Report No. 

E-HP-MS-01-16 

August 2017 

U.S. ELECTION ASSISTANCE
 

COMMISSION 

OFFICE OF INSPECTOR GENERAL 

FINAL REPORT: 

ADMINISTRATION OF PAYMENTS RECEIVED 

UNDER THE HELP AMERICA VOTE ACT BY 

THE MISSISSIPPI SECRETARY OF STATE
 

APRIL 10, 2003THROUGH SEPTEMBER 30, 2015 
 

 

 

 

 

 

 

 

 

 

 

OFFICE OF THE INSPECTOR GENERAL 

MEMORANDUM 

To:	 Brian Newby 

Executive Director 

From:	 Patricia L. Layfield 

Inspector General 

Date:	 August 24, 2017 

Subject:	 Final Performance Audit Report - Administration of Payments Received 

Under the Help America Vote Act by the Mississippi Secretary of State 

(Assignment Number E-HP-MS-01-16) 

We contracted with the independent certified public accounting firm of McBride, Lock & 

Associates, LLC to audit the administration of payments received under the Help America Vote 

Act (HAVA) by the Mississippi Secretary of State (MSSOS). 

In its audit, McBride, Lock & Associates, LLC concluded that the Office generally accounted for 

and expended the HAVA funds in accordance with applicable requirements for the period from 

April 10, 2003 through September 30, 2015. However the following exceptions were identified: 

1.	 The Office did not adequately support all salaries and wages charged to the grant 

award. 

2.	 The Office did not provide adequate documentation to support allowability for certain 

expenditures. 

3.	 The Office expended $66,878 of HAVA funds for purposes that are not allowable under 

the award's terms and conditions or HAVA regulations. 

In the report, McBride, Lock & Associates, LLC summarized the MSSOS response to the reported 

recommendations, as well as their comments on the responses after the recommendations. 

The MSSOS office generally agreed with the findings and recommendations. The EAC indicated 

that it would work with the MSSOS to resolve the issues in the report. The MSSOS complete 

1
 
2 

response is included as Appendix A-1 and the EAC’s complete response is included as Appendix

A-2. 

We would appreciate being kept informed of the actions taken on our recommendations as we 

will track the status of their implementation. Please respond in writing to the findings and 

recommendations included in this report by October 20, 2017. Your response should include 

information on actions taken or planned, targeted completion dates, and titles of officials 

responsible for implementation.

To fulfill our responsibilities under Government Auditing Standards, the Office of Inspector 

General:

• Reviewed McBride, Lock & Associates, LLC'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 the audit report, prepared by McBride, Lock & Associates, LLC to ensure 

compliance with Government Auditing Standards; and

• Coordinated issuance of the audit report.

McBride, Lock & Associates, LLC is responsible for the attached auditor’s report and the 

conclusions expressed in the report. We do not express any opinion on the conclusions 

presented in McBride, Lock & Associates, LLC's audit report.

The legislation creating the Office of Inspector General requires that we report to Congress 

semiannually on all audit reports issued, actions taken to implement our recommendations, 

and recommendations that have not been implemented.

If you have any questions regarding this report, please call me at (301) 734-3104.

Attachment 

cc: Director of Grants and Payments
 

Performance Audit Report 

Administration of Payments Received Under the Help America Vote Act by 

the Mississippi Secretary of State 

Prepared for 

The United States Election Assistance Commission (EAC)
 

Office of Inspector General
 

By 

McBride, Lock & Associates, LLC 

May 2017 

McBRIDE, LOCK & ASSOCIATES, LLC 

CERTIFIED PUBLIC ACCOUNTANTS 

KANSAS CITY 
 

 

Performance Audit Report
 

Administration of Payments Received Under the Help America Vote Act by 

the Mississippi Secretary of State 

TABLE OF CONTENTS 

Page 

EXECUTIVE SUMMARY 1 

BACKGROUND 2 

AUDIT OBJECTIVES 4 

SCOPE AND METHODOLOGY 5 

AUDIT RESULTS 5 

APPENDICES: 

Appendix A-1: Response of the Mississippi Secretary of State to the Draft Report 

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

to the Draft Report 

Appendix B: Audit Methodology 

Appendix C: Monetary Impact as of September 30, 2015 
 

 

 

 

 

 

 

 

 

U.S. Election Assistance Commission
 

Performance Audit Report
 

Administration of Payments Received Under the Help America Vote Act by 

the Mississippi Secretary 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 

Mississippi Secretary of State’s Office (Office) from inception on April 10, 2003 through 

September 30, 2015 to determine whether the Office used payments authorized by Sections 101, 

102, and 251 of the Help America Vote Act of 2002 (the HAVA) in accordance with HAVA and 

applicable requirements; accurately and properly accounted for property purchased with HAVA 

payments and for program income; maintained state expenditures at a level not less than the level 

maintained in the fiscal year ending prior to November 2000; and met HAVA requirements for 

Section 251 funds for an election fund and for a matching contribution. 

In addition, the Commission requires states to comply with certain financial management 

requirements, specifically: 

•	 Comply with the Uniform Administrative Requirements for Grants and Cooperative 

Agreements with State and Local Government, 41 CFR 105-71, (originally Office of 

Management and Budget Circular A-102, also known as the “Common Rule”). 

•	 Expend payments in accordance with cost principles set forth in Cost Principles for State 

and Local Governments, 2 CFR 225, (originally Office of Management and Budget 

Circular A-87) for establishing the allowability or unallowability of certain items of cost 

for federal participation. 

•	 Follow the requirements of the Federal Cash Management and Improvement Act. 

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

•	 Comply with the provisions of Audits of States, Local Governments and Non-Profit 

Organizations (Office of Management and Budget Circular A-133). 

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 

1
 
 

 

 

 

 

 

 

 

 

requirements mentioned above for the period from April 10, 2003 through September 30, 2015. 

The exceptions are as follows: 

1.	 The Office did not adequately support all salaries and wages charged to the grant award. 

2.	 The Office did not provide adequate documentation to support allowability for certain 

expenditures. 

