Secretary of State

Audits Division

State of Oregon

DEPARTMENT OF HUMAN RESOURCESMedicaid Management Information System Review

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Secretary of State

Audits DivisionNo. 97-83 December 15, 1997

State of Oregon

DEPARTMENT OF HUMAN RESOURCESMedicaid Management Information System Review

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Secretary of State Audits DivisionAuditing for a Better Oregon

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255 Capitol Street NE • Suite 500 • Salem, Oregon 97310 • (503) 986-2255FAX (503) 378-6767 • INTERNET: Audits.hotline@state.or.us

http://www.sos.state.or.us/audits/audithp.htm

The Honorable John KitzhaberGovernor of OregonState Capitol BuildingSalem, Oregon 97310

Gary Weeks, DirectorDepartment of Human Resources500 Summer Street NESalem, Oregon 97310

This report is on our review of payments made through the Medicaid ManagementInformation System of the Department of Human Resources. We identified controlweaknesses resulting in overpayments made to providers during fiscal year 1995-96 thattotaled approximately $1.3 million. The list of overpayments has been turned over to thedepartment for recovery.

The Department of Human Resources agrees with our findings and has responded bydeveloping an action plan to address most of our concerns and to recover most of theoverpayments.

The cooperation extended by the management and staff of the Department of HumanResources was commendable and much appreciated.

OREGON AUDITS DIVISION

John N. LattimerDirector

Fieldwork Completion Date:August 12, 1997

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T A B L E O F C O N T E N T S

Page

SUMMARY...................................................................................................................vii

INTRODUCTION

BACKGROUND.................................................................................................... 1

MEDICAID MANAGEMENT INFORMATION SYSTEM .................................. 1

INFORMATION SYSTEM CONTROLS .............................................................. 2

SCOPE AND METHODOLOGY .......................................................................... 3

AUDIT RESULTS

OVERPAYMENTS MADE ON BEHALF OF DECEASED CLIENTS ................ 5

OVERPAYMENTS RESULTING FROMINEFFECTIVE PROGRAMMED EDIT CHECKS................................................ 8

OTHER CONTROL WEAKNESSES.................................................................... 9

INADEQUATE SYSTEM MAINTENANCE ....................................................... 11

REPORT DISTRIBUTION ............................................................................................ 14

COMMENDATION....................................................................................................... 14

AGENCY’S RESPONSE TO THE AUDIT REPORT................................................... 15

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SUMMARY

PURPOSE Medicaid payments are paid through the MedicaidManagement Information System (MMIS) of theDepartment of Human Resources. The purpose of thisreview was to determine whether MMIS controls weresufficient to ensure that claims paid through the systemwere appropriate.

BACKGROUND MMIS is the federally mandated computer system thatautomates Medicaid claim payments. During fiscal year1995-1996, approximately 14 million claims totaling$1.3 billion were paid through MMIS. Within theDepartment of Human Resources, the Office of MedicalAssistance Programs (OMAP) is responsible for Medicaidas well as MMIS. OMAP relies on the complex series ofautomated controls in MMIS to ensure that payments madethrough the system conform to current laws and regulations.OMAP receives technical support to maintain and modifyMMIS through the Office of Information Systems (OIS) inthe Department of Human Resources.

RESULTS IN BRIEF Specific MMIS controls have been insufficient to ensureappropriate payment of claims. From our limited testing ofclaims processed through MMIS during fiscal year1995-96, we identified control weaknesses resulting inoverpayments to providers totaling approximately$1.3 million. These errors included $420,000 that OMAPinadvertently paid to insure Oregon Health Plan clientswho had previously died. In addition, MMIS allowed$800,000 in overpayments because its controls to limitpayments to designated service levels did not function asintended. Furthermore, OIS has been unable to keep upwith a growing backlog of MMIS system change requestsor to provide necessary system support. As a result,known system errors have gone unresolved for extendedperiods and cost-effective projects have beeninappropriately delayed. The OIS resource inadequaciesstem in part from statewide and agency pressures to reducestaffing. In addition, turnover within OIS has resulted inthe assignment of less-experienced staff to maintain anincreasingly complex and aging MMIS.

