OFFICE OF INSPECTOR GENERAL

U.S. Election Assistance Commission

AUDIT OF THE HELP AMERICA VOTE ACT GRANTS 

AWARDED TO THE COMMONWEALTH OF 

PENNSYLVANIA

Report No. G22PA0014-22-07

September 22, 2022
HIGHLIGHTS

Report No. G22PA0014-22-07

What OIG Audited 

The Office of Inspector General, through the 

independent public accounting firm of McBride, 

Lock & Associates, LLC, audited funds received by 

the Commonwealth of Pennsylvania under the Help 

America Vote Act (HAVA), including state matching 

funds and interest earned, totaling $53.4 million. 

This included Election Security, reissued Section 

251, and Coronavirus Aid, Relief, and Economic 

Security (CARES) Act grants. 

AUDIT OF THE HELP AMERICA VOTE 

ACT GRANTS AWARDED TO THE 

COMMONWEALTH OF PENNSYLVANIA

What OIG Recommended

The Office of Inspector General made six 

recommendations to address the noted deficiencies:

September 22, 2022

What OIG Found

The Pennsylvania Department of State generally 

accounted for and expended HAVA funds in 

accordance with applicable requirements and used 

the funds in a manner consistent with informational 

plans submitted during the audit period. 

However, the Department (1) did not have 

timesheets to support $80,026 in salary and fringe 

costs for three employees; (2) reimbursed a county 

$15,198 for a purchase that was made before the 

approved budget period; and (3) did not ensure that 

four counties were properly maintaining property 

records.

The objectives of the audit were to determine 

whether the Commonwealth of Pennsylvania: 

(1) used funds for authorized purposes in

accordance with Section 101 and 251 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.

U.S. Election Assistance Commission | Office of Inspector General

The Department has already taken action to resolve 

Recommendations 3 and 4. They will be closed upon 

report issuance.
OFFICE OF INSPECTOR GENERAL

U.S. Election Assistance Commission

DATE: September 22, 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 Commonwealth of 

Pennsylvania (Report No. G22PA0014-22-07)

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

Commonwealth of Pennsylvania. 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. 

OIG has reviewed the actions taken by the Commonwealth of Pennsylvania in response to the 

report’s six recommendations. Recommendations 3 and 4 will be closed upon report issuance.

Please keep us informed of the actions taken on the report’s remaining four 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 Pennsylvania Department of State 

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 p. 816-221-4559 admin@mcbridelock.com 

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

 

 

 

 

 

 

Performance Audit Report 

Administration of Payments Received Under the Help America Vote Act by 

the Pennsylvania Department of State 

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 Pennsylvania Department of State to the Draft Report 

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

to the Draft Report 

Appendix B: Audit Scope and Methodology 

Appendix C-1: Election Security Expenditures by Budget Category and Program 

Category 

Appendix C-2: Section 251 Reissued Expenditures by Spending Category 

Appendix C-3: CARES Act Expenditures by Cost Category 

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

Section 251 Reissued Grants and as of December 31, 2020 for CARES 

Act Grant 
 

 

 

 

 

 

 

 

 

 

 

 

U.S. Election Assistance Commission 

Performance Audit Report 

Administration of Payments Received Under the Help America Vote Act by 

the Pennsylvania Department of State 

EXECUTIVE SUMMARY 

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

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

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

Pennsylvania Department of State’s Office (Office). The payments received by the Office are 

identified as Election Security, Section 251 Reissued, and the CARES Act. The scope of the audit 

includes: Election Security administration from inception on August 3, 2018 through September 

30, 2020; Section 251 Reissued administration from inception on October 1, 2018 through 

September 30, 2020; CARES Act administration from inception on April 23, 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: 

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1. For 15 of 56 payroll charges selected for testing ($53,031 of salary and $26,995 of fringes) 

the employee did not maintain a timesheet supporting their efforts. The 15 payroll charges 

were for three employees. 

2. One of 14 subaward reimbursements selected for testing included an election equipment 

invoice dated March 2017 in the amount of $72,405 which was partially reimbursed in the 

amount of $15,198 by the Office using 2020 Election Security Grant funds. March 2017 is 

before the approved budget period of the 2020 Election Security grant of December 21, 

2019 – December 20, 2024. 

3. The Office’s monitoring of subrecipients did not ensure that property records were 

maintained in compliance with 2 CFR 200. Four out of 67 counties were selected for 

physical observation of equipment. The four counties were Chester, Dauphin, Luzerne and 

Montgomery. These four counties represented $2,413,828 of the State’s reported 

expenditures. None of the four counties had inventory listings in compliance with 2 CFR 

200.313(d)(1). 

We have included in this report as Appendix A, the Department of State’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. 

