Performance Auditing Challenges in WA
Performance Auditing Challenges in WA
Performance
Auditing:
How a State Auditor
with Intriguing New
Performance Auditing
Authority is Meeting Them
A
GA’s Corporate Partner Advisory Group (CPAG), The CPAG was organized in 2001 as a business element
executive director and director of research are creat- within AGA. The mission of the CPAG is to bring industry
ing research projects of value to governments, indus- and government executives together to exchange informa-
try and the entire AGA membership. These studies are tion, support professional development, improve communi-
expected to result in reports assessing current and/or best cations and understanding, solve issues and build
practices and make recommendations for future improve- partnership and trust, thereby enhancing AGA’s focus on
ments in federal, state and local governmental accounting, advancing government accountability. Corporate member
auditing and financial management. CPAG members sup- involvement in the CPAG is limited to organizations that
port AGA research through either cooperative or sponsored sign up for the AGA Corporate Partner membership pro-
research projects. “By undertaking research, AGA is fulfilling gram.
its mission as a thought leader in advancing government For more information on the Research Program, please
accountability,” said AGA Executive Director Relmond Van visit the AGA website, Research Section at www.agacgfm.org/
Daniker, DBA, CPA. “This is one of numerous research initia- research/default.aspx or contact Anna Miller at
tives that will benefit government and bridge the gap [email protected].
between the public and private sectors.”
Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Protocol for Audit Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Contracting for Audit Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Strategic Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Performance Management and Measurement . . . . . . . . . . . . . . . . . . . . . . . . . 12
June 2006 3
CHALLENGES IN PERFORMANCE AUDITING
Background stated by State Auditor Brian Sonntag, “To meet public
In November of 2005 the citizens of Washington state expectations, we must get audits under way almost immedi-
voted to give their state auditor the most extensive authority ately, and produce results. We also must balance that with
in the country to conduct comprehensive, independent per- exercising care in deciding what we audit, how we hire and
formance audits of state and local governments. To carry out train, and how we involve citizens, public employees and
this authority, the citizen-sponsored initiative dedicated a others in our decisions. And our audit work must be fair and
portion of the state sales and use tax revenue solely for the objective, it must be sound and of high quality, and it must
conduct of performance audits. Among its provisions, the be credible and constructive.” In this context, it is important
initiative requires the state auditor to follow Government to recognize that when the initiative was passed, the state
Auditing Standards, and states that no legislative body, auditor had no performance audit staff, no policies and
office holder or employee may impede or restrict the author- procedures, no space and an inadequate salary structure.
ity of the state auditor to conduct performance audits. On
the conduct of audits, it urges the state auditor to focus on
the largest, costliest government entities first, and to offer a Research Objective
step-by-step remedy to whatever ineffectiveness and ineffi- The objective of this research study is to document the ini-
ciency is discovered in audited entities. tial actions taken by Sonntag to implement the provisions of
The initiative, with its monthly revenue stream of $800,000 the initiative and prepare to conduct performance audits.
to $900,000, brings with it extraordinary expectations. As The graphic below depicts what he wants to achieve.
June 2006 5
CHALLENGES IN PERFORMANCE AUDITING
initiative, Mr. Eyman is the state auditor may have up to five years to demonstrate
Nothing is more powerful quoted as saying, “All the value of performance auditing before the legislature will
than an idea whose time has the intellectual ground- venture to critically review the initiative and the dedicated
come. work for performance source of funding.
—Victor Hugo audits had been laid 2. While Initiative 900 states that performance audits may be
out for years by the done on contract, there appears to be an expectation by
Evergreen Freedom the legislature and the governor that performance audits
Foundation (a proponent of performance auditing) and talk will be done on contract. This expectation reflects a desire
radio, making Initiative 900 a real cakewalk. Voters instinc- of a large number of legislators to limit the growth of state
tively want accountability and transparency, but elected employees. As evidence of this expectation, all legislative
officials don’t.” bills since 2002 on performance auditing have contained a
While past Eyman tax cut initiatives drew media opposi- requirement for the audits to be done on contract. Sonntag
tion, I-900 enjoyed broad media support, particularly from and Long plan to conduct much of the initial performance
talk radio and most of the state’s newspapers. According to audit work under contract with private firms to meet pub-
a respected state politician who held positions in the state lic expectations for near-term results. Their short-term
legislature and the federal executive, “The appeal of the ini- goal is to conduct about 50 percent of performance audits
tiative was not hurt by the fact that the state auditor is the on contract. Their current long-term goal is to conduct
most popular elected official in the state.” about 25 percent of performance audits on contract and
On passage of the initiative, Sonntag is quoted as saying, about 75 percent with in-house auditors. To the research
“We now have a unique opportunity where we have sup- team’s knowledge, no U.S. audit office conducts perform-
port by the governor’s office and the citizens for independ- ance audits on contract as a matter of routine, ongoing
ent performance audits. practice.
