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Washington State Doc Audit Jul 2008-jun 2009

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Washington State Auditor’s Office
Accountability Audit Report

Department of Corrections
Audit Period
July 1, 2008 through June 30, 2009
Report No. 1002601

Issue Date
December 7, 2009

Washington State Auditor
Brian Sonntag

December 7, 2009

Mr. Eldon Vail, Secretary
Department of Corrections

Report on Accountability
We appreciate the opportunity to work in cooperation with your agency to promote
accountability, integrity and openness in government. The State Auditor’s Office takes seriously
our role to advocate for government accountability and transparency and to promote positive
Please find attached our report on the Department of Corrections’ accountability and
compliance with state laws and regulations and its own policies and procedures. Thank you for
working with us to ensure the efficient and effective use of public resources.


Insurance Building, P.O. Box 40021  Olympia, Washington 98504-0021  (360) 902-0370  TDD Relay (800) 833-6388
FAX (360) 753-0646 

Table of Contents
State of Washington
Department of Corrections

Audit Summary ........................................................................................................................... 1
Related Reports .......................................................................................................................... 2
Description of the Department..................................................................................................... 3
Schedule of Audit Findings and Responses ................................................................................ 5
Status of Prior Audit Findings .................................................................................................... 15

Audit Summary
State of Washington
Department of Corrections
This report contains the results of our independent accountability audit of the
Department of Corrections for the period from July 1, 2008, through June 30, 2009.
We evaluated internal controls and performed audit procedures on the activities of the
Department. We also determined whether the Department complied with state laws and
regulations and its own policies and procedures.
In keeping with general auditing practices, we do not examine every transaction, activity
or area. Instead, the areas examined were those representing the highest risk of
noncompliance, misappropriation or misuse. The following areas were examined during
this audit period:



Cash handling
Credit cards


Local funds
Status of prior year loss

In most areas, the Department complied with state laws and regulations and its own
policies and procedures.
However, we identified conditions significant enough to report as findings:


The Department does not have adequate policies or internal controls over
Voyager fuel cards.


The Department does not have adequate internal controls over cash handling in
the prison mail rooms.

We also noted certain matters that we communicated to Department management. We
appreciate the Department’s commitment to resolving those matters.

Washington State Auditor’s Office

Related Reports
State of Washington
Department of Corrections
We perform an annual audit of the statewide basic financial statements, as required by
state law (RCW 43.09.310). Our opinion on these financial statements is included in the
Comprehensive Annual Financial Report (CAFR) prepared by and available from the
Office of Financial Management. The CAFR reflects the financial activities of all funds,
organizations, institutions, agencies, departments and offices that are part of the state's
reporting entity. That report is issued by the Office of Financial Management in
December of each year and can be found at

In accordance with the Single Audit Act, we annually audit major federal programs
administered by the state of Washington. Rather than perform a single audit of each
agency, we audit the state as a whole. The results of that audit are published in a report
issued by the Office of Financial Management in March of each year.

During the current audit period, the State Auditor’s Office issued reports in pursuant to
the State Employee Whistleblower Act (Chapter 42.40 RCW). Those reports are
available on our Web site,

Washington State Auditor’s Office

Description of the Department
State of Washington
Department of Corrections
The Department of Corrections was created in 1981 by the Washington State
Legislature (Chapter 72, RCW). Prior to 1981, the Department was a division of the
Department of Social and Health Services. The Department consists of the Office of the
Secretary and four operating divisions, headed by three Assistant Secretaries and one
Health Services Director: the Prisons Division, the Community Corrections Division, the
Administrative Services Division and the Health Services Administration.
The Department is a highly decentralized agency, employing approximately 8,000
employees to administer and supervise over 18,000 offenders housed in 15 institutions
and 15 work release locations around the state. In addition, the Department provides
oversight for more than 42,000 offender field cases, of which over 29,000 are supervised
offenders in the community. In 2003 the Department began renting beds in local jails
and other jurisdictions to address a shortage of space in state prisons. Approximately
1,700 beds are rented from these additional sources.
The Department also operates Correctional Industries, a business enterprise, at several
of its institutions. Correctional Industries is committed to maintaining and expanding
offender work/training programs which develop marketable job skills, instill and promote
a positive work ethic among offender workers and reduce the tax burden of corrections.
Correctional Industries includes, but is not limited to, furniture and clothing
manufacturing, food processing and printing.
For the 2007-2009 biennium, the Department budgeted $1.76 billion for operations and
$376 million was allocated to capital projects.