• 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 Reissued and CARES Act grants also require that states 

must: 

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

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• 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 Pennsylvania Department of State 

The HAVA funds were awarded to the Pennsylvania Department of State. The Secretary of the 

Commonwealth is appointed by the Governor and confirmed by the Senate. The Secretary is 

Pennsylvania’s Chief Election Official. 

Help America Vote Act Commonwealth of Pennsylvania State Plans 

The Commonwealth of Pennsylvania’s HAVA budget narrative was prepared by the Acting 

Secretary of the Commonwealth. 

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 all new voting systems that are certified to meet state and federal standards. The state issued 

an Invitation for Bid for vendors to submit proposals for these systems from which counties were able 

to choose. The counties were instructed that they must select new voting systems which meet the 

standards by December 31, 2019. The funds were distributed as reimbursements for expenditures made 

on voting equipment by the counties. The grant award and matching funds were distributed to counties 

proportionally based on numbers of registered voters officially certified by counties to the Office. 

Counties submitted to the state documentation of their acceptance of the award and proof of use for 

voting equipment replacement and upgrades. 

The objective of the 2020 project funded by HAVA, as set forth in the budget letter, was to make $7 

million of the grant available as subgrants to the counties, divided proportionally based on numbers of 

registered voters in each county. Counties were required to submit documentation of their acceptance 

of the subgrants and proof of use for approved purposes in order to receive their funds. 

The remaining $8.1 million was to be expended directly by the Office for statewide efforts including 

post-election audit implementation, election security and technology enhancements for the voter 

registration and other cyber systems, training and support for election officials, communications to 

voters, and other technological enhancements to improve statewide election administration and 

security. 

Section 251 Reissued 

On July 30, 2019, the Office was informed of an interim administrative closeout of the HAVA 

Section 251 grant through September 30, 2018. On that date, the unexpended federal share and 

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program income was carried forward and reissued as a new grant. The funds were to be spent in 

accordance with Section 251. 

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 COVID-19, domestically or internationally, for 

the 2020 Federal election cycle. The Office planned to provide public notification and education about 

the change in the date of the primary due to COVID-19 and how to vote by absentee or mail-in ballot, 

including mailings to voters and other paid communications; provide precinct protection supplies, 

including disinfectants and protective masks for election personnel and poll workers to mitigate the 

spread of COVID-19 at in-person polling locations; implement an accessible electronic ballot marking 

device tool to enable voters with disabilities to vote absentee or by mail; implement technology 

modifications to account for the changed primary date and other needs; and provide grants to counties 

for purposes such as the above as well as increased equipment, staffing, and other needs. 

AUDIT OBJECTIVES 

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

1. Used funds for authorized purposes in accordance with Section 101 and Section 251 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 August 3, 

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 audited the Section 251 grant funds reissued to and disbursed 

by the Office from October 1, 2018, through September 30, 2020. We audited the CARES Act 

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grant funds received and disbursed by the Office from April 23, 2020, through December 31, 2020 

including matching fund expenditures made after December 31, 2020. These funds are related 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 $ 28,651,723 $ 6,113,085 $ 14,223,603 

State Matching Funds 673,808 - 2,713,652 

Program Income 488,894 503,131 20,107 

Total Funds $ 29,814,425 $ 6,616,216 $ 16,957,362 

Less Disbursements (15,232,130) (3,088,501) (11,135,612) 

Fund Balance $ 14,582,295 $ 3,527,715 $ 5,821,750 

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, Section 251 

Expenditures detailed by spending 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 

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 

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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. The exceptions to applicable 

compliance requirements are described below. 

Finding No. 1 – Payroll Documentation 

For 15 of 56 payroll charges selected for testing ($53,031 of salary and $26,995 of fringes) the 

employee did not maintain a timesheet supporting their efforts. The 15 payroll charges were for 

three employees. 

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

Awards (Uniform Guidance) 2 CFR 200.430(i)(1) states that, “Charges to Federal awards for 

salaries and wages must be based on records that accurately reflect the work performed. These 

records must: (i) Be supported by a system of internal control which provides reasonable assurance 

that the charges are accurate, allowable, and properly allocated. (ii) Be incorporated into the 

official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the 

employee is compensated by the non-Federal entity, not exceeding 100% of compensated 

activities.” 

In general, the Office’s elections staff enters their time as appropriate for the areas they work on 

each biweekly payroll period. However, in these 15 instances, the employees did not enter their 

time and their efforts were billed by the Office to the HAVA grant. 

Proper documentation of expenses ensures that charges to the grant are accurate, allowable, and 

properly allocated. 