While I-900's adoption in A 57 percent vote is a 3. Since I-900 was a citizen-driven initiative, Sonntag has
Washington has immediate loud voice. Clearly the embarked on a process to engage citizens and elicit their
implications for that state, sup- people are saying they ideas on where performance audits should be focused. In
porters of limited and account- want accountability its First 100 Day Report, the Office of the State Auditor
able government see the and transparency.” indicated that it has contracted with a research firm and is
initiative’s 57 percent approval working to develop focus groups, public forums, opinion
vote as having an impact on Unique Features of polling, Web surveys and other means to gather citizens’
budget debates nationwide. the State Auditor’s thoughts and ideas. Those efforts are intended to meet
—Heartland Institute (in report- New Authority proper qualitative and quantitative research methods. In
ing on I-900) public forums already held, the audit priorities of citizens
There are five
were transportation, education, social services and health
unique features of the
care. Those issues will be among the initial list of audits
Washington state auditor’s authority and expectations for
conducted.
conducting performance audits. To the knowledge of the
research team, very few, if any, audit offices in states where 4. I-900 states that the scope for each performance audit
auditors conduct performance auditing have these features. shall not be limited, and that each audit is to include nine
The first feature is one that warrants attention of the entire elements. In brief, these are to identify:
performance audit community. A full list of the authority • cost savings;
conferred by I-900 is in Exhibit A. • best practices;
1. I-900 provides the auditor with a dedicated source of • services that can be reduced or eliminated;
funding. The voter-approved initiative dedicates 0.16 per-
cent of the state’s sales and use tax revenue for the con- • services that can be transferred to the private sector;
duct of performance audits. This revenue is to be • gaps or overlaps in programs and services;
deposited to an “audits account” from which only the • the feasibility of pooling information technology systems;
state auditor or the state auditor’s designee may authorize
• opportunities to change or eliminate departmental roles
expenditures. The funding source and amount is not sub-
or functions;
ject to approval by the legislature. The money is not only
dedicated, but the amount is significant; an estimated $6.6 • statutory or regulatory changes that may be necessary for
million in fiscal year 2006 (per the state Office of Financial the department to properly carry out its functions; and
Management) and a total of $18.4 million by June 30, 2007. • to analyze departmental performance data, performance
On the question of how long this situation will prevail, measures and self-assessment systems.
state law prohibits the legislature from changing initiative- The last bullet relates to the state’s efforts to establish a
induced provisions for two years after enactment. It would “performance budgeting and measurement system” (further
be a politically sensitive vote to change what the citizens put discussed below).
in place. The research team was told by a reliable source that
given the popularity of the initiative and the state auditor,
June 2006 7
CHALLENGES IN PERFORMANCE AUDITING
while perfectly valid, could be seen as undermining the in Washington experienced the delicacy of this arrangement
cost-cutting results implied by the initiative. firsthand when, in 1969, the legislature barred any money
• The initiative does not address using existing financial from being spent for performance audits. Performance
audit teams to conduct performance audits, although auditing is a tough, precarious job, and auditors need pro-
those financial auditors could be a resource in gathering tection against retribution for doing it well.
data from locations across the state for evaluation by per- Washington State Auditor’s Unique Funding
formance audit teams. This is left to the discretion of the Arrangement
state auditor. Secure Source—The Washington state auditor has a
• Pressure to move quickly on performance auditing led to secure source of funding. Initiative 900,which restored the
salary waivers for performance audit managers, creating state auditor’s authority to conduct performance audits,
pay inequities with financial audit staff within the same dedicates 0.16 percent of the state’s sales and use tax rev-
office. The state’s pay scale for financial professionals enue for the conduct of performance audits. This revenue is
already was inadequate. The combination of a dedicated deposited to an account from which only the state auditor or
funding stream directed expressly to performance audits the state auditor’s designee may authorize expenditures.
and the need to hire performance audit professionals The funding source and amount is not subject to approval
quickly has the potential to magnify the salary inequities by the legislature. The research team knows of only one
and impact the overall operation of the state auditor’s other audit office in the United States that enjoys the added
Office. independence afforded by having a dedicated funding
source.