3.	 The Office expended $66,878 of HAVA funds for purposes that are not allowable under 

the award's terms and conditions or HAVA regulations. 

We have included in this report as Appendix A, the Secretary of State’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 payments to States authorized by HAVA under Titles 

I and II, as follows: 

•	 Title I, Section 101 payments are for activities such as complying with HAVA 

requirements for uniform and nondiscriminatory election technology and administration 

requirements (Title III), improving the administration of elections for federal office, 

educating voters, training election officials and pool workers, and developing a State plan 

for requirements payments. 

•	 Title I, Section 102 payments are available only for the replacement of punchcard and lever 

action voting systems. 

•	 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. 

Title II also requires that states must: 

•	 Have appropriated funds equal to five percent of the total amount to be spent for activities 

for which requirements payments are made. 

•	 Maintain the expenditures of the State for activities funded by the requirements payment 

at a level that is not less than the expenditures maintained by the State for the fiscal year 

ending prior to November 2000. 

2
 
 

 

 

 

 

 

 

•	 Establish an election fund for amounts appropriated by the State for carrying out activities 

for which requirements payments are made, for the Federal requirements payments 

received, for other amounts as may be appropriated under law and for interest earned on 

deposits of the fund. 

The Awardee – The Mississippi Secretary of State 

The HAVA funds were awarded to the Mississippi Secretary of State. The Secretary of State is the 

state’s chief elections official. In that capacity, the office is responsible for National Voter 

Registration Act coordination among state registrar agencies and distribution of NVRA 

registration forms. The Office certifies the annual training and qualifications of local election 

officials and party executive committee chairs to conduct primary and general elections. The 

Office is the candidate qualifying office for certain judicial offices and all independent candidates 

for state, state district and legislative district offices. The Office is a member of a three person 

State Board of Election Commissioners which meets to certify certain candidates’ eligibility for 

placement on general election ballots and to adopt an official sample ballot. Finally, the Secretary 

of State totals certified local election returns and certifies election results for statewide, state 

district and legislative district offices. 

Help America Vote Act State of Mississippi State Plan 

The Mississippi Secretary of State’s advisory committee consisted of 27 individuals representing 

a cross-section of election stakeholders. The committee was selected by the chief elections officer, 

the Secretary of State. 

The main objectives of the project funded by HAVA, as set forth in the state plan, were to purchase 

statewide uniform voting systems; purchase, implement, administrate and maintain a computerized 

statewide voter checklist; and training of voters, poll workers, local election officials on HAVA 

implementation. 

The Secretary of State established and maintained an election fund for the exclusive purpose of 

carrying out activities of HAVA. The fund was non-lapsing and accrued interest earned. Additionally, 

the Office managed all expenditures funded by HAVA and did not distribute any of the requirements 

payments to the local units of government. 

3
 
 

 

 

 

AUDIT OBJECTIVES 

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

1.	 Used payments authorized by Sections 101, 102, and 251 of the Grant in accordance with 

Grant and applicable requirements; 

2.	 Accurately and properly accounted for property purchased with Grant payments and for 

program income; 

3.	 Met HAVA requirements for Section 251 funds for creation of an election fund, providing 

required matching contributions, and meeting the requirements for maintenance of a base 

level of state outlays, commonly referred to as Maintenance of Expenditures (MOE). 

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: 

•	 Comply with the Uniform Administrative Requirements for Grants and Cooperative 

Agreements with State and Local Government, 41 CFR 105-71, (originally Office of 

Management and Budget Circular A-102, also known as the “Common Rule”). 

•	 Expend payments in accordance with cost principles set forth in Cost Principles for State 

and Local Governments, 2 CFR 225, (originally Office of Management and Budget 

Circular A-87) for establishing the allowability or unallowability of certain items of cost 

for federal participation. 

•	 Follow the requirements of the Federal Cash Management and Improvement Act. 

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

•	 Comply with the provisions of Audits of States, Local Governments and Non-Profit 

Organizations (Office of Management and Budget Circular A-133). 

4
 
 

 

 

 

 

 

 

 

 

 

 

SCOPE AND METHODOLOGY 

We audited the Grant funds received and disbursed by the Office from April 10, 2003 through 

September 30, 2015 as shown in the following table: 

HAVA HAVA HAVA 

Description Section 101 Section 102 Section 251 Total 

Funds Received from EAC $ 3,673,384 $ 1,778,067 $ 25,152,465 $ 30,603,916

State Matching Funds - - 2,018,328 2,018,328 

Program Income 443,450 102,733 1,588,892 2,135,075 

Total Funds $ 4,116,834 $ 1,880,800 $ 28,759,685 $ 34,757,319

Less Disbursements (4,116,834) (1,880,800) (28,759,685) (34,757,319) 

Fund Balance $ - $ - $ - $ -

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 for the period from April 10, 2003 through September 30, 2015. The exceptions 

to applicable compliance requirements are described below. 

Finding No. 1 – Inadequate Payroll Documentation 

The Mississippi Secretary of State (Office) did not adequately support all salaries and wages 

charged to the grant award. 

Office of Management and Budget (OMB) Circular A-87, Cost Principles for State, Local, and 

Indian Tribal Governments, Attachment B.8.h.(3) states that “Where employees are expected to 

work solely on a single Federal award or cost objective, charges for their salaries and wages will 

be supported by periodic certifications that the employees worked solely on that program for the 

period covered by the certification. These certifications will be prepared at least semi-annually and 

will be signed by the employee or supervisory official having first-hand knowledge of the work 

performed by the employee.” 

Attachment B.8.h.(4), states that “Where employees work on multiple activities or cost objectives, 

a distribution of their salaries or wages will be supported by personnel activity reports or equivalent 

documentation which meets the standards in subsection (5)... Such documentary support will be 

required where employees work on... (b) A Federal award and a non Federal award” 

5
 
 

 

 

 

 

Attachment B.8.h.(5), states that “Personnel activity reports or equivalent documentation must 

meet the following standards: (a) They must reflect an after the fact distribution of the actual 

activity of each employee, (b) They must account for the total activity for which each employee is 

compensated, (c) They must be prepared at least monthly and must coincide with one or more pay 

periods, (d) They must be signed by the employee, and (e) Budget estimates or other distribution 

percentages determined before the services are performed do not qualify as support for charges to 

Federal awards but maybe used for interim accounting purposes.” 

