UNITED STATES 

ELECTION ASSISTANCE COMMISSION 

OFFICE OF INSPECTOR GENERAL 

Administration of Payments Received 

Under the Help America Vote Act by 

the Massachusetts Secretary of the 

Commonwealth

Report No. E-HP-MA-11-20
 

 

 

 

 

 

 

~ '3;I 

OFFICE OF THE INSPECTOR GENERAL 

US ELECTION ASSISTANCE COMMISSION 

633 3RD STREET, NW, SUITE 200 

WASHINGTON, DC 20001 

Memorandum 

To: Mona Harrington 

Executive Director 

From: Patricia L. Layfield 

Patricia L. Layfield 

Inspector General 

Date: February 4, 2021 

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

Help America Vote Act by the Massachusetts Secretary of the Commonwealth 

(Assignment Number E-HP-MA-11-20) 

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 Massachusetts Secretary of the Commonwealth 

(MASOC). The audit scope covered the grant funds received and disbursed by the MASOC, from 

June 18, 2018, through September 30, 2019. The $7.9 million in funds paid to the MASOC 

represented Massachusetts’ share of the appropriation of $380 million under the Consolidated 

Appropriations Act of 2018 (P.L. 115-151). MASOC expended approximately $2.0 million of the 

HAVA funds (including state matching funds and program income) during the period covered by 

the audit. 

Results of Audit 

Based on the audit procedures performed, MLA concluded that, except for the matters 

discussed below, the Office the Office generally accounted for and expended the Grant funds in 

accordance with Federal requirements for the period from June 29, 2018 through September 

30, 2019. However, MLA noted the following exceptions: 

1. Program income reported on the Federal Financial Reports (FFRs) was not supported in 

total by the supporting documentation provided by the MASOC. 

Find us here: EAC OIG Website 

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

 

 

 

 

 

 

 

 

2. The Schedule of Expenditures of Federal Awards (SEFA) for the Commonwealth of 

Massachusetts reported $5,280,822 of expenditures for the year ended June 30, 2019 

under Catalog of Federal Domestic Assistance (CFDA) 90.401, Help America Vote Act 

Requirements Payments. The correct CFDA for the $1,474,520 of Election Security Grant 

expenditures for the year ended June 30, 2019 is 90.404. 

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

responded on January 14, 2021 and stated that they are reviewing the Office’s planned actions. 

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 concerning the status of 

your audit follow-up on 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 MLA’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 and selected work products, 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 the 

internal controls or compliance of the MASOC. 

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. 

2 
 

cc: Commissioner Benjamin W. Hovland, Chair 

Commissioner Donald L. Palmer, Vice-Chair 

Commissioner Thomas Hicks 

Commissioner Christy McCormick 

Michelle K. Tassinari, Director and Legal Counsel, Elections Division, Office of the 

Secretary of the Commonwealth of Massachusetts 

Attachment 

3 
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 Massachusetts Secretary of the Commonwealth 

Prepared for 

The United States Election Assistance Commission (EAC) 

Office of Inspector General 

By 

McBride, Lock & Associates, LLC 

December 2020 

4151 N. Mulberry Drive, Suite 275 p. 816-221-4559 admin@mcbridelock.com 

Kansas City, Missouri 64116 f. 816-221-4563 www.mcbridelock.com 
 

----

Performance Audit Report 

Administration of Election Security Payments Received Under the Help 

America Vote Act by the Massachusetts Secretary of the Commonwealth 

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 Massachusetts Secretary of the Commonwealth 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 
 

 

 

 

 

 

 

 

 

 

 

 

U.S. Election Assistance Commission 

Performance Audit Report 

Administration of Election Security Payments Received Under the Help 

America Vote Act by the Massachusetts Secretary of the Commonwealth 

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 Massachusetts Secretary of the Commonwealth’s Office (Office) received 

between June 18, 2018 and September 30, 2019. The objective of the audit was to determine 

whether the Office used payments authorized by Section 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 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 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 18, 2018 through September 30, 2019. 

The exceptions are as follows: 

1. Program income reported on the Federal Financial Reports (FFRs) was not supported in 

total by the supporting documentation provided by the state. 