Common Challenges in Performance Auditing Adequacy—The amount of dedicated money that accrues
Audit offices face a common set of challenges in conduct- is estimated at $8.5 to $12 million a year by the Washington
ing performance audits. These challenges include: funding, State Office of Financial Management. This amount is suffi-
staff salaries, staff quantity and quality, organizational struc- cient to finance a staff of about 60 auditors (to include
ture, training, audit selection, reporting model, when to con- salaries, facilities, equipment, supplies, etc.) and about $7
duct audits in-house and on contract, policies and million in contracts. This is a relatively large performance
procedures (for conducting and managing audits with in- audit staff in the state audit community (per NASACT data).
house staff and with contractors), audit protocol and quality In comparison, the state auditor has an annual budget of
assurance. These concerns pertain to the profession as a $22.5 million and 300-plus staff to conduct financial audits.
whole, as well as to audit offices just getting started. Howev- Given that the number of government organizations and
er, because Sonntag plans to conduct audits on contract, at entities is the same (about 2,700 units), does this suggest that
least initially, he has unique challenges to deal with. financial and compliance audits are roughly two times more
In a rush to get started and produce results, Sonntag and valuable than performance audits? Is this ratio of spending
Long attempted to address all of these concerns more or less on financial versus performance auditing common in the
simultaneously. The actions discussed below were those state auditor community? More research may be needed to
they had completed or had in process at March 31, 2006. The answer questions such as these.
list is limited to the actions related to the common chal- Staff Salaries
lenges of the performance audit community and those Common Practice—
unique to the Washington state audit office.
Maintaining an adequate salary structure—from entry
In presenting the actions of the Washington state auditor through senior auditors—is the No. 2 challenge for the gov-
and his performance audit staff we have contrasted them ernment performance audit community. Without adequate
with the common practices in per-
formance auditing. In this it is impor-
tant to recognize that practices in the Figure 1
performance auditing profession are Entry Level Auditor Starting pay range $19,100 to $45,700 Mean: $30,000 - $35,000
far from standard.
Top of pay range $31,600 to $77,400 Mean: $35,000 - $50,000
Funding
Middle Level Auditor Starting pay range $25,300 to $57,800 Mean: $30,000 - $45,000
Common Practice—
Top of pay range $35,100 to $83,300 Mean: $40,000 - $55,000
Maintaining a secure source of ade-
quate funding is the No. 1 challenge Upper Level Auditor Starting pay range $29,200 to $66,600 Mean: $35,000 - $50,000
for the government performance audit
Top of pay range $41,100 to $123,200 Mean: $45,000 - $75,000
community. Government audit offices
throughout the United States are Audit Supervisor Starting pay range $33,600 to $76,100 Mean: $40,000 - $70,000
dependent on the legislature to pro- Top of pay range $51,600 to $135,300 Mean: $60,000 = $85,000
vide money to fund performance audit
operations. This is true even for elect- Audit Manager Starting pay range $37,900 to $87,600 Mean: $45,000 - $75,000
ed state auditors. The state audit office Top of pay range $57,500 to $155,800 Mean: $65,000 - $110,000
June 2006 9
CHALLENGES IN PERFORMANCE AUDITING
exceptions were required (and obtained) to recruit the per- islative or executive branch requests; some act on issues
formance audit managers. Second, the state initially had no uncovered by investigative and financial audit teams. In
civil service position description addressing the knowledge, preparing annual audit plans, many audit offices seek input
skills and abilities required of performance auditors. Hiring from the legislature or from officials of the entity they report
of additional staff for performance audit began in March. to. The research team does not know how many audit offices
seek input from citizens. This is not a widely publicized
Training practice.