The sample selection of 12 payroll transactions found two instances, related to one employee, in 

which the employee did not have an adequate work effort certification for the pay period. 

Timesheets were not provided for distribution of time between Federal grant activity and district 

activity. 

Of the $55,630 of salary costs reviewed, $8,911 was determined to be unsupported. 

Recommendation 

We recommend that EAC address and resolve the following recommendations that the Mississippi 

Secretary of State’s Office: 

a)	 Transfer into the election fund $8,911 for the questioned salary charges. 

b)	 Implement written policies to ensure that all employees who expend efforts on Federal 

activities to accurately record their time in compliance with Federal Regulations. 

Secretary of State Response: 

If the EAC determines these payments are not allowable under HAVA, the State maintains it has 

expended more than sufficient state funds in payment of election-related expenses to offset this 

expenditure. Specifically, EAC Funding Advisory Opinion FAO-08-008 opines, “it is in the best 

interest of voters to have voting systems that are safe, reliable, secure and functional and that 

inherent to those capabilities is a regular plan of maintenance of the voting system.” The cost of 

preventative maintenance is an allowable HAVA expense. For example, one preventative 

maintenance expense paid by the State solely through state funds in August 2014 was in the amount 

of $285,000. 

Additionally, the Report recommends the State “implement written policies to ensure that all 

employees who expend efforts on Federal activities to accurately record their time in compliance 

with Federal Regulations.” The recommendation is not applicable as the State no longer has 

HAVA or any federal funds. 

Auditor’s Response: 

The Secretary of State acknowledges that salaries may potentially not be allowable. The response 

indicates that additional costs may have been incurred that would otherwise qualify for this grant. 

We recommend that EAC evaluate the salary cost information and work with the Secretary of State 

6
 
 

 

 

 

 

 

to evaluate the allowability of other related costs. The Secretary of State should ensure that work 

certifications are signed and that pay rates are approved. 

Finding No. 2 – Unsupported Costs 

Adequate documentation to support allowability was not provided for certain expenditures. 

Office of Management and Budget Circulars and Guidance, Cost Principles for State, Local, and 

Indian Tribal Governments 2 CFR § 225, Appendix A.C.1.j states, “To be allowable under Federal 

awards, costs must meet the following general criteria: (j) Be adequately documented.” 

The Uniform Administrative Requirements for Grants and Cooperative Agreements with State and 

Local Governments 41 CFR § 105-71.120 (b)(7) (The “Common Rule”) section states that, 

“Accounting records must be supported by such source documentation as cancelled checks, paid 

bills, payrolls, time and attendance records, contracts and subgrant award documents, etc.” 

The Office was unable to provide adequate documentation to support nine of the 60 transactions 

sampled. For these transactions, the Office was unable to provide documentation, outside of the 

transactions description, to show what was purchased. 

The Office expended $134,211 of HAVA funds for these nine transactions. 

The Office did not maintain adequate documentation to support the allowability expenditures 

charged to the HAVA grant as required by federal regulation. 

Recommendation 

We recommend that EAC address and resolve the following recommendations that the Mississippi 

Secretary of State’s Office: 

a)	 Transfer into the election fund $134,211 for the unsupported costs cited above. 

b)	 Develop and implement policies and procedures regarding maintenance of supporting 

source documentation for all Federal expenditures incurred. 

Secretary of State Response: 

The State will respond to each of the nine questioned transactions individually below. 

1.	 Payment to Mississippi Press Services, Inc. dated October 6, 2004. 

HAVA Section 101(b)(1)(C) states in part that funds distributed under this section shall be 

used to carry out educating voters concerning voting procedures and voting rights. The 

EAC issued Funding Advisory Opinion FAO-08-005 (“FAO-08-005”) which further states 

Section 101 funds may be used “at any time to instruct individuals on how to register to 

vote. This would include print, radio, and television advertisements informing individuals 

7
 
 

 

about the need to register to cast a vote, where to register to vote, how to obtain registration 

forms, and how to complete the forms.” 

The State is in possession of the print advertisements related to the payment to Mississippi 

Press Services and will produce the advertisements to the EAC. The content of the 

advertisements informs potential voters of the need to register to vote in advance of the 

November 2004 Presidential Election, the voter registration deadline, how and where to 

register to vote, and advises voters of their voting rights (including their right to cast a vote 

by affidavit/provisional ballot if their name does not appear on the poll list and their right 

to receive assistance if they are blind, are unable to read, or have some other disability). 

The State maintains this expenditure is allowable under HAVA Section 101(b)(1)(C) and 

FAO-08-005. 

2. Payment to Nick Clark Printing and Signs dated June 1, 2005. 

The State is in possession of supporting documentation which attributes this expense to the 

printing of polling place signage related to the prohibition against campaigning within 150 

feet of a polling place. If the EAC determines this payment is not allowable, the State again 

maintains it has expended more than sufficient state funds to offset such amount. 

3. Payment to G. Williams & Associates, Inc. dated December 29, 2008. 

The State is in possession of the script used in connection with the payment to G. Williams 

& Associates for radio advertisement placement and will produce it to the EAC. The 

content of the script informs individuals of the need to register to vote in advance of the 

2008 Presidential Election and directs potential voters to the Mississippi Secretary of 

State’s website to obtain more information about where to register to vote and how to 

obtain voter registration forms in accordance with the guidance provided by the EAC in 

FAO-08-005. The State maintains this expenditure was in accordance with the mandate 

of HAVA Section 101(b)(1)(C) and FAO-08-005 as set forth above. 

4. Payment to Boxx Jockey, LLC dated July 15, 2009. 

The State is in possession of the script used in connection with the payment to Boxx Jockey 

for production services to produce a radio advertisement and will produce it to the EAC. 