2. The Schedule of Expenditures of Federal Awards (SEFA) for the Commonwealth of 

Massachusetts reported $5,280,822 of expenditures for the year ended June 30, 2019 under 

Catalog of Federal Domestic Assistance (CFDA) 90.401, Help America Vote Act 

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Requirements Payments. The correct CFDA for the $1,474,520 of Election Security Grant 

expenditures for the year ended June 30, 2019 is 90.404. 

We have included in this report as Appendix A, the Secretary of the Commonwealth’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 Massachusetts Secretary of the Commonwealth 

The HAVA funds were awarded to the Massachusetts Secretary of the Commonwealth (the 

Office). The Secretary of the Commonwealth is the chief record-keeping, public information, 

securities regulator, and elections officer of the Commonwealth. The office is responsible for the 

maintenance of public records, administration of elections, storage of historical data, preservation 

of historical sites, registration of corporations, and the filing and distribution of regulations and 

public documents. The elections are conducted at the municipal level with responsible officials at 

each of the 351 municipalities. 

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Help America Vote Act Commonwealth of Massachusetts Plan 

The State of Massachusetts’ HAVA budget narrative was prepared by the Secretary of the 

Commonwealth. The main objectives of the project funded by HAVA, as set forth in the budget letter, 

were to make funds available as grants to the local election officials for the purchase of voting 

equipment, and additional voter registration technology such as electronic poll books. The Office 

proposed spending part of the budget on upgrades and improvements to the statewide database of 

registered voters. The Office proposed spending a part of the budget, and all of the match, on cyber 

security, specifically on new networking equipment and workstations used by local election officials 

to access the statewide database, and additional equipment to be used for the backup of the statewide 

voter file. The Office expended $1,484,663 for their cities and towns. The funds were for computer 

hardware, software, licensing and training. 

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 18, 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: 

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Election 

Description Security Funds 

Funds Received from EAC $ 7,890,854 

State Matching Funds 394,543 

Program Income 209,764 

Total Funds $ 8,495,161 

Less Disbursements (2,049,194) 

Fund Balance $ 6,445,967 

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 

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 correctly state financial 

information 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. 

4 
 

 

 

 

 

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 18, 2018 through September 

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

Finding No. 1 – Financial Reporting of Program Income 

Program income reported on the Federal Financial Reports (FFRs) was not supported in total by 

the supporting documentation provided by the state. The total program income earned as reported 

by the Office for the Election Security grant was $76,125. The total program income earned as 

documented on the Office’s internal records was $209,764, which is $133,639 more than what was 

reported on the FFR as of September 30, 2019. 

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 

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 discrepancy was caused by formula errors in the Office’s internal records which are used to 

track program income. 

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

and spent in accordance with federal regulations. 

Recommendation 

1. We recommend that the EAC require the Office implement a procedure to perform an 

independent review of significant formulas prior to reporting grant activity in the financial 

reports. 

5 
 

 

 

 

 

 

 

 

 

 

 

 

Secretary of the Commonwealth’s Response: 

The Division is required to report program income in accordance with the terms and conditions of 

the Election Security Grant. The program income reported of the Federal Financial Reports (FFRs) 

was not accurate and were the result of formula errors in the Office’s internal records which are 

used to track program income. 

As noted, in the DAR, appropriate corrective action has been taken to ensure that the cumulative 

data reported to the EAC reflects detailed state records. The Division has strengthened our internal 

controls that require an independent review of all financial report preparation to ensure accurate 

reporting and has established enhanced oversight to properly track expenditures and account for 

grant funds to ensure compliance with HAVA. The Division regularly monitors HAVA grant 

activity, which is being reconciled quarterly. 

Auditor’s Response: 

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

Finding No. 2 – Identification of CFDA on SEFA 

The Schedule of Expenditures of Federal Awards (SEFA) for the Commonwealth of 

Massachusetts reported $5,280,822 of expenditures for the year ended June 30, 2019 under Catalog 

of Federal Domestic Assistance (CFDA) 90.401, Help America Vote Act Requirements Payments. 

The correct CFDA for the $1,474,520 of Election Security Grant expenditures for the year ended 

June 30, 2019 is 90.404. 

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

each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all 

Federal awards received and expended and the Federal programs under which they were received. 

Federal program and Federal award identification must include, as applicable, the CFDA title and 

number, Federal award identification number and year, name of the Federal agency, and name of 

the pass-through entity, if any.” Office of the Comptroller of the Commonwealth of Massachusetts 

MMARS Policy: Federal Grants dated September 8, 2014 states “that a new Major 

Program/Appropriation is created for each new federal grant. There should be only one Major 

Program assigned to an appropriation.” 