Common Practice— Washington State Auditor’s Actions—
Training is critical to an audit office’s success. No college I-900 encourages the state auditor to look at large-sized,
or university program in the United States specifically trains big-dollar organizations first. In that spirit, Sonntag’s “First
students to be performance auditors. As a consequence, 100 Days Progress Report” states that the initial audit selec-
audit organizations either hire auditors from other audit tions were based on size, public concerns, and audit staff
offices or develop their own. The “development” of profes- knowledge and opinion that the subjects will yield signifi-
sionals into performance auditors is achieved through a cant opportunities for cost savings and improved services.
combination of formal and on-the-job training, coupled with Input from citizens—a telephone interview survey and an
experience doing performance audits. The success of this ongoing website survey—weighed heavily in the subjects
development process is heavily dependent on good training. initially selected for audit. In addition, the state auditor has
The importance of training is recognized by the profes- a legislative mandate, funded at $4 million, to conduct per-
sion. Government performance auditors are required by formance audits of the State Department of Transportation
auditing standards to obtain continuing professional educa- and some transportation-related agencies. These audits must
tion. Government Auditing Standards require each auditor be completed by June 30, 2007.
to obtain 80 hours of continuing professional education Selection Criteria—The following criteria were chosen to
every two years with at least 20 hours obtained in one of the guide selection of specific topics for audit:
years. Auditors obtain the necessary training in a wide vari- • expectations from citizens;
ety of ways, to include training from professional audit
• ideas and suggestions from frontline public employees;
training organizations.
• opinions and recommendations of policymakers, interest-
Washington State Auditor’s Actions—
ed organizations and the government entities themselves;
Sonntag plans to pursue a cross training program to
• ideas generated by the governor’s performance-based
expand the capacity of his professional staff that performs
initiatives;
financial and legal compliance audits. The intent is to pro-
vide them with new skills that will give the audit office • auditor’s own research including analysis of best
greater flexibility in staffing for all types of audits, and practices;
expand career opportunities with the audit office. The state • auditor’s own judgment from knowledge and long expe-
auditor’s office is also working with two state universities to rience in conducting financial and legal compliance audits
provide internship opportunities for students doing gradu- of state and local governments;
ate work. • expectation of identifying significant efficiencies and cost
Contractors—Materials were in place for state audit office savings; and
staff to provide contractors with pre-audit training on Team- • the nine elements contained in I-900. The performance
Mate, working papers, public records, referencing and active audit team reordered the I-900 cited nine elements to
listening. reflect the team’s order of priority. As a signal of the
team’s priorities, it put identifying “best practices” ahead
Protocol for Audit Selection of the five elements that focus on “cost savings.”
Common Practice— Outreach to Citizens—Sonntag insists that his office
To have a full degree of independence, performance audit engage the public, including public employees. In particular,
offices need authority to select subjects for audit without they must gather information from various public groups on
approval of the legislature, governor or some other oversight topics of interest for audit. The performance audit team
body. Most, if not all, federal and local government auditors established a website survey which 600 people had complet-
have such authority. Of the 42 state auditors who conduct ed by March 30, 2006. The performance audit team also con-
performance audits, 30 have authority to independently tracted with a professional firm with experience in obtaining
select audits, according to NASACT. ideas from diverse public groups—through opinion polls,
The methods used to select subjects for audit vary among focus groups and other means—to assist them in obtaining
performance audit offices. Many conduct risk assessments, input from the public, to include citizens, business, interest
some using the COSO approach that involves constructing groups and government employees. The state auditor
an audit universe, prioritizing areas in accordance with risk intends for the results of these surveys to play a large role in
level, getting validation from a group of advisors, and audit- his audit selection. The first survey was conducted in mid-
ing the highest risk areas first, each year. Others receive leg- March. A telephone survey covered 405 voters from a mix of
June 2006 11
CHALLENGES IN PERFORMANCE AUDITING
edged in both the private and public sectors, and is required the tools of strategic business planning and performance
by many, if not most, government entities. Beyond a few measures to establish their priorities and measure their
generally recognized items, such as a vision statement, mis- progress toward their stated goals.” This order established a
sion statement, an explanation of how the mission is to be series of “quality management” activities for state agencies,
achieved, and measures of performance, organizations are including the establishment of a quality-improvement repre-
free to decide the form and content for their strategic plans. sentative for individual agencies, and quality steering com-
For performance audit offices, one unique, and important mittees, which were to report to the governor each quarter.