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Recommendation 

We recommend that the EAC require the Office: 

1. Transfer into the election fund $80,026 for the unsupported payroll costs cited above. 

2. Implement procedures and training which ensure that payroll costs are supported with 

records that accurately reflect the work performed and are incorporated into the official 

records before being allocated to the HAVA grants. 

Secretary of State’s Response: 

Staff time for the 15 documented payroll transactions could not be substantiated through paper 

documentation that work completed was relative to the Help America Vote Act activities. 

However, the noted staff were tasked with completion of work for the Commonwealth’s Statewide 

Uniform Registry of Electors (SURE) new IT system, SUREVote. Because there is no written 

documentation on the work completed, the Department has returned all personnel expenditures 

previously allocated to the grant totaling $80,026 to the state election fund on July 29, 2022. 

Additionally, the Department will increase the frequency of information sharing and training as it 

relates to payroll recording. Previously, once annually, the Bureau of Finance and Operations 

Division of Fiscal Management would provide information and updates regarding timesheet 

processing to bureau management on the proper account code information as it relates to all 

activities within the bureau, including work on federal grants. The frequency of communications 

will increase to a quarterly reminder with the next informational push occurring in September 

2022. Subsequent follow-up will also occur in December 2022, March 2023, and June 2023. This 

will be completed annually as part of the new procedure. Lastly, as part of the notifications, 

supervisors will be reminded to review employee timesheets as part of the internal validation 

process to ensure that employees are accurately reporting hours worked to appropriate elections 

programs. 

Auditor’s Response: 

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

Finding No. 2 – Unallowable Costs 

One of 14 subaward reimbursements selected for testing included an election equipment invoice 

dated March 2017 in the amount of $72,405 which was partially reimbursed in the amount of 

$15,198 by the Office using 2020 Election Security Grant funds. March 2017 is before the 

approved budget period of the 2020 Election Security grant of December 21, 2019 – December 

20, 2024. 

The Uniform Guidance at 2 CFR 200.403(h) states that costs must meet the following general 

criteria to be allowable, “Cost must be incurred during the approved budget period.” 

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The Office approved a partial reimbursement on June 16, 2020 of the March 2017 invoice in the 

amount of $15,198. 

The audit noted $15,198 of questioned costs which were determined to not be allowable per the 

Uniform Guidance at 2 CFR 200.403(h). 

Recommendation 

We recommend that the EAC require the Office to: 

3. Transfer into the election fund $15,198 for the questioned costs cited above. 

4. Develop and implement policies and procedures and provide training to ensure that 

subaward reimbursements charged to HAVA are for costs that are allowable, allocable and 

reasonable to HAVA. 

Secretary of State’s Response: 

Due to the high volume of state and federal grants for county boards of elections, the Department 

sent an email to the county (Susquehanna) to request the use of a different allowable expense to 

replace that of the one falling outside the grant period timeline of the 2020 Election Security Grant. 

The Commonwealth issued a state Grant for Election Modernization Systems (GEMS) to counties 

to reimburse 60% of expenses as it related to modernizing aging voting equipment. Since the 

county was still responsible for the remaining 40% of the expenditures, funds from the submitted 

expenses under GEMS were used to reallocate the previously awarded federal grant to an expense 

within the allowable timeframe. The county confirmed the expense was covered under county 

election dollars and not by other grant dollars. 

Additionally, the Department will require the use of the Grant Expenditure Worksheet for county 

reimbursement requests. While this form has been provided for optional use in all previous grant 

award reporting, requiring its use along with the addition of listing the purchase date will allow 

Department staff the ability to do an additional verification that expenditures are within the grant 

period timeline of the grant. 

Auditor’s Response: 

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

resolution process should determine the allowability of the alternate expense proposed by the 

Office to replace the questioned cost. 

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Finding No. 3 – Subrecipient Monitoring 

The Office’s monitoring of subrecipients did not ensure that subrecipient property records were 

maintained in compliance with 2 CFR 200. Four out of 67 counties were selected for physical 

observation of equipment. The four counties were Chester, Dauphin, Luzerne and Montgomery. 

These four counties represented $2,413,828 of the State’s reported expenditures. None of the four 

counties had inventory listings in compliance with 2 CFR 200.313(d)(1). 

The Uniform Guidance at 2 CFR 200.332(d) states that all pass-through entities must: “Monitor 

the activities of the subrecipient as necessary to ensure that the subaward is used for authorized 

purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the 

subaward; and that subaward performance goals are achieved.” 2 CFR 200.313(d)(1) requires that 

“property records must be maintained that include a description of the property, a serial number or 

other identification number, the source of funding for the property (including the FAIN), who 

holds title, the acquisition date, and cost of the property, percentage of Federal participation in the 

project costs for the Federal award under which the property was acquired, the location, use and 

condition of the property, and any ultimate disposition data including the date of disposal and sale 

price of the property.” 