The Election Security Grant funds were deposited into the same Appropriation as the original 

HAVA funds and no distinction was made by the Office of the Comptroller for the Election 

Security Grant’s differing CFDA number when preparing the Statewide Schedule of Expenditures 

of Federal Awards. 

Proper identification of a federal program’s CFDA number increases the likelihood that the entity 

complies with the requirements of that program. 

6 
 

 

 

 

 

Recommendation 

2. We recommend that the EAC require the Office to follow the implemented policy from the 

Office of Comptroller to ensure amounts reported by the Office of the Comptroller on the 

Statewide SEFA are accurate and are properly identified by CFDA title and number in 

compliance with Uniform Guidance. 

Secretary of the Commonwealth’s Response: 

The Catalog of Federal Domestic Assistance (CFDA) of Election Security Grant expenditures for 

the year ended June 30, 2019 is 90.404 but was incorrectly reported under CFDA 90.401 by a 

different state agency. The Election Security Grant funds were deposited into the same 

Appropriation as the original HAVA funds and no distinction was made by the Office of the 

Comptroller for the Election Security Grants differing CFDA number when preparing the 

Statewide Schedule of Expenditures of Federal Awards. 

Presently, the Commonwealth of Massachusetts State Comptroller’s Office reports all HAVA 

grant program expenditures on one line item. In accordance with your recommendation, we will 

contact the Comptroller’s Office and formally request that they modify federal HAVA reporting 

to identify each grant separately. 

Auditor’s Response: 

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

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

Secretary of the Commonwealth. We considered any comments received prior to finalizing this 

report. 

The Office responded on January 11, 2021 and generally agreed with the report’s findings and 

recommendations. The EAC responded on January 14, 2021 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 December 1, 2020. 

(Original Signed by McBride, Lock & Associates, LLC) 

McBride, Lock & Associates, LLC 

Kansas City, Missouri 

December 1, 2020 

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APPENDIX A-1 

Response of the Massachusetts 

Secretary of the Commonwealth to the Draft Report 
 

 

 

 

 

 

 

 

 

 

 

 

 

The Commonwealth of Massachusetts 

William Francis Galvin, Secretary of the Commonwealth 

Elections Division 

January 11, 2021 

Patricia L. Layfield 

Inspector General 

U.S. Election Assistance Commission 

633 3rd Street, NW, Suite 200 

Washington, DC 20001 

Aaron Rhodenbaugh 

McBride, Lock and Associates 

4151 N. Mulberry Drive, Suite 275 

Kansas City, MO 64116 

Dear Ms. Layfield and Mr. Rhodenbaugh: 

The Elections Division within the Office of the Secretary of the Commonwealth (Division) 

welcomes the opportunity to respond to the Draft Audit Report (DAR) prepared by McBride, 

Lock and Associates (MLA) in connection with the Election Security Payments received under 

the Help America Vote Act (HAVA), covering the period June 18, 2018 through September 30, 

2019. 

Since the inception of HAVA, the Division has taken extra care in considering the use of 

HAVA funds and implementing requirements in accordance with HAVA. With these new funds 

dedicated to election security, the Division carefully reviews all guidance available to ensure 

funds are used for their intended purpose and in accordance with law and regulation. We 

appreciate the recognition that the Division accounted for and expended the HAVA funds in 

accordance with the requirements, properly accounted for and controlled property purchased, 

and used the funds in a manner consistent with the budget plan submitted. The Division 

welcomes the opportunity to provide written responses to the draft report’s findings and 

recommendations and is committed to resolving any concerns set forth in the report. Please 

find our written responses below. 

Finding No. 1 – Financial Reporting of Program Income 

The Division is required to report program income in accordance with the terms and 

conditions of the Election Security Grant. The program income reported of the Federal 

Financial Reports (FFRs) was not accurate and were the result of formula errors in the Office’s 

internal records which are used to track program income. 

One Ashburton Place, 17th Floor, Boston, Massachusetts 02108 • (617) 727-2828 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

As noted, in the DAR, appropriate corrective action has been taken to ensure that the 

cumulative data reported to the EAC reflects detailed state records.