Department of Corrections
P.O. Box 41107
Olympia, WA 98504-1107


(360) 725-8213

Web site:

Washington State Auditor’s Office

We audit the Department annually. The past five audits of the Department have
reported three findings in two areas of concern. The 2004 audit reported weaknesses in
internal controls over pharmaceutical inventories. No findings were reported in 2005,
2006 or 2007. The 2008 audit contained two findings, one involving internal control
weaknesses over local funds and one involving a misappropriation of funds from the
Offender Welfare and Betterment Fund at McNeil Island Correctional Center.

Washington State Auditor’s Office

Schedule of Audit Findings and Responses
State of Washington
Department of Corrections

The Department does not have adequate internal controls over Voyager
fuel cards to prevent or detect misappropriation of public funds.
The Department issues Voyager fuel cards to its field offices, prisons and regional
offices for use in fueling Department vehicles. The Department had 1,152 fuel cards at
the end of May 2009. Only 785 of these cards were used during the year.
Approximately $639,000 was charged on the active cards between July 1, 2008, and
June 30, 2009.
Department policy states the cards can be used to purchase regular unleaded fuel,
diesel fuel and up to six car washes per car per year. They are not to be used for any
other items, including service or maintenance, except in the case of emergency. In the
case of emergency, only oil, wiper blades and operating lights may be purchased.
The fuel cards are assigned as follows: 852 cards to fleet vehicles, 279 cards to prisons
and other offices and 21 cards to individuals. All fuel card bills are reviewed and paid by
the Northwest Regional Office, Southwest Regional Office or Eastern Regional Office.

Description of Condition
We reviewed controls in place over fuel cards at the three regional offices and found:


Because supporting documentation is not reviewed and card activity is not
tracked by user, responsibility for transactions cannot be affixed for cards
assigned to vehicles card users and purchase reviewers do not have a consistent
understanding regarding what types of purchases are allowable.


Card users do not consistently obtain receipts for purchases.


Fuel card bills are not reconciled to supporting documentation.


Card reviewers do not request justification for “emergency” use.


No one tracks the number of car washes purchased for each car each year.


No activity for 367 cards during the fiscal year. The Department did not cancel or
deactivate the unused cards.

Washington State Auditor’s Office

Cause of Condition
State rules require agencies to establish internal controls regarding credit card use. The
Department has a policy regarding the use of purchasing cards and a separate policy
covering the use of fuel cards, we found the fuel card policy does not address several
areas including transaction documentation (receipts, mileage logs, emergencies)
requirements, how to submit the documentation, tracking of purchases and use of a
credit card user agreement.
The Department stated that it was aware of the issues with the fuel cards but was not
sure how to address them.

Effect of Condition
We reviewed the April 2009 fuel card statements, totaling $36,406.93, from all three
regions. The statements described each purchase. We reviewed the statements and
chose 120 transactions to review, with descriptions that appeared questionable, totaling
$3,712.77. We requested supporting receipts and mileage logs and found $2,900.84 in
charges to the card were unallowable or did not have enough documentation to allow us
to determine if they were allowable. Specifically:


Ninety-one out of 120 transactions were not supported by a receipt and/or
mileage log. We then looked at the billing statement descriptions to determine if
the transactions were allowable.


Seventy of these transactions were for purchases of unallowable items
such as unleaded plus gas, premium gas and nonemergency oil changes.


We were unable to determine whether 18 of those transactions, based on
the descriptions in the billing statements, were for Department business.

Additionally, maintaining far more cards than needed increases the risk of loss or misuse
of public resources.

We recommend the Department establish and enforce adequate policies and
procedures to ensure fuel cards are used for allowable business purposes and in
accordance with management’s expectations.
Card users should be trained on the allowable use of the cards and types of
documentation they need to retain and submit. The Department should obtain and
review support documentation before paying fuel card bills.
We further recommend the Department regularly eliminate cards that are not being

Washington State Auditor’s Office

Department’s Response
The Department of Corrections would like to thank the State Auditor's Office for their
assistance during the current audit.
The Department concurs with the Auditor's recommendations and has acted to establish
effective controls of Agency's fuel cards. A new process was established to randomly
audit fuel cards. In addition, the Agency will update the policy to standardize practices
and controls for the use of these cards at all agency locations.

Auditor’s Remarks
We thank the Department for its cooperation and assistance throughout the audit. We
will follow up during our next audit.

Applicable Laws and Regulations
WAC 236-48-251, Distribution of credit, charge cards or purchasing cards, states:
Agency heads (or their designees) shall institute a system for
responsibility, control and distribution of credit, charge or purchasing
cards within each agency.
SAAM 45.20.20.a states in part:
An agency should establish internal controls to address the use of the
purchase card as a means of expending state funds. The following is the
minimum level of controls acceptable:


Maintaining a list of all cardholders, card custodians, and
designated card users in the agency.


