U.S. ELECTION ASSISTANCE 

COMMISSION 

OFFICE OF INSPECTOR GENERAL 

FINAL REPORT: 

Administration of Payments Received 

Under the Help America Vote Act by the 

Connecticut Secretary of State’s Election 

Division
 

APRIL 15, 2003 THROUGH JANUARY 31, 2010 

Report No. 

E-HP-CT-07-10 

September 2010 
U.S. ELECTION ASSISTANCE COMMISSION

OFFICE OF INSPECTOR GENERAL

1201 New York Ave. NW - Suite 300 

Washington, DC 20005

September 28, 2010 

Memorandum 

To: Thomas Wilkey 

 Executive Director 

From: Curtis W. Crider 

 Inspector General 

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

Vote Act by the Connecticut Secretary of State’s Election Division 

 (Assignment Number E-HP-CT-07-10) 

 We contracted with the independent certified public accounting firm of Clifton Gunderson 

LLP (Clifton Gunderson) to audit the administration of payments received under the Help America 

Vote Act (HAVA) by the Connecticut Secretary of State (SOS). The contract required that the audit 

be done in accordance with U.S. generally accepted government auditing standards. Clifton 

Gunderson is responsible for the attached auditor’s report and the conclusions expressed therein. 

 In its audit of the SOS, Clifton Gunderson concluded that, except for the maintenance of 

comprehensive equipment inventories and security over voting equipment, our audit concluded that 

the SOS generally accounted for and expended HAVA funds in accordance with the HAVA 

requirements and complied with the financial management requirements established by the U.S. 

Election Assistance Commission. The SOS also complied with section 251 requirements. 

In her July 22, 2010 response to the draft report (Appendix A-1), the SOS agreed with the 

report’s finding and recommendations, and provided corrective action. Also, we have included in 

the report the EAC response to the draft report (Appendix A-2), dated August 13, 2010, which 

indicated general concurrence with the recommendation. 

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

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

recommendation included in this report by November 30, 2010. Your response should include 

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

responsible for implementation. 

 The legislation, as amended, creating the Office of Inspector General (5 U.S.C. § App.3) 

requires semiannual reporting to Congress on all audit reports issued, actions taken to implement 

audit recommendations, and recommendations that have not been implemented. Therefore, this 

report will be included in our next semiannual report to Congress. 

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

 

 

 

 

 

 

 

PERFORMANCE AUDIT REPORT
 


ADMINISTRATION OF PAYMENTS RECEIVED
 


UNDER THE
 


HELP AMERICA VOTE ACT
 


BY THE
 


STATE OF CONNECTICUT
 


April 15, 2003 Through January 31, 2010 

UNITED STATES ELECTION
 


ASSISTANCE COMMISSION
 


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TABLE OF CONTENTS 

PAGE
 


EXECUTIVE SUMMARY 1 

BACKGROUND 2 

AUDIT OBJECTIVES 3 

SCOPE AND METHODOLOGY 4 

AUDIT RESULTS 4 

APPENDICES
 


Appendix A-1: Secretary of State Response To Audit Results 6 

Appendix A-2: U. S. Election Assistance Commission Response to Draft Report 8 

Appendix B: Audit Methodology 9 

 

 

 

 

 

 

 

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U.S. Election Assistance Commission
 


Performance Audit of the Administration of Payments Received Under the
 


Help America Vote Act by the State of Connecticut
 


EXECUTIVE SUMMARY 

Clifton Gunderson LLP was engaged by the U.S. Election Assistance Commission (EAC or the 

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

Secretary of State (SOS) for the period April 15, 2003 through January 31, 2010 to determine 

whether the SOS used payments authorized by Sections 101, 102, and 251 of the Help America 

Vote Act of 2002 (HAVA or the Act) in accordance with HAVA and applicable requirements; 

accurately and properly accounted for property purchased with HAVA payments and for 

program income, and met HAVA requirements for Section 251 funds for an election fund and for 

a matching contribution. Maintenance of Effort was not included in the scope of our audit 

procedures. Subsequent to the date of our report, on June 28, 2010, the Commission issued its 

revised guidance on the Maintenance of Expenditures (MOE) requirement, which includes a 

provision that the states will have 12 months from the date of the policy to submit a MOE plan to 

the EAC. 