The content of the script informs individuals they need to register to vote in advance of the 

2008 Presidential Election and directs potential voters to the Mississippi Secretary of 

State’s website to obtain more information about where to register to vote and how to 

obtain voter registration forms in accordance with the guidance provided by the EAC in 

FAO-08-005. The State maintains this expenditure was in accordance with the mandate of 

HAVA Section 101(b)(1)(C) and FAO-08-005 as set forth above. 

5. Payment to Coalition for Citizens with Disabilities dated January 17, 2007. 

HAVA provides that funds received under its provisions shall be used for making polling 

places accessible to individuals with disabilities, including the blind and visually impaired, 

8
 
 

 

 

 

in a manner that provides the same opportunity for access and participation as for other 

voters. 

The Coalition for Citizens with Disabilities surveyed Mississippi’s more than 1,800 polling 

places and conducted a needs assessment to determine improvements necessary to ensure 

each was accessible to individuals with disabilities and therefore compliant with the 

Americans with Disabilities Act, as well as HAVA. This expense was paid for by HAVA 

funds based upon a grant request to and award letter issued by the United States Department 

of Health and Human Services. The State is in possession of (1) the contents of the survey; 

(2) the State’s application for HAVA funds (which states part of the funds, if awarded, 

would be used for the needs assessment study conducted by Coalition for Citizens with 

Disabilities); and (3) the award letter from the United States Department of Health and 

Human Services approving said application. The State will provide these documents to the 

EAC. The State maintains the payment to the Coalition for Citizens with Disabilities was 

in accordance with the mandate of HAVA and the terms and conditions of the grant 

awarded to it under HAVA. 

6. Payment to Yazoo County dated June 6, 2007. 

HAVA Section 101(b)(1)(G) provides, in part, that funds received under its provisions may 

be used to improve the accessibility of polling places, including providing physical access 

for individuals with disabilities. 

The State is in possession of an invoice from the Yazoo County Board of Supervisors 

requesting reimbursement for polling place improvements for accessibility for individuals 

with physical disabilities and detailed documentation of said improvements (installation of 

handicap accessible door locks, signage, and ramps) and will produce said documentation 

to the EAC. The State maintains the payment to Yazoo County was in accordance with the 

mandate of HAVA Section 101(b)(1)(G). 

7. Payment to WLOX Inc. dated February 10, 2009. 

The State is in possession of the script used in connection with the payment to WLOX for 

airtime to run an informational voter registration advertisement and will produce it to the 

EAC. The content of the script informs individuals of the need to register to vote in advance 

of the 2008 Presidential Election and directs potential voters to the Mississippi Secretary 

of State’s website to obtain more information about where to register to vote and how to 

obtain voter registration forms in accordance with the guidance provided by the EAC in 

FAO-08-005. The State maintains this expenditure was in accordance with the mandate of 

HAVA Section 101(b)(1)(C) and FAO-08-005. 

8. Payment to National Cable Communications, LLC dated April 1, 2009. 

The State is in possession of the script used in connection with the payment to National 

Cable Communications for advertisement placement and will produce it to the EAC. The 

content of the script informs individuals of the need to register to vote in advance of the 

9
 
 

 

 

2008 Presidential Election and directs potential voters to the Mississippi Secretary of 

State’s website to obtain more information about where to register to vote and how to 

obtain voter registration forms in accordance with the guidance provided by the EAC in 

FAO-08-005. The State maintains this expenditure was in accordance with the mandate of 

HAVA Section 101(b)(1)(C) and FAO-08-005. 

9. Payment to Sir Speedy, Inc. dated May 25, 2006. 

HAVA Section 101(b)(1)(D) provides, in part, that HAVA funds shall be used for “training 

election officials, poll workers, and election volunteers.” Further, HAVA Section 102 

required the replacement of punch card and lever voting machines. The TSX Voting 

System was one of the voting systems Mississippi chose as a replacement for the punch 

card and lever voting machines. The payment to Sir Speedy was for printing and delivery 

costs associated with the distribution of the 500-plus page training and process document 

titled “Guide for Conducting Elections in Mississippi with the Statewide TSX Voting 

System” (the Guide). 

The State maintains the payment to Sir Speedy for the printing and distribution of the Guide 

to the officials in charge of elections in all eighty-two (82) counties throughout Mississippi 

in 2006 is an allowable expenditure under HAVA Section 101(b)(1)(D). The Guide is a 

training and process document for election officials to aid them in transitioning to the new 

TSX Voting System as required by HAVA Section 102. The State will make the Guide 

available to the EAC. 

Further, the Report recommends the State “develop and implement policies and procedures 

regarding maintenance of supporting source documentation for all Federal expenditures 

incurred.” This recommendation is not applicable as the State no longer has HAVA or any 

federal funds. 

Auditor’s Response: 

The response provides for additional information regarding the allowability of certain of the items. 

On other questioned items, the response indicates that additional costs, other than those claimed 

were incurred that would otherwise qualify as allowable costs for this grant. The EAC should 

evaluate the detail for the questioned items included in this report. The additional incurred costs 

not previously claimed are not specifically identified in the response. 

Finding No. 3 – Unallowable Costs 

The Office expended HAVA funds for purposes that are not allowable under the award’s terms 

and conditions or HAVA regulations. 

HAVA Section 101 (b)(1) states, “A State shall use the funds provided under a payment made 

under this section to carry out one or more of the following activities: (B) Improving the 

administration of elections for Federal Office. (C) Educating voters concerning voting procedures, 

voting rights, and voting technology. 

10
 
 

 

 

 

The EAC, in its Funding Advisory Opinion FAO-08-005, concluded that, neither Section 101 nor 

251 funds may be used to conduct voter registration drives or get out the vote efforts. Further, the 

EAC concluded that, neither Section 101 nor 251 funds may be used to print, copy, or revise State 

voter registration forms. 

The Office expended $62,117 of HAVA funds for four transactions for advertising which would 

be considered get out the vote efforts. The Office expended $4,761 of HAVA funds for one 

transaction which was for voter registration forms. These costs are not allowable under HAVA 

Section 101(b)(1)(B) or (C). 