The Office did not perform activity monitoring sufficient to ensure that subrecipients were 

maintaining property records in compliance with Federal statutes and the terms and conditions of 

the subaward resulting in the following: 

• Chester County’s inventory listing consisted of description of property and serial number. 

• Dauphin County’s inventory listing consisted of description of property, serial number, and 

location. 

• Luzerne County’s inventory listing consisted of description of property, serial number, 

acquisition date, cost of the property, and location. 

• Montgomery County did not provide an inventory listing. 

Proper monitoring of subrecipients ensures that equipment purchased with federal funds is being 

used and disposed of in accordance with federal regulations. 

Recommendation 

We recommend that the EAC require the Office to: 

5. Implement procedures or training to ensure that all subrecipients are properly monitored in 

accordance with federal statutes and the terms and conditions of the subaward. 

6. Ensure all property purchased by subrecipients with federal funds is placed on a compliant 

property record. 

Secretary of State’s Response: 

The Department is currently working to issue a new subrecipient grant award from the 

Commonwealth’s 2022 Election Security Grant, specifically to be used by counties to purchase 

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needed equipment for the new SUREVote voter registration and election management system. 

Because this is a new grant award specifically to be used to purchase equipment, the Department 

will use the opportunity to reiterate to counties the importance of compliance with 2 CFR 

200.313(d)(1). All existing Help America Vote Act grant awards signed by the counties note the 

requirement of compliance with the law. To ensure that occurs, the new grant award will include 

detailed information directly from the online eCFR with the correspondence on how to obtain grant 

dollars. 

Additionally, the Department has created a template that county’s must use to record the required 

information of equipment purchased with federal grant dollars for tracking purposes. This will be 

provided and will be required to be returned when requesting grant dollars, and then biennially 

thereafter. Internal policies on the biennial review of county equipment purchased with federal 

dollars are still being reviewed as well as determination of specific bureau responsibilities. 

Auditor’s Response: 

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

The Office responded on August 18, 2022, and generally agreed with the report’s findings and 

recommendations. The EAC responded on August 23, 2022, and stated they will work with the 

Pennsylvania Department of State 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 20, 2021, 

and July 19, 2022. 

McBride, Lock & Associates, LLC 

Kansas City, Missouri 

July 19, 2022 

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APPENDIX A-1 

Response of the 

Pennsylvania Department of State 

to the Draft Report 
 

 

 

 

 

 

 

 

Commonwealth of Pennsylvania 

Department of State 

302 North Office Building 

(717) 787-6458 

MEMORANDUM 

DATE: August 18, 2022 

TO: Brianna Schletz 

U.S. Election Assistance Commission, Inspector General 

FROM: Leigh Chapman 

Acting Secretary of State 

SUBJECT: Help America Vote Act Grant Awards – Audit Responses 

Upon review of the draft audit report on the Administration of Payments Received Under the Help America 

Vote Act by the Pennsylvania Department of State dated July 2022, enclosed you will find audit responses 

and corrective actions: 

1. Finding No. 1 – Payroll Documentation 

- Issue: 15 of 56 payroll charges selected for testing ($53,031 of salary and $26,995 of fringes), 

the employee did not maintain a timesheet supporting their efforts. The 15 payroll charges were 

for three (3) employees. 

- Corrective Action: Staff time for the 15 documented payroll transactions could not be 

substantiated through paper documentation that work completed was relative to the Help America 

Vote Act activities. However, the noted staff were tasked with completion of work for the 

Commonwealth’s Statewide Uniform Registry of Electors (SURE) new IT system, SUREVote. 

Because there is no written documentation on the work completed, the Department has returned 

all personnel expenditures previously allocated to the grant totaling $80,026 to the state election 

fund on July 29, 2022 (Attachment A). 

Additionally, the Department will increase the frequency of information sharing and training as 

it relates to payroll recording. Previously, once annually, the Bureau of Finance and Operations 

Division of Fiscal Management would provide information and updates regarding timesheet 

processing to bureau management on the proper account code information as it relates to all 

activities within the bureau, including work on federal grants (Attachment B). The frequency of 

communications will increase to a quarterly reminder with the next informational push occurring 

in September 2022. Subsequent follow-up will also occur in December 2022, March 2023, and 

June 2023. This will be completed annually as part of the new procedure. Lastly, as part of the 

notifications, supervisors will be reminded to review employee timesheets as part of the internal 

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validation process to ensure that employees are accurately reporting hours worked to appropriate 

elections programs. 