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 Governments (also known as the “Common Rule”) as 

published in the Code of Federal Regulations 41 CFR 105-71. 

•		 Expend payments in accordance with cost principles for establishing the allowance or 

disallowance of certain items of cost for federal participation issued by the Office of 

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

Indian Tribal Governments. 

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

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. Because of inherent 

limitations, a study and evaluation made for the limited purposes of our review would not 

necessarily disclose all weaknesses in administering HAVA payments. 

Except for the maintenance of adequate property records and security over HAVA funded 

equipment, as discussed below, our audit concluded that the SOS generally accounted for and 

expended HAVA funds in accordance with the requirements mentioned above for the period 

from April 15, 2003 through January 31, 2010. The exception needing SOS’s management 

attention is as follows: 

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•		 Inventory listings of voting and SVRS equipment did not conform to the requirements of 

41 C.F.R. 105-71.132 (d) (1), (the Common Rule) at the seven towns we visited. The 

listings did not include required elements such as use, condition or the federal, state, or 

county percentage of ownership. Four of the towns did not have inventory records of 

their handicap accessible voting equipment. One town did not have adequate physical 

security controls over its HAVA funded equipment. 

We have included in this report as Appendix A-1 the SOS management’s formal response to the 

findings and recommendations dated July 22, 2010. The SOS response included the detail 

inventory listings, reflecting the changes that had been implemented to resolve the exceptions 

noted above, which we did not include in Appendix A-1. The listings would add significant volume 

of pages to the report, and will be made available to the EAC upon request for resolution of any 

outstanding issues. Although we have included management’s written responses to our notices 

of findings and recommendations, such responses have not been subjected to the audit 

procedures and, accordingly, we do not provide any form of assurance on the appropriateness of 

the responses or the effectiveness of the corrective actions described therein. SOS officials 

agreed with our recommendations. 

The draft report, including the SOS response, was provided to the Executive Director of the 

EAC for review and comment. The EAC agreed with the report’s conclusions and 

recommendations as well as the Connecticut officials’ initial responses. The EAC’s complete 

response is included as Appendix A-2. 

BACKGROUND 

HAVA created the Commission to assist states and insular areas with the improvement of the 

administration of federal elections and to provide funds to states to help implement these 

improvements. HAVA authorizes payments to states under Titles I and 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, and developing a state plan for requirements 

payments. 

•		 Title I, Section 102 payments are available only for the replacement of punch card and 

lever action voting systems. 

•		 Title II, Section 251 requirements payments are for complying with Title III requirements 

for voting system equipment; and for 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 5 percent of the total amount to be spent for such 

activities [activities for which requirements payments are made].” [Section 253(b) (5)]. 

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•		 “Maintain the expenditures of the state for activities funded by the [requirements] payment 

at a level that is not less than the level of such expenditures maintained by the state for 

the fiscal year ending prior to November 2000.” [Section 254(a)(7)]. 

•		 Establish an election fund for amounts appropriated by the state “for carrying out the 

activities for which the requirements payment is made,” for the Federal requirements 

payments received, for “such other amounts as may be appropriated under law,” and for 

“interest earned on deposits of the fund.” [Section 254(b)(1)]. 

AUDIT OBJECTIVES 

The objectives of our audit were to determine whether the Connecticut Secretary of State: 

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

HAVA and applicable requirements; 

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

program income; 

3.	 	Met HAVA requirements for Section 251 funds for an election fund and for a matching 

contribution. We did not determine whether the SOS met the requirement for 

maintenance of a base level of state outlays, because the Commission is reviewing its 

guidance on the applicability of the maintenance of a base level of state outlays to 

subgrantees of the SOS. 