Recommendation 

We recommend that EAC address and resolve the following recommendations that the Mississippi 

Secretary of State’s Office: 

(a) Transfer into the election fund $66,878 for the unallowable costs cited above. 

(b) Perform an analysis of charges incurred for advertising to determine the extent of 

HAVA funds spent on get out the vote efforts. 

(c) Develop and implement policies and procedures and provide training to ensure that 

charges to HAVA are allowable, allocable and reasonable to HAVA. 

Secretary of State Response: 

The State will respond to each of the five questioned transactions individually below. 

1. Payment to SRCP Media Inc. dated September 24, 2010. 

The State is in possession of supplemental and supporting documentation in the form of 

two scripts used in advertisements related to the SRCP Media payment for video 

advertisement production services and will provide this documentation to the EAC. The 

first script informs voters who registered to vote for the first time by mail that they may be 

required to show a form of HAVA-approved identification when they arrive at their polling 

place to vote. Voters are instructed to contact the Office of the Mississippi Secretary of 

State or their local circuit clerk for more information or to answer any questions they may 

have. Further, the script instructs voters to visit the polling place locator located on the 

Mississippi Secretary of State’s website to find information regarding where their polling 

place is located. The second script educates voters about voting procedures and rights 

(including the right to cast an absentee ballot, the applicable qualification requirements for 

voting absentee, and who to contact for more information). The State maintains this 

expenditure was in accordance with the mandate of HAVA Section 101(b)(1)(C) and FAO08-005. 

11
 
 

 

 

 

 

2. Payment to Godwin Advertising Agency, Inc. dated January 15, 2013. 

The State is in possession of two scripts used in advertisements related to the payment for 

airtime to Godwin Advertising Agency and will produce them to the EAC. The content of 

the first script informs potential voters of the voter registration deadline for the 2012 

Presidential Election, where they may register to vote, and when those locations will be 

open for individuals to register to vote. The second advertisement airing after the voter 

registration deadline encouraged voter participation in the upcoming Presidential Election. 

The State maintains some or all of this payment is an allowable expenditure under HAVA 

and again refers to FAO-08-005, which states HAVA “Section 101 funds may be used at 

any time to instruct individuals on how to register to vote” and further expands by stating 

this includes radio advertisements informing individuals about the need to register to cast 

a vote and where to register to vote. If the EAC determines this payment is not allowable, 

the State maintains it has expended more than sufficient state funds to offset such 

expenditure in whole. 

3. Payment to Comcast Spotlight dated January 28, 2013. 

The State is in possession of two scripts used in advertisements related to the payment for 

airtime to Comcast Spotlight and will produce them to the EAC. The content of the first 

script informs potential voters of the voter registration deadline for the 2012 Presidential 

Election, where they may register to vote, and when those locations will be open for 

individuals to register to vote. The second advertisement airing after the voter registration 

deadline encouraged voter participation in the upcoming Presidential Election. The State 

maintains some or all of this payment is an allowable expenditure under HAVA and FAO08-005. If the EAC determines this payment is not allowable, the State maintains it has 

expended more than sufficient state funds to offset such expenditure in whole 

4. Payment to Maris West & Baker, Inc. dated June 17, 2010. 

The State is in possession of the script used in connection to the advertising placement 

related to the payment to Maris West & Baker. Upon additional review of the content of 

the script, the State has determined the nature of the script’s content is “get out the vote.” 

If the EAC determines this payment is not allowable, the State maintains it has expended 

more than sufficient state funds to operate as an offset. 

5. Payment to AmeriMail Direct dated March 9, 2005. 

The State has reviewed the details of the invoice related to the payment to AmeriMail and 

disputes MLA’s finding this expense was not allowable under HAVA. This payment was 

made in 2005, well before the EAC provided any guidance or advisories that would have 

precluded the use of HAVA Section 101 funds for this purpose. The explicit language of 

HAVA Title III permits the expenditure of Section 101 funds for printing and mailing voter 

registration forms. HAVA Section 303(a)(4) specifies the requirements for mail-in 

registration forms; Section 303(d)(2) requires a state to make these materials available to 

voters by 2004. 

12
 
 

 

The EAC first provided guidance in FAO-08-005 on the specific question of using HAVA 

funds to print voter registration forms in August 2008; nearly two and a half years after the 

State made the payment to AmeriMail for printing and distributing voter registration 

applications to potential voters. Although FAO-08-005 states Section 101 funds may not 

be used to print voter registration forms, it also states: “[e]ducating voters on voting 

procedures would include providing instructions on how to register to vote...” Further, it 

states: “Section 101 funds may be used at any time to instruct individuals on how to register 

to vote.” The particular voter registration forms in question here, which include instructions 

on how to register to vote, were updated for potential voters most likely to be impacted by 

new HAVA identification requirements for first-time voters August 11, 2017 who register 

by mail. The State maintains this payment should be allowable under HAVA Section 101 

due to the EAC’s failure to provide specific guidance to the State before the expenditure 

was made. 

Additionally, MLA recommends (1) the State perform an analysis of charges incurred for 

advertising to determine the extent of HAVA funds spent on get out the vote efforts and 

(2) develop and implement policies and procedures and provide training to ensure that 

charges to HAVA are allowable, allocable and reasonable to HAVA. In regards to this 

recommendation, the state responds this recommendation is not applicable as Mississippi 

no longer has HAVA funds. 

Auditor’s Response: 

The response provides for additional information regarding the allowability of certain of the items. 

On other questioned items, the response indicates that additional costs, other than those claimed 

were incurred that would otherwise qualify as allowable costs for this grant. The EAC should 

evaluate the detail for the questioned items included in this report. The additional incurred costs 

not previously claimed are not specifically identified in the response. 

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

Secretary of State. We considered any comments received prior to finalizing this report. 

The Office responded on August 4, 2017 and generally agreed with the report’s findings and 

recommendations. The EAC responded on August 10, 2017 and stated they will work with the 

Secretary’s Office to ensure appropriate corrective action. 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 May 3, 2016 

and July 13, 2017. 