strategic planning item is audit selection—the method and For every major program administered by an agency, pro-
rationale for selecting subjects for audit. gram objectives are to be reported with measurable outputs
Washington State Auditor’s Actions— and outcomes, to the extent possible. This performance
Sonntag and Long’s stated intention is to totally transform information is publicly reported, at the agency level, in the
the plan in light of their performance audit authority. At the biennial executive budget document. The JLARC is responsi-
cut-off date for this research project (March 31, 2006), the ble for assessing the relevance and reliability of agency per-
plan was still in development. formance measures.
One item common to strategic plans is a vision statement. The quality of the performance measures developed by
Sonntag’s vision for performance audit is that the audits: agencies can directly affect the results of performance audits.
If those measures are broad, vague and difficult to quantify,
• be fair, then the performance auditors will have a difficult time
• be valued and implemented as a management tool, clearly delineating, which measures have been met and
• promote continuous improvement of quality, efficiency which have not. In conducting performance audits, the audi-
and effectiveness, tors will be faced with preparing their own measures, which
• focus on results, they may recommend that the agency prepare on a regular,
recurring basis.
• enhance accountability and trust, and
Priorities of Government (POG) Budget Process
• complement the state’s performance management and
budgeting priorities. The Washington state POG initiative was designed to rank
and prioritize state government services and develop a
His expectation for the performance audit program is that budget strategy from the results of these exercises. POG cate-
it will achieve profound results, first and every year, meas- gorizes all state programs in services into one of 11 results
ured by success in having recommendations implemented areas. The results areas are statewide desired conditions (for
and the impact achieved. example, improve student achievement in elementary, mid-
Performance Management and Measurement dle and high schools; improve quality of Washington's natu-
Current Practice— ral resources); they are not program-specific.
In recent years the federal government, and many state A guidance team and 11 results teams that corresponded
and local governments, have enacted laws requiring estab- with each of the results areas were developed to implement
lishment of measures of performance and for use of those the POG process. Ultimately, the POG approach informed
measures in managing. These laws generally require that the governor’s proposed budget for the 2003-05 biennium.
executive branch agencies engage in strategic planning to Budget activities were ranked by contribution to the results,
include the development of an agency mission statement, and a line was drawn at the dollar amount allocated to the
measurable goals for applicable aspects of output and out- results. Activities below the line were listed in order to iden-
come performance, and performance measures indicating tify how changes in funding might affect service provisions.
the relative success in achieving program goals. Some have a Washington State Auditor’s Actions—
requirement for use of performance measures in budgeting, Initiative 900 cites as one of the 11 items to be included in
generically referred to as performance-based budgeting. each performance audit, “an analysis of departmental per-
To date, the efforts of audit offices in verifying the reliabil- formance data, performance measures and self-assessment
ity of agency-prepared performance measures has been lim- systems.” In keeping with this requirement, one of the state
ited, based on the knowledge of the research team. auditor’s visions for performance audit is that his audits
Washington’s Government Management Accountability “will complement the state’s Priorities of Government Bud-
and Performance Program (GMAP) get Process and the Government Management Accountabili-
ty and Performance program.”
In 1993 the legislature amended Washington’s Budgeting
and Accounting Act to require state agencies to engage in Consistent with these performance-based management
strategic planning, including the development of an agency initiatives, Sonntag envisions his audits to “be valued and
mission statement and measurable goals, program objec- implemented as a management tool.” This could prove to be
tives, and budget proposals that incorporate performance a considerable challenge. The state auditor is independently
measures indicating the relative success in achieving pro- elected and not considered a member of either the legislative
gram objectives and goals. This legislation was followed in or the executive management team. Moreover, both the legis-
1997 by an executive order requiring state agencies to “use lature and the executive have historically perceived the state
June 2006 13
CHALLENGES IN PERFORMANCE AUDITING
dedicated funding to ensure the independent voice that Expectations—The following provisions lay out key
citizens want and expect from their government auditing expectations of I-900 performance audits.
agencies. How those resources are used and managed in • The people encourage the state auditor to aggressively
Washington state creates another subject for future study pursue the largest, costliest governmental entities first but
and review. to pursue all governmental entities in due course.