2. Finding No. 2 – Unallowable Costs 

- Issue: One of 14 subaward reimbursements selected for testing included an election equipment 

invoice dated March 2017 in the amount of $72,405 which was partially reimbursed in the amount 

of $15,198 by the Department using 2020 Election Security Grant funds. March 2017 is before 

the approved budget period of the 2020 Election Security grant of December 21, 2019 – December 

20, 2024. 

- Corrective Action: Due to the high volume of state and federal grants for county boards of 

elections, the Department sent an email to the county (Susquehanna) to request the use of a 

different allowable expense to replace that of the one falling outside the grant period timeline of 

the 2020 Election Security Grant. The Commonwealth issued a state Grant for Election 

Modernization Systems (GEMS) to counties to reimburse 60% of expenses as it related to 

modernizing aging voting equipment. Since the county was still responsible for the remaining 

40% of the expenditures, funds from the submitted expenses under GEMS were used to reallocate 

the previously awarded federal grant to an expense within the allowable timeframe. The county 

confirmed the expense was covered under county election dollars and not by other grant dollars 

(Attachment C). 

Additionally, the Department will require the use of the Grant Expenditure Worksheet 

(Attachment D) for county reimbursement requests. While this form has been provided for 

optional use in all previous grant award reporting, requiring its use along with the addition of 

listing the purchase date will allow Department staff the ability to do an additional verification 

that expenditures are within the grant period timeline of the grant. 

3. Finding No. 3 – Subrecipient Monitoring 

- Issue: The Department’s monitoring of subrecipients did not ensure that subrecipient property 

records were maintained in compliance with 2 CFR 200. Four (4) out of 67 counties were selected 

for physical observation of equipment. The four counties were Chester, Dauphin, Luzerne, and 

Montgomery. These four (4) counties represented $2,413,828 of the state’s reported 

expenditures. None of the four (4) counties had inventory listings in compliance with 2 CFR 

200.313(d)(1). 

- Corrective Action: The Department is currently working to issue a new subrecipient grant award 

from the Commonwealth’s 2022 Election Security Grant, specifically to be used by counties to 

purchase needed equipment for the new SUREVote voter registration and election management 

system. Because this is a new grant award specifically to be used to purchase equipment, the 

Department will use the opportunity to reiterate to counties the importance of compliance with 2 

CFR 200.313(d)(1). All existing Help America Vote Act grant awards signed by the counties 

note the requirement of compliance with the law. To ensure that occurs, the new grant award will 

include detailed information directly from the online eCFR (Attachment E) with the 

correspondence on how to obtain grant dollars. 

Additionally, the Department has created a template (Attachment F) that county’s must use to 

record the required information of equipment purchased with federal grant dollars for tracking 

purposes. This will be provided and will be required to be returned when requesting grant dollars, 

and then biennially thereafter. Internal policies on the biennial review of county equipment 

purchased with federal dollars are still being reviewed as well as determination of specific bureau 

responsibilities. 

If you have any questions or need additional information, please contact Kim Mattis, Director, Bureau of 

Finance and Operations, at 772-5193 or at kmattis@pa.gov. 

2 
 

 

 

 

 

 

 

Thank you for your consideration. 

c: Pam Iovino, Executive Deputy Secretary (PA DOS) 

Jonathan Marks, Deputy Secretary for Elections and Commissions (PA DOS) 

Peg Rosenberry, U.S. Election Assistance Commission 

Kimberly Mattis, Director, Bureau of Finance and Operations (PA DOS) 

Julie Snader, Deputy Director, Finance and Operations Manager (PA DOS) 

Amanda Richards, Chief, Fiscal Management (PA DOS) 

3 
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 23, 2022 

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

Department of State 

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

Pennsylvania Department of State 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. Action is complete on Finding #2 and 

Recommendations #3 and #4. 

Finding #1 and Recommendations #1 and #2, Payroll Documentation: The auditors 

noted that 15 of 56 payroll charges selected for testing, totaling $53,031 of salary and 

$26,995 of fringe benefits, did not have employee timesheets supporting their efforts. The 

auditors recommend that the EAC require the Department to: 

1. Transfer into the election fund $80,026 for the unsupported payroll costs cited above. 

2. Implement procedures and training which ensure that payroll costs are supported with 

records that accurately reflect the work performed and are incorporated into the 

official records before being allocated to the HAVA grants. 