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

McBride, Lock & Associates, LLC 

July 13, 2017 

13
 
APPENDIX A-1
 

Response of the Mississippi 

Secretary of State to the Draft Report
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

August 11, 2017 

Ms. Patricia L. Layfield 

Inspector General 

U.S. Election Assistance Commission 

1335 East West Highway, Suite 4300 

Silver Spring, MD 20910 

Dear Inspector General Layfield, 

The Office of the Mississippi Secretary of State (the State) has received and reviewed the 

Draft Performance Audit Report (the Report) prepared by McBride, Lock & Associates (MLA) in 

connection with the State’s administration of payments received under the Help America Vote Act 

of 2002 (HAVA). 

Since the inception of HAVA and receipt of the funds thereunder, the State has taken the 

utmost care when contemplating the use of HAVA funds and implementing requirements in 

accordance with HAVA. The State appreciates the opportunity to provide a written response to the 

Report and the State is committed to resolving any concerns with the United States Election 

Assistance Commission (the EAC). 

The State disputes the findings of MLA in the Report and maintains the majority of the 

questioned costs therein were allowable expenditures under HAVA. The State sets forth the 

authority under HAVA for those expenditures below and the supporting documentation to the 

EAC. 

Though HAVA funds have been fully exhausted, the State continues to expend in excess 

of $1,000,000 per fiscal year in election related expenditures, specifically those which further and 

fulfill the requirements of HAVA, such as the performance of preventative maintenance of more 

than 7,500 TSX voting machines and the education of Mississippi voters through print and radio 

public service announcements focused upon voters’ rights and voter registration. These electionrelated expenses, solely paid from State resources since the exhaustion of HAVA funds in fiscal 

year 2013, are more than sufficient to offset any amount questioned by MLA. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

August 11, 2017 

Page 2 of 7 

Finding No. 1 – Inadequate Payroll Documentation 

The Report states, generally, the State did not adequately support all salaries and wages 

charged to the grant award. Specifically, MLA noted three instances, related to one employee, in 

which the employee did not have an adequate work effort certification for the pay period and that 

timesheets were not provided for distribution of time between Federal grant activity and district 

activity. 

Additionally, the Report recommends the State “implement written policies to ensure that 

all employees who expend efforts on Federal activities to accurately record their time in 

compliance with Federal Regulations.” 

State’s Response to Finding No. 1 

If the EAC determines these payments are not allowable under HAVA, the State maintains 

it has expended more than sufficient state funds in payment of election-related expenses to offset 

this expenditure. Specifically, EAC Funding Advisory Opinion FAO-08-008 opines, “it is in the 

best interest of voters to have voting systems that are safe, reliable, secure and functional and that 

inherent to those capabilities is a regular plan of maintenance of the voting system.” The cost of 

preventative maintenance is an allowable HAVA expense. For example, one preventative 

maintenance expense paid by the State solely through state funds in August 2014 was in the amount 

of $285,000. 

Additionally, the Report recommends the State “implement written policies to ensure that 

all employees who expend efforts on Federal activities to accurately record their time in 

compliance with Federal Regulations.” The recommendation is not applicable as the State no 

longer has HAVA or any federal funds. 

Finding No. 2 – Unsupported Costs 

The second finding of the Report alleges a lack of documentation, outside of the 

transactions description, to support the allowance of nine transactions. 

State’s Response to Finding No. 2 

The State will respond to each of the nine questioned transactions individually below. 

1. Payment to Mississippi Press Services, Inc. dated October 6, 2004. 

HAVA Section 101(b)(1)(C) states in part that funds distributed under this section shall be 

used to carry out educating voters concerning voting procedures and voting rights. The EAC issued 

Funding Advisory Opinion FAO-08-005 (“FAO-08-005”) which further states Section 101 funds 

may be used “at any time to instruct individuals on how to register to vote. This would include 

print, radio, and television advertisements informing individuals about the need to register to cast 

a vote, where to register to vote, how to obtain registration forms, and how to complete the forms.” 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

August 11, 2017 

Page 3 of 7 

The State is in possession of the print advertisements related to the payment to Mississippi 

Press Services and will produce the advertisements to the EAC. The content of the advertisements 

informs potential voters of the need to register to vote in advance of the November 2004 

Presidential Election, the voter registration deadline, how and where to register to vote, and advises 

voters of their voting rights (including their right to cast a vote by affidavit/provisional ballot if 

their name does not appear on the poll list and their right to receive assistance if they are blind, are 

unable to read, or have some other disability). The State maintains this expenditure is allowable 

under HAVA Section 101(b)(1)(C) and FAO-08-005. 

2. Payment to Nick Clark Printing and Signs dated June 1, 2005. 

The State is in possession of supporting documentation which attributes this expense to the 

printing of polling place signage related to the prohibition against campaigning within 150 feet of 

a polling place. If the EAC determines this payment is not allowable, the State again maintains it 

has expended more than sufficient state funds to offset such amount. 

3. Payment to G. Williams & Associates, Inc. dated December 29, 2008. 

The State is in possession of the script used in connection with the payment to G. Williams & 

Associates for radio advertisement placement and will produce it to the EAC. The content of the 

script informs individuals of the need to register to vote in advance of the 2008 Presidential 

Election and directs potential voters to the Mississippi Secretary of State’s website to obtain more 

information about where to register to vote and how to obtain voter registration forms in 

accordance with the guidance provided by the EAC in FAO-08-005. The State maintains this 

expenditure was in accordance with the mandate of HAVA Section 101(b)(1)(C) and FAO-08-005 

as set forth above. 

4. Payment to Boxx Jockey, LLC dated July 15, 2009. 

The State is in possession of the script used in connection with the payment to Boxx Jockey 

for production services to produce a radio advertisement and will produce it to the EAC. The 

content of the script informs individuals they need to register to vote in advance of the 2008 

Presidential Election and directs potential voters to the Mississippi Secretary of State’s website to 

obtain more information about where to register to vote and how to obtain voter registration forms 

in accordance with the guidance provided by the EAC in FAO-08-005. The State maintains this 

expenditure was in accordance with the mandate of HAVA Section 101(b)(1)(C) and FAO-08-005 

as set forth above. 