Card users shall be given a copy of the agency purchase card
policies and procedures, should sign a card user agreement
form, and should complete training prior to a purchase card
being issued and used.


Promptly recording, properly
reconciling all transactions.


Assigning key duties and responsibilities to ensure a proper
separation of duties.


Safeguarding purchase cards and account numbers against
loss, theft, and unauthorized use. Cards should be kept by the
cardholder or card custodian in a secure (locked) location
when not in use.


Agencies utilizing department cards should create and
maintain a department card log to track card use. Designated
card users should check out and check in the card on a


Washington State Auditor’s Office



department card log and describe the business purpose for
each use in order to make a purchase.


Reconciling and approving card statements at least monthly.

SAAM 45.10.70.c states in part:
The agency program administrator is the person responsible for
management and oversight of the purchase card program within the
agency, and is responsible for the following:


Developing and enforcing agency policies and procedures for
using the purchase card, including disciplinary procedures
related to unauthorized use of cards and card renewal
procedures. The agency policies and procedures should meet
the minimum requirements of the statewide policies and
procedures contained in this chapter. State ethics laws should
also be considered when developing agency policies.


Providing training to approving officials, cardholders, card
custodians, and designated card users in the management,
security, and use of the card.


Reviewing the agency purchase card program at least
annually to ensure that proper procedures are being followed.


Ensuring card users satisfy documentation requirements for


Closing card accounts as necessary, and collecting and
destroying cards upon employee reassignment or termination.

SAAM 45.10.70.d states in part:
The approving official is assigned to monitor, review, and approve card
transactions to ensure compliance with purchase card policies and
procedures, and is responsible for the following:


Ensuring timely reconciliation of card statements, including
ensuring that supporting documentation is attached.


Monitoring card activity for unusual patterns of use or
unacceptable transactions, and taking appropriate disciplinary
measures with card users who misuse their purchase card.

SAAM 45.10.70.e states in part:
For agencies who choose to utilize department cards, the card custodian
administers and controls the use of department cards by authorized
designated card users within the card custodians’ workgroup and is
responsible for the following:
Washington State Auditor’s Office


Complying with all state, agency, and purchasing statutes,
rules, policies, and procedures.


Training designated card users on the use of the card.


Ensuring that designated card users obtain and submit valid
supporting documentation for each purchase made.


Reconciling the card statement to the purchase card
transaction log and supporting documentation, at least
monthly, and submitting to the approving official for approval.

SAAM 45.10.70.f states in part:
For agencies who choose to utilize department cards, the designated
card user is an authorized user of a department card, and is responsible
for the following:


Using the purchase card in accordance with all state and
agency statutes, rules, policies, and procedures.


Obtaining and submitting valid supporting documentation for
each purchase made.


Checking card back in on department card log after use and
immediately returning card and supporting documentation to
card custodian.


Safeguarding card security at all times.

Department of Corrections Vehicle Use Policy 230.500, Part B – Fuel Cards, states in


Vehicle washes may be purchased, up to 6 per vehicle annually,
without prior approval.


Cards may be used to purchase fuels, oil, and emergency repairs
when using the Department of Transportation fuel card would cause
undue hardship.


Mileage logs, keys, and fuel cards will be kept in the local Department
office when the vehicle is not in use.


Fuel cards should be used to purchase Regular Unleaded gasoline or
diesel whenever possible.

Washington State Auditor’s Office

Schedule of Audit Findings and Responses
State of Washington
Department of Corrections

The Department does not have adequate controls over cash receipting in
the mailrooms at the prisons to prevent or detect misappropriation.
The Department receipts money orders, checks and some cash at all 15 prisons it
administers. Most of this money is sent by friends and family to inmates. When an
inmate receives money in addition to his or her wages except settlements, awards
resulting from legal action, or funds designated for postage, state law subjects this
money to a 20 percent deduction to contribute to the cost of incarceration.
The Department receipted approximately $21 million into inmate accounts in fiscal year
2009. Of this, approximately $1.8 million was deducted by the Department for cost of

Description of Condition
We reviewed the cash-handling for inmate accounts at the Washington Correctional
Center for Women, the McNeil Island Correctional Center, the Monroe Correctional
Center and Airway Heights Correctional Center. The prisons all use the same receipting
system to log cash receipted in the mailrooms.
During our review, we identified the following weaknesses in cash-receipting processes
in the mailrooms:
At all four prisons:


The mail is not opened by two people.


Money orders are left unsecured on a table before they are entered into the


No signature is required when money orders are transferred from the mailroom to
the Business Office.