RECOMMENDATIONS We recommend that OMAP and OIS correct faulty systemcontrols or, if it is more cost-effective, implement alternatecontrols or procedures. In addition, we recommend that

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OMAP and OIS provide sufficient staff to ensure the timelyresolution of known system errors and to facilitate cost-effective and required system modifications. We alsorecommend that OMAP recover the $1.3 million in invalidclaims identified by our audit.

AGENCY RESPONSE The Department of Human Resources agrees with our auditfindings and recommendations and has responded bydeveloping an action plan to correct identified weaknessesand recover overpayments.

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INTRODUCTION

BACKGROUND

The Department of Human Resources is Oregon’s healthand social services agency. The department’s mission is tohelp people be independent, healthy, and safe. To achieveits objectives, the department administers more than 200programs through six divisions and three program offices.The department’s Office of the Director provides overallleadership and integration of the several programs, as wellas department-wide services such as accounting andinformation systems.

Under the Office of the Director, the Office of MedicalAssistance Programs (OMAP) administers the MedicaidProgram for the state of Oregon. OMAP has a legislativemandate to improve the health of Oregonians by expandingaccess to health coverage. It is working to meet thisobjective by prioritizing services through a managed caresystem called the Oregon Health Plan. The Oregon HealthPlan currently operates under a Medicaid waiver from thefederal government and provides health care coverage toapproximately 380,000 Oregonians. The federalgovernment provides approximately 62 percent of thefunding for Medicaid with the remaining resources comingfrom the state.

MEDICAID MANAGEMENTINFORMATION SYSTEM

The Medicaid Management Information System (MMIS) isthe federally mandated computer system that automates andmanages payment of claims. MMIS is a mainframeapplication composed of approximately 950 productionprograms operating within seven subsystems. In order forMMIS to correctly process claims, the subsystems musteffectively interact with each other. During fiscal year1995-96, MMIS processed approximately 14 millionclaims totaling $1.3 billion.

The department implemented the MMIS in 1982. Its maincomponent is a copy of the Missouri fee-for-service systemthat was developed in the late 1970s and then modified tocomply with OMAP’s specific needs. Since the

Introduction

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implementation of the original system, OMAP hassignificantly changed MMIS. The most significantmodifications were program additions to facilitate the1994 implementation of the Oregon Health Plan. At thattime OMAP added a subsystem to allow for processingand support of managed care claims and contracts. Inaddition, other changes to both federal and staterequirements and programs have required OMAP tofrequently alter MMIS.

Ongoing maintenance, operation, and support of MMIS areprovided through the department’s Office of InformationServices (OIS). The Office of Information Servicesbecame a centralized function under the Office of theDirector in 1996.

INFORMATION SYSTEMCONTROLS

Information system controls are typically classified aseither general controls or application controls. Generalcontrols are designed to protect the environment in whichsystems operate. They include procedures that controlphysical security, system development, and backup andrecovery of data, and procedures to ensure appropriateoperation of the system. On the other hand, applicationcontrols relate to specific processing requirements. Thosecontrols are intended to ensure that there are no errors inthe recording, classifying, and summarizing of authorizedtransactions.

The Medicaid Management Information System relies onestablished general and application controls to determinewhether claims are valid prior to payment of claims.During the claims processing cycle, MMIS performsprogrammed edit checks that compare claims data withclients’ medical histories. In addition, those edits performvarious tests that determine whether specific requirementshave been satisfied. For example, one-edit checks to seewhether clients are eligible for services provided. Thesystem utilizes approximately 360 programmed edit checkswhile processing claims. Each edit is a unique andintegral segment of MMIS computer programming code.Because MMIS programming is very complex, changes toedits usually require significant computer programmingresources.

Introduction

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In addition to programmed edit checks, MMIS performsother programmed checks called audits. Programmedaudits verify that claim data conform to medical policy.For example, one audit limits payment for certain surgeriesto once in a lifetime. Unlike programmed edits, audits aredesigned to be easily adjusted to fit changing paymentcriteria. Such adjustments do not require changing MMISprogramming code and thus may be performed by OMAPsupport staff rather than OIS programmers. MMIScurrently uses approximately 240 programmed audits.