5. Payment to Coalition for Citizens with Disabilities dated January 17, 2007. 

HAVA provides that funds received under its provisions shall be used for making polling 

places accessible to individuals with disabilities, including the blind and visually impaired, in a 

manner that provides the same opportunity for access and participation as for other voters. 

The Coalition for Citizens with Disabilities surveyed Mississippi’s more than 1,800 polling 

places and conducted a needs assessment to determine improvements necessary to ensure each was 

accessible to individuals with disabilities and therefore compliant with the Americans with 

Disabilities Act, as well as HAVA. This expense was paid for by HAVA funds based upon a grant 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

August 11, 2017 

Page 4 of 7 

request to and award letter issued by the United States Department of Health and Human Services. 

The State is in possession of (1) the contents of the survey; (2) the State’s application for HAVA 

funds (which states part of the funds, if awarded, would be used for the needs assessment study 

conducted by Coalition for Citizens with Disabilities); and (3) the award letter from the United 

States Department of Health and Human Services approving said application. The State will 

provide these documents to the EAC. The State maintains the payment to the Coalition for Citizens 

with Disabilities was in accordance with the mandate of HAVA and the terms and conditions of 

the grant awarded to it under HAVA. 

6. Payment to Yazoo County dated June 6, 2007. 

HAVA Section 101(b)(1)(G) provides, in part, that funds received under its provisions may be 

used to improve the accessibility of polling places, including providing physical access for 

individuals with disabilities. 

The State is in possession of an invoice from the Yazoo County Board of Supervisors 

requesting reimbursement for polling place improvements for accessibility for individuals with 

physical disabilities and detailed documentation of said improvements (installation of handicap 

accessible door locks, signage, and ramps) and will produce said documentation to the EAC. The 

State maintains the payment to Yazoo County was in accordance with the mandate of HAVA 

Section 101(b)(1)(G). 

7. Payment to WLOX Inc. dated February 10, 2009. 

The State is in possession of the script used in connection with the payment to WLOX for 

airtime to run an informational voter registration advertisement and will produce it to the EAC. 

The content of the script informs individuals of the need to register to vote in advance of the 2008 

Presidential Election and directs potential voters to the Mississippi Secretary of State’s website to 

obtain more information about where to register to vote and how to obtain voter registration forms 

in accordance with the guidance provided by the EAC in FAO-08-005. The State maintains this 

expenditure was in accordance with the mandate of HAVA Section 101(b)(1)(C) and FAO-08-

005. 

8. Payment to National Cable Communications, LLC dated April 1, 2009. 

The State is in possession of the script used in connection with the payment to National Cable 

Communications for advertisement placement and will produce it to the EAC. The content of the 

script informs individuals of the need to register to vote in advance of the 2008 Presidential 

Election and directs potential voters to the Mississippi Secretary of State’s website to obtain more 

information about where to register to vote and how to obtain voter registration forms in 

accordance with the guidance provided by the EAC in FAO-08-005. The State maintains this 

expenditure was in accordance with the mandate of HAVA Section 101(b)(1)(C) and FAO-08-

005. 

9. Payment to Sir Speedy, Inc. dated May 25, 2006. 

HAVA Section 101(b)(1)(D) provides, in part, that HAVA funds shall be used for “training 

election officials, poll workers, and election volunteers.” Further, HAVA Section 102 required the 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

August 11, 2017 

Page 5 of 7 

replacement of punch card and lever voting machines. The TSX Voting System was one of the 

voting systems Mississippi chose as a replacement for the punch card and lever voting machines. 

The payment to Sir Speedy was for printing and delivery costs associated with the distribution of 

the 500-plus page training and process document titled “Guide for Conducting Elections in 

Mississippi with the Statewide TSX Voting System” (the Guide). 

The State maintains the payment to Sir Speedy for the printing and distribution of the Guide 

to the officials in charge of elections in all eighty-two (82) counties throughout Mississippi in 2006 

is an allowable expenditure under HAVA Section 101(b)(1)(D). The Guide is a training and 

process document for election officials to aid them in transitioning to the new TSX Voting System 

as required by HAVA Section 102. The State will make the Guide available to the EAC. 

Further, the Report recommends the State “develop and implement policies and procedures 

regarding maintenance of supporting source documentation for all Federal expenditures incurred.” 

This recommendation is not applicable as the State no longer has HAVA or any federal funds. 

Finding No. 3 – Unallowable Costs 

Finally, the Report asserts the State expended HAVA funds for get out the vote efforts and 

for voter registration forms which MLA concludes are not allowable under HAVA Section 

101(b)(1)(B) or (C). 

State’s Response to Finding No. 3 

The State will respond to each of the five questioned transactions individually below. 

1. Payment to SRCP Media Inc. dated September 24, 2010. 

The State is in possession of supplemental and supporting documentation in the form of two 

scripts used in advertisements related to the SRCP Media payment for video advertisement 

production services and will provide this documentation to the EAC. The first script informs 

voters who registered to vote for the first time by mail that they may be required to show a form 

of HAVA-approved identification when they arrive at their polling place to vote. Voters are 

instructed to contact the Office of the Mississippi Secretary of State or their local circuit clerk for 

more information or to answer any questions they may have. Further, the script instructs voters 

to visit the polling place locator located on the Mississippi Secretary of State’s website to find 

information regarding where their polling place is located. The second script educates voters 

about voting procedures and rights (including the right to cast an absentee ballot, the applicable 

qualification requirements for voting absentee, and who to contact for more information). The 

State maintains this expenditure was in accordance with the mandate of HAVA Section 

101(b)(1)(C) and FAO-08-005. 