The reciepting system allows transactions to be permanently deleted, leaving no
record of the activity.

At McNeil Island, Monroe, and the Washington Correctional Center for Women:


A common logon is used, even though individual user accounts can be created.

Washington State Auditor’s Office


Not all money received is receipted into the receipting system. Items such as
money orders that are not properly filled out and income tax refunds are set
aside and returned to the sender or forwarded to family members without being

At Airway Heights:


An employee picks the mail up from the Post Office alone.


After money orders are entered into the system, the receipts are attached and
they are left in an unsecured bin in the middle of the mailroom until they are
transported to the Business Office.

At the Washington Correctional Center for Women:


No one was reconciling the bank deposit to the daily money order list.

Cause of Condition
Department management has not put policies and procedures in place to establish
adequate controls over cash receipting in the mailrooms because inmates do not have
access to the mailrooms so they perceive the money to be safe. Management was not
aware of the receipting system deficiencies. Further, not all staff members working in
the mailrooms are adequately trained.

Effect of Condition
The Department cannot ensure all funds received through the prison mailrooms were
receipted and deposited. These weaknesses impair the Department’s ability to prevent
or detect errors and irregularities in a timely manner, if at all.

We recommend the Department:


Ensure two people are present at all times when mail containing money is


Ensure all money received is receipted immediately upon opening the mail.


Establish and follow a cash-receipting system that tracks all cash receipts,
cannot have records permanently deleted and fixes responsibility for each


Create and maintain a log to document transfers of funds from one person to
another by an exchange of receipts acknowledging responsibility of the funds.

Washington State Auditor’s Office

Department’s Response
The Department of Corrections would like to thank the State Auditor's Office for their
assistance during the current audit.
The Department has reviewed the recommendations of the State Auditor Office.
Unfortunately, Department does not currently have resources to replace the current
cash-receipting system, but will make sure each employee has his or her own unique
logon and password. Additionally, we will improve the process for opening mail to
provide better controls. We concur with the other State Auditor's recommendations and
will work with staff to make sure they abide by these recommendations.
Auditor’s Remarks
We thank the Department for its cooperation and assistance throughout the audit. We
will follow up during our next audit.
Applicable Laws and Regulations
RCW 43.88.160, Fiscal management, Powers and duties of officers and agencies, states
in part:
The director of the Office of Financial Management (OFM), as an agent of
the governor:
Develop and maintain a system of internal controls and internal
audits comprising methods and procedures to be adopted by each
agency that will safeguard its assets, check the accuracy and
reliability of its accounting data, promote operational efficiency,
and encourage adherence to prescribed managerial policies for
accounting and financial controls. The system developed by the
director shall include criteria for determining the scope and
comprehensiveness of internal controls required by the classes of
agencies, depending on the level of resources at risk. Each
agency head or authorized designee shall be assigned the
responsibility and authority for establishing and maintaining
internal audits following the standards of internal auditing of the
Institute of Internal Auditors . . . .
SAAM 20.10.30, Applicability, states in part:
This chapter is applicable to and binding on all agencies of the state of
Washington, unless otherwise exempted by statute or rule. The Budget
and Accounting Act (RCW 43.88.020) defines the term "Agency" to mean
and include . . . every state office, officer, each institution, whether
educational, correctional, or other, and every department, division, board
and commission, except as otherwise provided . . . .

Washington State Auditor’s Office

SAAM 20.15.30, Who is responsible for internal control?
Each agency, regardless of size, is required to adopt methods to
periodically assess risk and to develop, implement, and review its system
of internal controls. The methods should be tailored to the specific needs
of the agency.
SAAM 20.15.30.a states:
The agency head or authorized designee is ultimately responsible for
identifying risks and establishing, maintaining, and reviewing the agency’s
system of internal control. If the agency head delegates this responsibility,
the designated person should have sufficient authority to carry out these
responsibilities. Normally, this person is a senior agency manager who
does not serve in the internal audit function.
SAAM 20.25.30.a states in part:
The following are descriptions of some commonly used control activities.
This is not an exhaustive listing of the alternatives available to
Verification – Controls activities in this category include a variety of
computer and manual controls designed to provide reasonable assurance
that all accounting information has been correctly captured.
Reconciliation – Control activities in this category are designed to provide
reasonable assurance of the accuracy of financial records through the
periodic comparison of source documents to data recorded in accounting
information systems.
Physical security over assets – Control activities in this category are
designed to provide reasonable assurance that assets are safeguarded
and protected from loss or damage due to accident, natural disaster,
negligence or intentional acts of fraud, theft, or abuse.
Segregation of duties – Control activities in this category reduce the risk
of error and fraud by requiring that more than one person is involved in
completing a particular fiscal process.
Education, training and coaching – Control activities in this category
establish key performance indicators for the agency that may be used to
identify unexpected results or unusual trends in data which could indicate
situations that require further investigation and/or corrective actions.
Evaluations may be done at multiple levels within the agency, as
appropriate: the agency as a while; major initiatives; specific functions; or
specific activities.