Management Decision: The Department explained the unsupported payroll costs 

resulted for three employees whose timesheets were not initially set up for the specific 

HAVA-related activities added to their duties later in the year. They transferred those 

costs to other funding sources and returned the amount to the state election fund. The 

Grants staff confirmed the transfer was completed on July 29, 2022. To address 

Recommendation #2, the Department is revising its notification process and reminders 

concerning timesheets and accurate time accounting. Currently the state sends out an 

annual notification and instructions for timesheets and accurate account coding for 

programs applicable to their areas. To ensure that they capture new hires, temporary staff, 

and others with additional grant duties added during the year, they will start sending the 

notifications out quarterly. The Department staff expects the revised procedure to be in 

place by September 30, 2022. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Finding #2 and Recommendations #3 and #4, Unallowable Costs: The auditors found 

that one of 14 subaward reimbursements selected for testing included an election 

equipment invoice dated March 2017 in the amount of $72,405 which was partially 

reimbursed in the amount of $15,198 by the Department using 2020 Election Security 

Grant funds. March 2017 is before the approved budget period for the 2020 Election 

Security grant began on December 21, 2019. The auditors recommend that the EAC 

require the Department to: 

3. Transfer into the election fund $15,198 for the questioned costs cited above. 

4. Develop and implement policies and procedures and provide training to ensure that 

subaward reimbursements charged to HAVA are for costs that are allowable, 

allocable and reasonable to HAVA. 

Management Decision: The Department provided an accounting record for the 

subwardee, dated August 2, 2022, that demonstrates the unallowable costs were removed. 

To address Recommendation #4, the Department revised its summary expenditure form 

the Department requires subawardees to submit with reimbursement requests. The form 

now requires subawardees to report purchase dates which Department staff review during 

the approval process to ensure expenditures are within the approved budget period. This 

will serve as another check to be sure they review the validity date of the purchase as 

well as confirming the purchase is an allowable expense. The Grants staff reviewed the 

form and confirmed it addresses the recommendation. Action is complete on this finding. 

Finding and Recommendation, Sub-recipient Monitoring: The auditors found that the 

Department’s monitoring of subrecipients did not ensure that subrecipient property 

records were 

maintained in compliance with 2 CFR 200. Four out of 67 counties were selected for 

physical observation of equipment. None of the four counties had inventory listings in 

compliance with 2 CFR 200.313(d)(1). The auditors recommend that the EAC require the 

Department to: 

5. Implement procedures or training to ensure that all subrecipients are properly 

monitored in accordance with federal statutes and the terms and conditions of the 

subaward. 

6. Ensure all property purchased by subrecipients with federal funds is placed on a 

compliant property record. 

Management Decision: The Department is developing an inventory template they 

will require subawardees to use to record all equipment purchased with HAVA funds 

and submit to the Department. That template, along with the specific requirements in 

the regulations, will be sent to the counties when the Department sends out the 

subawards for the 2022 Election Security funds. To address Recommendation #5, 

they will add a process to their monitoring procedures to review the inventories and 

will identify staff responsible for that process. They expect to revise the procedure 

and train identified staff by the end of December 2022. 

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

Department by January 31, 2023. 

2 
 

 

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: 

16 
 

 

 

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 Yes Yes 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 state’s 

proper use of funds and compliance with award requirements. 

The Information and Communication principles of Use Relevant Information, Communicate 

Internally and Communicate Externally were deemed to be significant to our determination of the 

awardee’s compliance with the federal financial reporting portion of this objective. These 

principles address the relevance of the information, the internal communication processes used to 

compile the data necessary to meet the state’s reporting objectives and the external communication 

processes used to inform the counties about grant requirements. 

17 
 

 

 

 

 

 

 

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 Office’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. 

18 
 

 

 

 

 

 

 

 

 

 

 

Appendix C-1 

ELECTION SECURITY EXPENDITURES BY BUDGET CATEGORY AND PROGRAM CATEGORY 

AUGUST 3, 2018 TO SEPTEMBER 30, 2020 

Budget Categories 

Personnel (Including Fringe) 

Equipment 

Subgrants 

Training 

All Other Costs 

Total Direct Costs 

Indirect Costs (if applied) 

Total Federal Expenditures 

Non-Federal Match 

Total Program Expenditures 

Voting 

Equipment 

$ -

31,783 

13,520,608 

-

-

$ 13,552,391 

-

$ 13,552,391 

673,808 

$ 14,226,199 

Program Categories 

Voter 

Election Registration Cyber 

Auditing Systems Security Communications 

$ - $ - $ - $ -

- 59,746 - 855,037 

- - 37,634 21,736 

- - - -

- - - -

$ - $ 59,746 $ 37,634 $ 876,773 

- - - -

$ - $ 59,746 $ 37,634 $ 876,773 

- - - -

$ - $ 59,746 $ 37,634 $ 876,773 

$ 

$ 

$ 

$ 

Other 

-

-

31,778 

-

-

31,778 

-

31,778 

-

31,778 

Total 

$ -

946,566 

13,611,756 

-

-

$ 14,558,322 

-

$ 14,558,322 

673,808 

$ 15,232,130 

19 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix C-1 (Cont’d) 