In addition to accounting for HAVA payments, the Act 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 HAVA funds to 

comply with certain financial management requirements, specifically: 

1.	 	Comply with the Uniform Administrative Requirements for Grants and Cooperative 

Agreements with State and Local Governments (also known as the “Common Rule”) as 

published in the Code of Federal Regulations at 41 CFR 105-71. 

2.	 	Expend payments in accordance with cost principles for establishing the allowance or 

disallowance of certain items of cost for federal participation issued by the OMB. 

3.	 	Submit detailed annual financial reports on the use of Title I and Title II payments. 1 

1 EAC requires states to submit annual reports on the expenditure of HAVA Sections 101, 102, and 251 funds. 

Through December 31, 2008, for Sections 101 and 102, reports were due on February 28 for the activities of the 

previous calendar year, and, for Section 251, reports were due by March 30 for the activities of the previous fiscal 

year ending on September 30. Beginning in calendar year 2009, all reports will be effective as of September 30, 

20XX for the fiscal year ended that date and will be due by December 31, 20XX. 

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SCOPE AND METHODOLOGY 

We audited the HAVA funds received and disbursed by the SOS from April 15, 2003 through 

January 31, 2010 (81-month period) as shown in the following table: 

FUNDS RECEIVED 

TYPE OF 

PAYMENT 

EAC 

PAYMENT 

PROGRAM 

INCOME 

STATE 

MATCH 

INTEREST 

EARNED 

TOTAL 

AVAILABLE 

FUNDS 

DISBURSED 

DATA 

AS OF 

Section 101 $ 5,000,000 $ 0 $ 0 $ 694,358 $5,694,358 $5,264,202 1/31/2010 

Section 102 0 0 0 0 0 0 1/31/2010 

Section 251 29,081,608 0 0 2 

2 Connecticut did not deposit its state match into the election fund. Instead, it considered expenditures for its statefunded Statewide Voter Registration System as satisfying its state match. 

3,645,382 32,726,990 28,903,801 1/31/2010 

Total $34,081,608 $ 0 $0 $4,339,740 $38,421,348 $34,168,003 1/31/2010 

Our audit methodology is set forth in Appendix B. 

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. Because of inherent 

limitations, a study and evaluation made for the limited purposes of our review would not 

necessarily disclose all weaknesses in administering HAVA payments. 

Except for the maintenance of adequate property records, and physical security over HAVA 

funded assets, our audit concluded that the SOS generally accounted for and expended HAVA 

funds in accordance with the requirements mentioned above. The SOS has taken action on or is 

working to resolve the exceptions described below as set forth in Appendix A-1: 

I.	 	 Property Records and Security over HAVA Funded Equipment 

The equipment listings provided to us by the Connecticut Office of the Secretary of the State 

(SOS), and each of the seven towns we visited, did not conform to the requirements of 41 

C.F.R. 105-71.132 (d)(1), (the Common Rule). We noted the following: 

1.	 	The listings included a description of the equipment, serial number and the location, but 

it did not include the condition, use, source or federal, state or town percentage of 

ownership. 

2.	 	Four of the seven towns we visited did not have inventory records of their handicap 

accessible voting equipment. 

There was one town that had a phone/fax machine stored in a locked wheeled cabinet in an 

unlocked room next to the town council meeting room. In the same town we found that a 

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phone/fax machine was stored in a locked cabinet inside a locked room along with the school’s 

athletic equipment. At this school only the school’s athletic staff had keys to the locked room. 

The Uniform Administrative Requirements for Grants and Cooperative Agreements with State 

and Local Governments 41 CFR § 105-71.132(d)(1), referred to as the Common Rule, states 

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

number or other identification number, the source of property, who holds the title, the acquisition 

date, cost of the property, percentage of Federal participation in the cost of the property, 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 Common Rule, 41 CFR § 105-71.132(d)(3), also 

requires that a control system must be developed to ensure adequate safeguards to prevent 

loss, damages or theft of the property. 