Washington State Auditor’s Office

SAAM 20.25.30.b states in part:
In those cases where staffing may prohibit or restrict the appropriate
segregation of duties, management must either have more active
oversight of operations or utilize personnel from other units to the extent
possible as compensating controls.

Washington State Auditor’s Office

Status of Prior Audit Findings
State of Washington
Department of Corrections
The status of findings contained in the prior years’ accountability audit reports of the Department
of Corrections is provided below:

Public funds were misappropriated from the Offender Welfare and Betterment
fund at McNeil Island Correction Center.
Report No. 1000494, dated January 20, 2009
A Department employee misappropriated at least $166,200 from the McNeil Island
Correctional Center’s Welfare and Betterment Fund from 2003 through 2007, as well as
one check for $3,800 from the Vocational Education Fund. We recommended the
Department seek recovery of $170,000 in misappropriated public funds plus audit costs.
We determined the Department did not have adequate segregation of duties or
monitoring in place to ensure all payments from the fund were properly authorized and
independently reviewed. The employee had the ability to issue checks, make changes
to the fund general ledger, unrestricted access to the safe containing blank fund check
stock, and was responsible for the reconciliation of the monthly bank statements to the
general ledger. Management’s review of monthly reconciliations was insufficient to
detect the improper activity.
We have determined that the prior year loss has been prosecuted and the control
weaknesses at the McNeil Island Correctional Center that allowed the loss to go
undetected have been adequately addressed. We consider this finding to be resolved.


The Department of Corrections does not have adequate internal controls over
local funds.
Report No. 1000494, dated January 20, 2009
We determined there was not an adequate segregation of duties in the Department’s
Trust Accounting System (TAS) at the McNeil Island Correctional Center to prevent or
detect misappropriations. We found 28 employees had levels of access that gave them
the ability to create trust accounts, create debt obligations against offender trust
accounts, generate checks and reconcile system activity at month’s end. These abilities

Washington State Auditor’s Office

would allow any employee to circumvent controls, generate fraudulent checks and alter
the general ledger and/or monthly reconciliations to avoid detection.
We also determined that local account reconciliations were not being submitted to
Department headquarters monthly as required by Department policy.
The Department has made significant improvements in its controls over local funds at
the McNeil Island Correctional Center. We also found most local account reconciliations
are being sent to Department headquarters as required. However, we did note some
minor issues during the current audit that were communicated to management. We will
review this area again during the next year’s audit.

Washington State Auditor’s Office

The State Auditor's Office is established in the state's Constitution and is part of the executive
branch of state government. The State Auditor is elected by the citizens of Washington and serves
four-year terms.
Our mission is to work in cooperation with our audit clients and citizens as an advocate for
government accountability. As an elected agency, the State Auditor's Office has the independence
necessary to objectively perform audits and investigations. Our audits are designed to comply with
professional standards as well as to satisfy the requirements of federal, state, and local laws.
The State Auditor's Office employees are located around the state to deliver our services effectively
and efficiently.
Our audits look at financial information and compliance with state, federal and local laws on the
part of all local governments, including schools, and all state agencies, including institutions of
higher education. In addition, we conduct performance audits of state agencies and local
governments and fraud, whistleblower and citizen hotline investigations.
The results of our work are widely distributed through a variety of reports, which are available on
our Web site and through our free, electronic subscription service. We continue to refine our
reporting efforts to ensure the results of our audits are useful and understandable.
We take our role as partners in accountability seriously. We provide training and technical
assistance to governments and have an extensive quality assurance program.
State Auditor
Chief of Staff
Deputy Chief of Staff
Chief Policy Advisor
Director of Audit
Director of Special Investigations
Director for Legal Affairs
Director of Quality Assurance
Local Government Liaison
Communications Director
Public Records Officer
Main number
Toll-free Citizen Hotline
Web Site
Subscription Service

(SAO FACTS.DOC - Rev. 06/09)

Brian Sonntag, CGFM
Ted Rutt
Doug Cochran
Jerry Pugnetti
Chuck Pfeil, CPA
Jim Brittain, CPA
Jan Jutte, CPA, CGFM
Ivan Dansereau
Mike Murphy
Mindy Chambers
Mary Leider
(360) 902-0370
(866) 902-3900