost or accounting records related to its expenditure of $33,750 in Federal grant funds. 

Furthermore, neither EAC nor Project Vote could produce interim or final financial 

reports that were required to be submitted by Project Vote pursuant to the grant 

agreement. The only information provided relative to costs were budget estimates 

included in Project Vote’s applications for the two grants. The two final reports 

4 
submitted by Project Vote included a list of the types of charges funded by the grants. 

The reports did not include amounts for each of the categories and did not provide any 

supporting documentation for salaries or any other charges. The records submitted by 

both the EAC and Project Vote did not include any SF 272 Federal Cash Transactions 

Reports or SF 269 Financial Status Reports. The records provided by Project Vote and 

EAC do not support costs reportedly incurred by Project Vote in conducting the two grant 

programs. 

FINDING1– – PROJECTVOTE’SCOSTSWEREUNSUPPORTED

Project Vote’s failure to maintain records in accordance with grant conditions, HAVA 

requirements, and applicable OMB circulars resulted in its inability to produce records to 

support costs reportedly incurred by Project Vote in conducting the grant programs. 

EAC, likewise, did not produce financial reports required to be submitted by Project Vote 

as a part of its grant agreement with EAC. As a result of the absence of cost records, all 

$33,750 in costs associated with grants made to Project Vote in 2006 are currently 

unsupported and are, therefore, questioned. 

RECOMMENDATIONS

We recommend that the EAC: 

1.	 Determine whether any costs associated with this grant are supported and 

allowable. EAC should work with Project Vote to determine whether Project 

Vote has any records to support its costs under the grants. 

2.	 Conduct a thorough search of its paper and electronic files to determine if the 

EAC has any additional documentation that would support Project Vote’s costs. 

3.	 Recover all unsupported and unallowable costs paid to Project Vote under the two 

grants issued in 2006. 

4.	 Follow policy and procedure established in the grant awards in obtaining and 

maintaining required reporting documents. 

PROJECTVOTECOMMENTS

Project Vote in a letter to the Office of Inspector General dated June 9, 2010, (Appendix 

3) provided additional information concerning the two grants issued to Project Vote in 

2006. In its letter, Project Vote indicated that it had provided all of the documents that 

were in its possession to the Office of Inspector General. Project Vote also felt that the 

documents that it had submitted showed that the projects were successfully completed. 

Project Vote also indicated that it had attempted to obtain records from its sub-contractor. 

The letter further stated that Project Vote was no longer affiliated with ACORN. 

5 
U.S.ELECTIONASSISTANCECOMMISSIONCOMMENTS

In its response to the draft report (Appendix 2), the EAC generally concurred with the 

findings and recommendations. The response indicated that the EAC would work with 

Project Vote to recover any unsupported or unallowable costs. 

6 
 

 

 

APPENDIX 1 

MONETARY IMPACT 

Description 

Questioned 

Costs 

Project Vote Delaware $ 16,875 

Project Vote Michigan $16,875 

Totals $33,750 

7 
Appendix 2

EAC RESPONSE TO THE DRAFT AUDIT: 

OIG Performance Audit Report on the Administration of 

Payments Received Under the Help America Vote Act 

College Program by Project Vote 

October 29, 2010 

MEMORANDUM 

To: Curtis Crider 

 Inspector General 

From: Thomas Wilkey 

 Executive Director 

Subject: Draft Audit Report – “Administration of Grant Funds Received 

Under the Help America Vote Act College Program by Project 

Vote”. 

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

Project Vote. 

The Election Assistance Commission (EAC) generally concurs with the results of 

the review and recommendations. Project Vote maintains that the work outlined 

in the grants received from EAC was successfully completed. However, Project 

Vote was unable to locate any cost or accounting records to support its or 

ACORN’s expenditures under the grant awards. EAC will work with Project Vote 

to recover any unsupported or unallowable costs from Project Vote. 