1 The Division has 

strengthened our internal controls that require an independent review of all financial report 

preparation to ensure accurate reporting and has established enhanced oversight to properly 

track expenditures and account for grant funds to ensure compliance with HAVA. The Division 

regularly monitors HAVA grant activity, which is being reconciled quarterly. 

Finding No. 2 – Identification of CFDA on SEFA 

The Catalog of Federal Domestic Assistance (CFDA) of Election Security Grant 

expenditures for the year ended June 30, 2019 is 90.404 but was incorrectly reported under 

CFDA 90.401 by a different state agency. The Election Security Grant funds were deposited into 

the same Appropriation as the original HAVA funds and no distinction was made by the Office of 

the Comptroller for the Election Security Grants differing CFDA number when preparing the 

Statewide Schedule of Expenditures of Federal Awards. 

Presently, the Commonwealth of Massachusetts State Comptroller’s Office reports all 

HAVA grant program expenditures on one line item. In accordance with your recommendation, 

we will contact the Comptroller’s Office and formally request that they modify federal HAVA 

reporting to identify each grant separately. 

Conclusion: 

The Division appreciates the opportunities afforded by Election Security Grant to ensure 

our elections are safe and secure and have used the funds to create a cyber-security team that 

works directly with our local election officials. The Division will continue to use these security 

funds to improve the administration of federal elections in the Commonwealth. Finally, the 

Division welcomes guidance provided by the EAC on HAVA funding requirements including that 

specific to security funding and remains committed to working with the OIG and EAC in the 

future. 

Thank you for your attention to this matter. Please do not hesitate to contact me if you 

have any questions or require any additional information. 

Very truly yours, 

Michelle K. Tassinari 

Director/Legal Counsel 

Elections Division 

Office of the Secretary of the Commonwealth 

cc: Kinza Ghaznavi 

1 As soon as the formula error was brought to our attention by the auditing team, we filed an amended 

Election Security Federal Financial Report to correct the income reporting discrepancy. 

2 
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: January 14, 2021 

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

Payments Received under the Help America Vote Act by the 

Massachusetts Secretary of the Commonwealth 

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

grant funds to Massachusetts. 

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

Massachusetts Secretary of the Commonwealth’s planned actions. The Secretary’s office 

submitted a revised Federal Financial Report (FFR) to correct the miscalculation errors 

and is working with the state comptroller’s office to modify HAVA reporting to report 

grants separately. 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. 
 

 

 

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: 

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Objective 

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 No No 

Monitoring 

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

17. Evaluates and communicates deficiencies No No No 

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 

Commonwealth’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 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 

Commonwealth’s reporting objectives. 

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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 

Commonwealth’s proper accounting and control over 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 

Commonwealth’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. 

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Appendix C 

EXPENDITURES BY BUDGET CATEGORY AND PROGRAM CATEGORY 

JUNE 18, 2018 TO SEPTEMBER 30, 2019 

Budget Categories 

Voting 

Equipment 

Election 

Auditing 

Program Categories 

Voter 

Registration Cyber 

Systems Security Communications Other Total 

Personnel (Including Fringe) 

Equipment 

Subgrants 

Training 

All Other Costs 

$ -

-

-

-

-

$ -

-

-

-

-

$ -

1,223,794 

-

-

-

$ -

-

-

-

430,857 

$ -

-

-

-

-

$ -

-

-

-

-

$ -

1,223,794 

-

-

430,857 

Total Direct Costs 

Indirect Costs (if applied) 

$ -

-

$ -

-

$ 1,223,794 

-

$ 430,857 

-

$ -

-

$ -

-

$ 1,654,651 

-

Total Federal Expenditures 

Non-Federal Match 

Total Program Expenditures 

$ 

$ 

-

-

-

$ 

$ 

-

-

-

$ 1,223,794 

-

$ 1,223,794 

$ 430,857 

394,543 

$ 825,400 

$ 

$ 

-

-

-

$ 

$ 

-

-

-

$ 1,654,651 

394,543 

$ 2,049,194 

14 
Appendix D 

MONETARY IMPACT AS OF SEPTEMBER 30, 2019 

Additional 

Questioned Unsupported Funds for 

Description Costs Costs Program 

None $ - $ - $ -

Total $ - $ - $ -

15 
 

 

 

 

 

 

 

 

 

 

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