Edits and audits constitute the majority of the MMISprogrammed procedures used to control the claimspayment process; therefore, the majority of our tests wererelated to the various critical edits or audits we identifiedthrough our risk assessment. Weak general controls,however, can negate the effectiveness of applicationcontrols. Therefore, an important aspect of our audit wasto determine whether OIS corrected general controlweaknesses identified in a previous audit report.

SCOPE ANDMETHODOLOGY

The objective of our audit was to determine whetherdepartment controls are sufficient to ensure that claimspaid through the Medicaid Management Information Systemcomply with current laws, regulations, and policies, thussafeguarding the state’s resources.

The scope of our audit included claims paid through MMISbetween July 1, 1995, and June 31, 1996.

To gain an understanding of existing controls and relatedrisks, we:

• Reviewed applicable federal and state laws,regulations, and policies;

• Interviewed OMAP, OIS, and other related departmentpersonnel;

• Reviewed prior audit workpapers and reports ofsimilar audits from other states and federal regulatoryagencies;

Introduction

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• Reviewed the agency’s system documentation andprocedures; and

• Reviewed the agency’s efforts to correct generalcontrol weaknesses identified by a previous audit.

To determine whether controls were sufficient to ensureappropriate payment of claims, we developed computerassisted audit techniques to evaluate the effectiveness ofselected controls. We designed our tests based onidentified risks, materiality, and the ease of verificationand recovery of overpayments. In addition, we observedcontrol processes and reviewed agency documents relatingto system errors and the resolution of those errors. Wealso reviewed selected computer controls outlined bycurrent computer control guidelines approved by theInformation Systems Audit and Control Association.Furthermore, we reviewed OMAP’s MMIS system changerequests and alerts as well as OMAP’s agency budget andstaffing documents.

We verified the reliability and completeness of computer-processed data used in our audit procedures by comparingdata amounts with financial records, matching downloadrecord totals with reported amounts, and comparing data todocumented record layouts. We also provided detailcopies of our test results to OMAP for its verification andto facilitate the timely recovery of invalid payments.

We conducted this audit in accordance with generallyaccepted government auditing standards. We limited ourreview to those areas specified in this section of the report.

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AUDIT RESULTS

OVERPAYMENTS MADEON BEHALF OF DECEASEDCLIENTS

State and federal regulations indicate that payments forservices or items provided to clients subsequent to theirdeaths are not valid. The intent of this regulation is toensure that funds expended actually benefit the clients’health and welfare and to prevent payment of claims filedby mistake as well as claims that are fraudulent. TheOffice of Medical Assistance Programs (OMAP) isresponsible for ensuring that claims satisfy this rule priorto payment. They are also responsible for ensuring thatMedical Management Information System (MMIS) controlsare sufficient to detect invalid claims and, if errors arefound, to make appropriate recoveries of funds.

OMAP relies on a series of MMIS programmed edits toensure that it pays only claims for clients who are eligibleat the time services are rendered. These edits accessinformation residing within the recipient subsystemcontaining the clients’ eligibility histories. Thus, theeffectiveness of the programmed edits depends on reliableand timely eligibility data.

The Department of Human Resources (department),however, determines eligibility for the Oregon Health Planon a relatively infrequent basis. Clients whose needs maybe temporary must demonstrate their eligibility for benefitsby submitting applications on a semiannual or annual basis.Other clients, such as the severely mentally impaired, areautomatically eligible for medical benefits because of theircontinuing need. Therefore, the department does notrequire these clients to resubmit benefit renewal forms on aregular basis. Caseworkers service those clients andupdate their eligibility records as required. Caseworkersare not always aware of a client’s death, however, andwithout this information they cannot update the system’seligibility records.

A client’s death immediately terminates eligibility formedical benefits. The appropriate MMIS eligibility file,however, does not reflect the change in eligibility statusuntil either the caseworker discovers the event or the client

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fails to resubmit a required application for Oregon HealthPlan benefits. In either case, this time differentialincreases the risk that OMAP will inappropriately payclaims on behalf of the client.