Subgrant Spending By Program Categories 

Voter 

Voting Election Registration Cyber 

County Equipment Auditing Systems Security Communications Other Total 

LEHIGH COUNTY CHIEF EXEC OFFICER $361,825 $ - $ - $ - $ - $- $361,825 

FRANKLIN COUNTY COMMISSIONERS 144,995 - - - - - 144,995 

BEDFORD COUNTY COMMISSIONERS 49,584 - - 23,556 - - 73,140 

ADAMS COUNTY COMMISSIONERS 104,574 - - - - - 104,574 

HUNTINGDON COUNTY COMMISSIONERS 47,185 - - - - - 47,185 

LEBANON COUNTY COMMISSIONERS 134,417 - - - - - 134,417 

MIFFLIN COUNTY COMMISSIONERS 38,964 - - - - - 38,964 

JUNIATA COUNTY COMMISSIONERS 21,735 - - - - - 21,735 

CHESTER COUNTY COMMISSIONERS 553,465 - - - - - 553,465 

DAUPHIN COUNTY COMMISSIONERS 290,517 - - - - - 290,517 

BUCKS COUNTY COMMISSIONERS 712,432 - - - - - 712,432 

BLAIR COUNTY COMMISSIONERS 119,734 - - - - - 119,734 

DELAWARE COUNTY EXECUTIVE DIRECTOR 627,585 - - - - - 627,585 

SCHUYLKILL COUNTY COMMISSIONERS 135,161 - - - - - 135,161 

BERKS COUNTY COMMISSIONERS 399,913 - - - - - 399,913 

YORK COUNTY COMMISSIONERS 477,237 - - - - - 477,237 

FULTON COUNTY COMMISSIONERS 17,023 - - - 2,188 - 19,211 

LANCASTER COUNTY COMMISSIONERS 514,128 - - - - - 514,128 

CUMBERLAND COUNTY COMMISSIONERS 268,490 - - - - - 268,490 

MONTGOMERY COUNTY COMMISSIONERS 887,077 - - - - - 887,077 

PERRY COUNTY COMMISSIONERS 44,776 - - - - - 44,776 

SNYDER COUNTY COMMISSIONERS 33,735 - - - - - 33,735 

BRADFORD COUNTY COMMISSIONERS 57,489 - - - - - 57,489 

CARBON COUNTY COMMISSIONERS 67,825 - - - - - 67,825 

CENTRE COUNTY COMMISSIONERS 171,026 - - - - - 171,026 

CLINTON COUNTY COMMISSIONERS 32,773 - - - - - 32,773 

COLUMBIA COUNTY COMMISSIONERS 59,974 - - - - - 59,974 

LACKAWANNA COUNTY CHIEF EXEC OFFICER 225,515 - - - - - 225,515 

LUZERNE COUNTY CHIEF EXECUTIVE 326,554 - - - - - 326,554 

20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix C-1 (Cont’d) 

Subgrant Spending By Program Categories (Cont'd) 