SOS election officials informed us that they were not aware of the detailed recordkeeping 

requirements of the Common Rule. 

Recommendations: 

We recommend that EAC require that the SOS ensure that the property records at towns 

include the minimum information required by the Common Rule, and that HAVA funded 

equipment is properly secured and only accessible by authorized election officials. 

SOS’s Response: 

The SOS concurred with our recommendations and said that inventory listings have been 

amended to include the information required by the Common Rule. The SOS has also 

promulgated procedures covering security over HAVA funded voting equipment. The SOS said 

that her staff had followed up with the town where we found inadequate security over voting 

equipment to ensure that the town understands and adheres to federal requirements. In 

addition, the SOS’s office plans to provide training to all towns in the state on property inventory 

records and security over voting equipment during September 2010. 

**************************************** 

We provided a draft of our report to the appropriate individuals of the Connecticut Secretary of 

State, and the United States Election Assistance Commission. We considered any comments 

received prior to finalizing this report. 

The draft report, including the SOS response, was provided to the Executive Director of the 

EAC for review and comment. The EAC agreed with the report’s conclusions and 

recommendations as well as the Connecticut officials’ initial responses. The EAC’s complete 

response is included as Appendix A-2. 

a1

CG performed its work between February 15, 2010 and March 5, 2010. 

Calverton, Maryland 

June 1, 2010 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
Susan BysTI.rewTI.ICZ 

SECRETARY OF THE STATE 

CONNECTICUT 

July 22,2010 

Mr. Curtis W. Crider 

Inspector General 

u.s. Election Assistance Commission 

Office of the Inspector General 

1201 New York Avenue, NW - Suite 300 

Washington, D.C. 20005 

RE: Response to Draft Report Entitled . "Performance Audit Report - Administration .of 

Payments Received Under the Help America Vote Act by the State of Connecticut" 

Dear Mr. Crider: 

Thank you very much for your letter of June 25, 2010. We are delighted that Clifton 

Gunderson LLP concluded that the State of Connecticut generally accounted for and 

expended Help America Vote Act ("HA V A") funds in accordance with HA V A and 

applicable requirements for the period from April 15, 2003 through January 31, 2010. 

We have worked very hard to meet allofthe requirements ofHAVA in a timely and costeffective way, and we are very proud of Connecticut's leadership in implementing a 

centralized voter registration database, new optical scan voting machines with a voter 

verified and auditable paper trail and other requirements. 

I am writing to address the one exception raised in your report related to the 

completeness of inventory listings: 

Finding: 

The equipment listings provided by the Connecticut Office ofthe Secretary of the State 

and each of the seven towns visited did not did not conform to the requirements of 41 

C.F.R. 105-71.132 (d) (1), (the Common Rule). Although the listings included a specific 

description ofthe equipment, serial numbers and the location of the equipment, they did 

not include the condition, use or source ofthat equipment and a designation of the 

federal, state or town percentage of ownership of said equipment. 

Response: 

The listings have already been amended to include the additional items required by 41 

C.F.R. 105-71.132 (d) (1). The revised form is attached. It should be noted that, while 

this information was not specifically contained on the listings, information regarding 

condition, use, source and percentage of ownership was communicated to towns through 

a variety of vehicles, including informational bulletins provided by the office. 

STATE CAPITOL, 210 CAPITOL AVENUE, HARTFORD, CT 06106 • (860) 509-6200 • FAX (860) 509-6209 
Finding: 

Additionally, four ofthe seven towns visited did not have inventory records of their 

accessible voting equipment. It was also noted that, in one town, one phone and fax 

machine used for accessible voting was stored in a locked cabinet on wheels, but was in 

an unlocked room next to the town council meeting room and in another instance in the 

same town, the equipment was properly locked up in a school, but auditors were told that 

only athletic staff had keys to the room. 