• AGA should consider conducting further research to • The scope for each performance audit shall not be limited
explore the appropriate role for public sector auditors in and shall include nine specific elements: (1) identification
government performance management initiatives. of cost savings; (2) identification of services that can be
reduced or eliminated; (3) identification of programs or
Appendix A: I-900 Audit Authority and Requirements services that can be transferred to the private sector; (4)
State Auditor’s Authority—The following provisions of analysis of gaps or overlaps in programs and services and
Initiative 900 lay out the state auditor’s authority for con- recommendations to correct gaps or overlaps; (5) feasibili-
ducting performance audits. ty of pooling information technology systems within the
• The state auditor shall conduct independent, comprehen- department; (6) analysis of the roles and functions of the
sive performance audits of state government and each of department, and recommendations to change or eliminate
its agencies, accounts and programs; local government departmental roles or functions; (7) recommendations for
and each of its agencies, accounts and programs; state and statutory or regulatory changes that may be necessary for
local education governmental entities and each of its the department to properly carry out its functions; (8)
agencies, accounts and programs; state and local trans- analysis of departmental performance data, performance
portation governmental entities and each of its agencies, measures, and self-assessment systems; and (9) identifica-
accounts and programs; and other governmental entities, tion of best practices.
agencies, accounts and programs. Government includes • To the greatest extent possible, the state auditor shall
all elective and nonelective offices in the executive branch instruct and advise the appropriate governmental body on
and includes the judicial and legislative branches. a step-by-step remedy to whatever ineffectiveness and
• The state auditor shall review and analyze the economy, inefficiency is discovered in the audited entity.
efficiency and effectiveness of the policies, management, Requirements of Report Recipients—The following
fiscal affairs, and operations of state and local govern- I-900 provisions lay out the requirements of audit report
ments, agencies programs and accounts. recipients.
• The state auditor may, at any time, conduct a performance • On or before 30 days after the performance audit is made
audit . . . Follow-up performance audits . . . may be con- public, the corresponding legislative body or legislative
ducted when determined necessary by the state auditor. bodies shall hold at least one public hearing to consider
• No legislative body, officeholder or employee may impede the findings of the audit and shall receive comments from
or restrict the authority or the actions of the state auditor the public.
to conduct independent, comprehensive performance • For performance audits of state government and its agen-
audits. cies, programs and accounts, the legislature must consider
• The state auditor is authorized to issue subpoenas to gov- the state auditor reports in connection with the legislative
ernmental entities for required documents, memos and appropriation process.
budgets to conduct the performance audits. • An annual report will be submitted by the joint legislative
• These performance audits shall be conducted in accor- audit and review committee by July 1 of each year detail-
dance with the U.S. Government Accountability Office ing the status of the legislative implementation of the state
government auditing standards. auditor’s recommendations. Justification must be provid-
ed for recommendations not implemented. Details of
• The state auditor may contract out any performance other corrective action must be provided as well.
audits.
• For performance audits of local governments and their
• For counties and cities, the audit may be conducted as agencies, programs and accounts, the corresponding leg-
part of audits otherwise required by state law. islative body must consider the state auditor reports in
• Each audit report shall be submitted to the corresponding connection with its spending practices.
legislative body or legislative bodies and made available • An annual report will be submitted by the legislative
to the public on or before 30 days after the completion of body by July 1 of each year detailing the status of the leg-
each audit or each follow-up audit. islative implementation of the state auditor’s recommen-
• Beginning on December 8, 2005, 0.16 percent of the sales dations. Justification must be provided for
and use taxes collected shall be dedicated to funding com- recommendations not implemented. Details of other
prehensive performance audits. This revenue shall be corrective action must be provided as well.
deposited in the Performance Audits of Government
Account. Only the state auditor or the state auditor’s
designee may authorize expenditures from the account.
June 2006 15
Advancing
Government
Accountability
Association
of Government
Accountants
PH703.684.6931
TF800.AGA.7211
FX703.548.9367
www.agacgfm.org
[email protected]