2. Payment to Godwin Advertising Agency, Inc. dated January 15, 2013. 

The State is in possession of two scripts used in advertisements related to the payment for 

airtime to Godwin Advertising Agency and will produce them to the EAC. The content of the first 

script informs potential voters of the voter registration deadline for the 2012 Presidential Election, 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

August 11, 2017 

Page 6 of 7 

where they may register to vote, and when those locations will be open for individuals to register 

to vote. The second advertisement airing after the voter registration deadline encouraged voter 

participation in the upcoming Presidential Election. The State maintains some or all of this 

payment is an allowable expenditure under HAVA and again refers to FAO-08-005, which states 

HAVA “Section 101 funds may be used at any time to instruct individuals on how to register to 

vote” and further expands by stating this includes radio advertisements informing individuals 

about the need to register to cast a vote and where to register to vote. If the EAC determines this 

payment is not allowable, the State maintains it has expended more than sufficient state funds to 

offset such expenditure in whole. 

3. Payment to Comcast Spotlight dated January 28, 2013. 

The State is in possession of two scripts used in advertisements related to the payment for 

airtime to Comcast Spotlight and will produce them to the EAC. The content of the first script 

informs potential voters of the voter registration deadline for the 2012 Presidential Election, where 

they may register to vote, and when those locations will be open for individuals to register to vote. 

The second advertisement airing after the voter registration deadline encouraged voter 

participation in the upcoming Presidential Election. The State maintains some or all of this 

payment is an allowable expenditure under HAVA and FAO-08-005. If the EAC determines this 

payment is not allowable, the State maintains it has expended more than sufficient state funds to 

offset such expenditure in whole 

4. Payment to Maris West & Baker, Inc. dated June 17, 2010. 

The State is in possession of the script used in connection to the advertising placement related 

to the payment to Maris West & Baker. Upon additional review of the content of the script, the 

State has determined the nature of the script’s content is “get out the vote.” If the EAC determines 

this payment is not allowable, the State maintains it has expended more than sufficient state funds 

to operate as an offset. 

5. Payment to AmeriMail Direct dated March 9, 2005. 

The State has reviewed the details of the invoice related to the payment to AmeriMail and 

disputes MLA’s finding this expense was not allowable under HAVA. This payment was made in 

2005, well before the EAC provided any guidance or advisories that would have precluded the use 

of HAVA Section 101 funds for this purpose. The explicit language of HAVA Title III permits the 

expenditure of Section 101 funds for printing and mailing voter registration forms. HAVA Section 

303(a)(4) specifies the requirements for mail-in registration forms; Section 303(d)(2) requires a 

state to make these materials available to voters by 2004. 

The EAC first provided guidance in FAO-08-005 on the specific question of using HAVA 

funds to print voter registration forms in August 2008; nearly two and a half years after the State 

made the payment to AmeriMail for printing and distributing voter registration applications to 

potential voters. Although FAO-08-005 states Section 101 funds may not be used to print voter 

registration forms, it also states: “[e]ducating voters on voting procedures would include providing 

instructions on how to register to vote...” Further, it states: “Section 101 funds may be used at any 

time to instruct individuals on how to register to vote.” The particular voter registration forms in 

question here, which include instructions on how to register to vote, were updated for potential 

voters most likely to be impacted by new HAVA identification requirements for first-time voters 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

August 11, 2017 

Page 7 of 7 

who register by mail. The State maintains this payment should be allowable under HAVA Section 

101 due to the EAC’s failure to provide specific guidance to the State before the expenditure was 

made. 

Additionally, MLA recommends (1) the State perform an analysis of charges incurred for 

advertising to determine the extent of HAVA funds spent on get out the vote efforts and (2) develop 

and implement policies and procedures and provide training to ensure that charges to HAVA are 

allowable, allocable and reasonable to HAVA. In regards to this recommendation, the State 

responds this recommendation is not applicable as Mississippi no longer has HAVA funds. 

State’s Proposal for Corrective Action Regarding Unallowable Costs 

Should the EAC determine any expenditure of HAVA funds by the State was unallowable, the 

State maintains any such amount may be offset by the election-related expenditures, and those 

which fulfill and further HAVA specifically, paid solely by the State. To that end, the State will 

provide documentation supporting said allowable expenditures. 

The State appreciates the opportunity to review and respond to the Report. If you have any 

questions or require any additional information, please do not hesitate to contact my office. 

Sincerely, 

Kim Turner 

Assistant Secretary of State, Elections Division 

cc:	 Mark Abbott, Grants Office, U.S. Election Assistance Commission 

Aaron Rhodenbaugh, McBride, Lock & Associates, LLC 

Michael Kenefick, MLKenefick, LLC 
APPENDIX A-2 

Response of the 

U.S. Election Assistance Commission
 

to the Draft Report
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

EAC RESPONSE TO THE DRAFT AUDIT: 

OIG Performance Audit Report on the Administration of Payments 

Received Under the Help America Vote Act by the Mississippi 

Secretary of State for the Period April 10, 2003 through September 

30, 2015. 

August 10, 2017 

MEMORANDUM 

To: Patricia Layfield, Inspector General 

From: Brian Newby, Executive Director 

Subject: Draft Performance Audit Report – “!dministration of Payments Received 

under the Help America Vote Act by the Mississippi Secretary of State 

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

Mississippi Secretary of State. 

The Election Assistance Commission (EAC) appreciates the auditor’s detailed findings 

and recommendations outlined in the draft audit report and will work with the 

Secretary’s Office to ensure appropriate corrective actions are taken in a timely and 

complete manner. 
APPENDIX B 

Audit Methodology 
 

 

 

 

 

 

 

 

 

Appendix B 

AUDIT 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. 

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. 

•	 Analyzed the inventory lists of equipment purchased with HAVA funds. 

•	 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 accounting for salaries. 

•	 Verified the establishment and maintenance of an election fund. 

•	 Verified the State expenditures met the Maintenance of Expenditures requirement 

•	 Conducted site visits of selected counties to observe physical security/safeguard of 

equipment purchased with HAVA funds and ensure compliance with federal regulation. 

•	 Verified that the matching requirement was timely met and 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. 

22
 
APPENDIX C 

Monetary Impact 
 

 

Appendix C 

MONETARY IMPACT AS OF SEPTEMBER 30, 2015 

Additional 

Questioned Funds for 

Description Costs Program 

Unsupported Payroll Costs $ 8,911 $ -

Unsupported Costs 134,211 -

Unallowable Costs 66,878 -

Total $ 210,000 $ -

23