Response: 

Following the August 10, 2010 primary, ttie Office ofthe Secretaryofthe State will issue 

inventory recommendations to the towns, along with sample forms for use in maintaining 

proper inventory records. With regard to proper storage, the Office ofthe Secretary of 

the State has promulgated procedures covering the type of finding listed above and will 

re-issue those procedures and conduct training for election officials at the next statewide 

conference in September, 2010. In addition, immediately after the audit site visit, we 

assigned our Municipal Liaison to follow up directly with that town to ensure that they 

understand the requirements and adhere to them. We will provide that documentation to 

you under separate cover. 

I trust that this response adequately addresses these issues. Please fell free to contact me 

at (860) 509-6200 if you have any further questions. Thank you again for your 

assistance. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EAC RESPONSE TO THE DRAFT AUDIT: 

OIG Performance Audit Report on the Administration of 

Payments Received Under the Help America Vote Act by the 

State of Connecticut, for the Period April 15, 2003 Through 

January 31, 2010 

MEMORANDUM 

August 13, 2010 

To: Curtis Crider 

Inspector General 

From: Thomas Wilkey 

Executive Director 

Subject: Draft Report Performance Audit Report – “Administration of Payments 

Received Under the Help America Vote Act by the State of Connecticut”. 

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

Connecticut. 

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

review and recommendations. We will make a sample inventory sheet available to the 

Connecticut Office of the Secretary of the State (SOS). 

EAC notes that the SOS office sent a proposed resolution to the Notice of Finding and 

Recommendations (NFR) issued for this audit to the Office of Inspector General (OIG). 

Any proposed solution to an audit finding should be addressed to the EAC and not the 

OIG. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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. 

•		 Understanding 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 SOS employees about the organization and operations of the HAVA 

program. 

•		 Reviewed prior single audit report and other reviews related to the state’s financial 

management systems and the HAVA program for the last 2 years. 

•		 Reviewed policies, procedures and regulations for the SOS’s management and accounting 

systems as they relate to the administration of HAVA programs. 

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

•		 Tested major purchases and supporting documentation. 

•		 Tested randomly sampled payments made with the HAVA funds. 

•		 Verified support for reimbursements to local governments (counties, cities, and 

municipalities). 

•		 Reviewed certain state laws that impacted the election fund. 

•		 Examined appropriations and expenditure reports for state funds used to meet the five 

percent matching requirement for section 251 requirements payments. 

•		 Evaluated compliance with the requirements for accumulating financial information reported 

to the Commission on the Financial Status Reports, Forms SF-269 and 425, accounting for 

property, purchasing HAVA related goods and services, and accounting for salaries. 

•		 Verified the establishment and maintenance of an election fund. 

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•		 Conducted site visits of selected counties/towns to perform the following: 

� Observe equipment purchased with HAVA funds for proper accounting and 

safeguarding. 

� Ensure compliance with HAVA Act. 

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OIG’s Mission 

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

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

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

enhance the economy, efficiency, and effectiveness in EAC 

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

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

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

operations. Products and services include traditional financial and 

performance audits, contract and grant audits, information systems 

audits, and evaluations. 

Obtaining 

Copies of 

OIG Reports 

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

(eacoig@eac.gov). 

Mail orders should be sent to: 

U.S. Election Assistance Commission 

Office of Inspector General 

1201 New York Ave. NW - Suite 300 

Washington, DC 20005 

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

Fax: (202) 566-0957 

To Report Fraud, 

Waste and Abuse 

Involving the U.S. 

Election Assistance 

Commission or Help 

America Vote Act 

Funds 

By Mail: U.S. Election Assistance Commission 

Office of Inspector General 

 1201 New York Ave. NW - Suite 300 

 Washington, DC 20005 

E-mail: eacoig@eac.gov 

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

FAX: 202-566-0957