8
APPENDIX 3 


Curtis Crider Jtme 9, 2010 

Inspector General 

United States Ekctlons Assistance Commission 

Office ofthe Inspector General 

1225 New York Avenue, NW Suite 1100 

Washington DC 20005 

Electronically delivered 

Re: 	 Project VoteNoting for America, Inc. 

Applications Nos. EAC 060035 and 060036 

Dear Mr. Crider: 

Project Vote informed you that it had provided all the documents you requested that was 

in its possession on April 20, 2007. Realizing that we had not given you a summary ofthose 

documents I wanted to follow up with this letter before you completed your investigation. 

Your audit was initiated because Congress requested the EAC audit ACORN and 

ACORN affiliated organizations. As ofJuly, 2008 Project Vote is no longer "affiliated" with 

ACORN under any definition ofthe word. While Project Vote has always been a separate, 

independent corporation and has had a separate, independent Board, we understand that because 

Project Vote has worked closely with ACORN on voter participation matters and shared a 

common employee until July 2008 that the EAC felt compelled to initiate the audit. I would like 

to further state that Project Vote no longer has any working relationships with ACORN. 

The audit relates to the two above captioned grants provided to Project Vote in 2006 to 

facilitate college stl~deilt participation as poll workers in elections held in November 2006. The 

grants were issued 1:0 Project Vote for work in Michigan and Delaware. Project Vote has 

provided you wi1th the only four documents it has in its possession that are related to the grants: a 

spread sheet report ofthe students participating in the program in Delaware, a May 2007 final 

report ofthe Delaware project, a Saginaw Michigan Activity Report and a May 2007 final report 

ofthe Michigan Project. The activity report from Saginaw states that the program was such a 

success that the election officials called and asked that outreach be stopped. In Delaware 125 

students were refened to training or trained under the project and 16 were selected as poll 

workers. As you appeared to agree during our conversation, this shows that the projects funded 

by the grants were completed successfully. Despite our requests to the sub-contractor Project 

Vote used to do the outreach and conduct the training, we did not receive any contemporaneous 

records oftime and resources expended pursuant to the projects. If, because ofthis, you feel the 

documentation is not adequate to support the expenditure, Project Vote is prepared to return a 

proportion or all ofthe funds provided as you see fit. 

737 1/2 8th Street SE • Washington, DC 20003 

1-800-546-8683 • www.projectvote.org 

9 
APPENDIX 3 


Please feel free to call me if you have any questions. 

Sincerely, 

/--- v-- MiL· 

Brian Mellor 


Senior Counsel 


Project VoteNoting for America, Inc. 


202-553 4317 


bmellor@projectvote.org 


10 

 

 

 

OIG’s Mission 

The OIG audit mission is to provide timely, high-quality 

professional products and services that are useful to OIG’s clients. 

OIG seeks to provide value through its work, which is designed to 

enhance the economy, efficiency, and effectiveness in EAC 

operations so they work better and cost less in the context of 

today's declining resources. OIG also seeks to detect and prevent 

fraud, waste, abuse, and mismanagement in these programs and 

operations. Products and services include traditional financial and 

performance audits, contract and grant audits, information systems 

audits, and evaluations. 

Obtaining 

Copies of 

OIG Reports 

Copies of OIG reports can be requested by e-mail. 

(eacoig@eac.gov). 

Mail orders should be sent to: 

U.S. Election Assistance Commission 

Office of Inspector General 

1201 New York Ave. NW - Suite 300 

Washington, DC 20005 

To order by phone: Voice: (202) 566-3100 

Fax: (202) 566-0957 

To Report Fraud, 

Waste and Abuse 

Involving the U.S. 

Election Assistance 

Commission or Help 

America Vote Act 

Funds 

By Mail: U.S. Election Assistance Commission 

Office of Inspector General 

 1201 New York Ave. NW - Suite 300 

 Washington, DC 20005 

E-mail: eacoig@eac.gov 

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

FAX: 202-566-0957