Voter 

Voting Election Registration Cyber 

County Equipment Auditing Systems Security Communications Other Total 

LYCOMING COUNTY COMMISSIONERS $ 107,456 $ - $ - $ - $ - $ - $ 107,456 

MONROE COUNTY COMMISSIONERS 166,744 - - - - - 166,744 

MONTOUR COUNTY COMMISSIONERS 20,866 - - 4,903 3,256 2,428 31,453 

NORTHAMPTON COUNTY CHIEF EXEC OFFICER 324,871 - - - - - 324,871 

NORTHUMBERLAND COUNTY COMMISSIONERS 83,034 - - - - - 83,034 

PIKE COUNTY COMMISSIONERS 65,933 - - - - - 65,933 

POTTER COUNTY COMMISSIONERS 16,897 - - - - - 16,897 

SULLIVAN COUNTY COMMISSIONERS 10,621 - - - - - 10,621 

SUSQUEHANNA COUNTY COMMISSIONERS 55,816 - - 1,275 973 4,590 62,654 

TIOGA COUNTY COMMISSIONERS 50,120 - - - - - 50,120 

UNION COUNTY COMMISSIONERS 37,682 - - - - - 37,682 

WAYNE COUNTY COMMISSIONERS 52,109 - - - - - 52,109 

WYOMING COUNTY COMMISSIONERS 26,718 - - - - - 26,718 

FOREST COUNTY COMMISSIONERS 5,290 - - - 2,763 860 8,913 

ELK COUNTY COMMISSIONERS 30,463 - - - - - 30,463 

CAMERON COUNTY COMMISSIONERS 4,624 - - - - - 4,624 

CLARION COUNTY COMMISSIONERS 35,973 - - - - 3,894 39,867 

JEFFERSON COUNTY COMMISSIONERS 47,074 - - - - - 47,074 

ALLEGHENY COUNTY CHIEF EXEC OFFICER 1,471,598 - - - - - 1,471,598 

ARMSTRONG COUNTY COMMISSIONERS 65,218 - - - - - 65,218 

BEAVER COUNTY COMMISSIONERS 173,721 - - 3,225 - - 176,946 

BUTLER COUNTY COMMISSIONERS 200,170 - - - - - 200,170 

CAMBRIA COUNTY COMMISSIONERS 131,374 - - 4,675 - 8,046 144,095 

CLEARFIELD COUNTY COMMISSIONERS 74,055 - - - - - 74,055 

ERIE COUNTY CHIEF EXECUTIVE OFFICER 302,183 - - - - - 302,183 

FAYETTE COUNTY COMMISSIONERS 122,885 - - - - - 122,885 

GREENE COUNTY COMMISSIONERS 34,534 - - - - - 34,534 

21 
 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix C-1 (Cont’d) 

Subgrant Spending By Program Categories (Cont'd) 

Voter 

Voting Election Registration Cyber 

County Equipment Auditing Systems Security Communications Other Total 

INDIANA COUNTY COMMISSIONERS $ 80,552 $ - $ - $ - $ - $ - $ 80,552 

LAWRENCE COUNTY COMMISSIONERS 86,176 - - - - - 86,176 

MERCER COUNTY COMMISSIONERS 112,396 - - - - - 112,396 

MCKEAN COUNTY COMMISSIONERS 37,604 - - - - - 37,604 

SOMERSET COUNTY COMMISSIONERS 73,979 - - - - - 73,979 

VENANGO COUNTY COMMISSIONERS 49,649 - - - - - 49,649 

WASHINGTON COUNTY COMMISSIONERS 223,750 - - - - - 223,750 

WESTMORELAND COUNTY COMMISSIONERS 390,443 - - - - - 390,443 

CRAWFORD COUNTY COMMISSIONERS 82,782 - - - 9,407 10,567 102,756 

WARREN COUNTY COMMISSIONERS 62,574 - - - - 1,393 63,967 

PHILADELPHIA CITY TREASURER 1,676,965 - - - 3,149 - 1,680,114 

Total Direct Costs $ 13,520,607 $ - $ - $ 37,634 $ 21,736 $ 31,778 $ 13,611,756 

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

Total Federal Expenditures $ 13,520,607 $ - $ - $ 37,634 $ 21,736 $ 31,778 $ 13,611,756 

22 
 

Appendix C-2 

SECTION 251 EXPENDITURES BY SPENDING CATEGORY 

OCTOBER 1, 2018 TO SEPTEMBER 30, 2020 

Section 251 

Spending Category Funds 

Voter Registration System $ 3,095,930 

Total Direct Costs $ 3,095,930 

Total Program Expenditures $ 3,095,930 

Note: Difference between Section 251 detailed federal expenditures above and Section 251 

expenditures of $3,088,501 in previous table is due to a corrected variance by the Office. 

23 
 

 

 

 

 

 

Appendix C-3 

CARES ACT EXPENDITURES BY COST CATEGORY 

APRIL 23, 2020 TO DECEMBER 31, 2020 

Expenditure Type 

Cost Categories Federal Match Total 

Voting Processes 

Staffing 

Security and Training 

Communications 

Supplies 

$ 2,359,974 

553,977 

547,001 

2,770,507 

2,174,883 

$ 337,153 

167,549 

-

-

-

$ 2,697,127 

721,526 

547,001 

2,770,507 

2,174,883 

Total CARES Expenditures $ 8,406,342 $ 504,702 $ 8,911,044 

Note: Difference between CARES detailed federal expenditures above and CARES expenditures 

of $8,421,960 in previous table is due to interest income expenditures not being detailed by the 

Office. Difference between CARES matching expenditures above and CARES match of 

$2,713,652 in previous table is due to matching expenditures made after December 31, 2020. 

24 
 

Appendix D 

MONETARY IMPACT AS OF SEPTEMBER 30, 2020 FOR ELECTION 

SECURITY AND SECTION 251 REISSUED GRANTS AND AS OF 

DECEMBER 31, 2020 FOR CARES ACT GRANT 

Additional 

Questioned Unsupported Funds for 

Description Costs Costs Program 

Election Security Grant $ 15,198 $ - $ -

Section 251 Reissued - 80,026 -

Total $ 15,198 $ 80,026 $ -

25 
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