Monthly managed health care premiums, referred to ascapitated payments, are particularly vulnerable to this risk.Managed care clients receive health care services throughhealth care organizations and other contractors paid inadvance of providing services. In other words, providersreceive health care premiums whether the clients presentthemselves for service or not. On the other hand, clientscovered on a fee-for-service basis must actually receiveservice from a health care professional before OMAP isbilled and the claim paid. Because managed care contractsrequire payment in advance, MMIS automatically createsand then pays monthly capitated premiums for all enrolledclients whose records indicate eligibility.

Our tests of claims processed during fiscal year 1995-96found that MMIS inappropriately paid 3,680 claims tohealth care contractors to insure managed care clients whohad previously died. The inappropriate claims for thisone-year period totaled approximately $420,000. We alsofound that payments for invalid capitated claims routinelycontinued for several months after clients’ deaths. Forexample, OMAP continuously paid one client’s capitationpremiums through June 1996 even though the client died inOctober 1995. Invalid payments for that client totaledapproximately $4,300.

Our testing also indicates that other services have the samerisks as capitated health care payments. For example,Portland metropolitan area clients having regulartransportation needs may receive bus passes or othertransportation through a special OMAP contract withTri-Met. Each month Tri-Met automatically bills OMAPfor the number of rides those clients are scheduled to make.Tri-Met, however, also relies on MMIS eligibility recordsto verify that clients are eligible for its services.Therefore, when the department does not update eligibilityrecords in a timely manner, invalid claims can begenerated through Tri-Met’s automated billing process.Our tests found that during our audit period MMISinappropriately allowed payment for 264 Tri-Met claimstotaling approximately $1,700 on behalf of clients who haddied prior to the claimed date of service.

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In addition to the just described claims, we identified 242fee-for-service payments to 86 other providers totaling$21,310 that failed our date-of-death tests. Our testsrevealed that those payments were for a variety ofservices, and no single provider received more than$1,600.

Invalid claims such as those identified by our tests may bethe result of inadvertent errors or provider abuse. Ourtests were not designed to ascertain whether theoverpayments were the result of fraud. Therefore, weprovided copies of our test results to the Department ofJustice Medicaid Fraud Unit for further investigation.

The conditions described above exist because theDepartment of Human Resources has not implementedcontrols sufficient to ensure that its clients’ eligibility filesare updated in a timely manner after its clients’ deaths. Inaddition, OMAP has not implemented controls to identifyand then recover invalid claims payments resulting fromthe untimely eligibility updates. Further discussionregarding insufficient MMIS system support can be foundin the Inadequate System Maintenance section starting onpage 11 of this report.

Agency AccomplishmentsIn response to the conditions described above, OMAP is inthe process of formulating and implementing a correctiveaction plan. This plan includes the following:

• Obtaining regular date-of-death data from the HealthDivision of the Department of Human Resources.

• Implementing ongoing procedures to identify invalidMMIS claims resulting from date-of-death eligibilityissues.

• Providing notification to health plan providers ofanticipated recoveries of funds.

• Implementing procedures to recover invalid paymentsmade to providers including the $443,000 specificallyidentified by our audit.

OMAP estimates that it will complete this action plan byDecember 1997.

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Audit RecommendationsWe recommend that OMAP complete the above actionplan in its entirety and that it make appropriate restitutionto the federal government for its proportionate share offunds. In addition, we recommend that the departmentimplement additional procedures to ensure that its clients’eligibility files are updated in a timely manner and thatpayment errors that may have resulted are recovered.

OVERPAYMENTSRESULTING FROMINEFFECTIVEPROGRAMMED EDITCHECKS

According to policy, the department offers some servicesto clients in only limited quantities. OMAP is responsiblefor ensuring that controls are sufficient to limit paymentsfor those services to the specified quantities. Furthermore,OMAP is responsible for ensuring that controls are alsosufficient to detect claims processing errors in a timelymanner and, if such errors are found, make the appropriaterecovery of funds.

OMAP relies on MMIS programmed edit checks to satisfythe just described criteria. These programmed checks,called audits, test claims data against established paymentcriteria. For example, the department’s Mental Health andDevelopmental Disability Services Division established alimit for mental health assessments at 16 units per monthper client. To ensure that claims satisfy this criterion,OMAP configured an audit intended to disallow paymentfor claims that exceed the designated limit.

During our review, we tested seven of the possible 240programmed edit checks to see if they correctly limited theservices as anticipated. We found that none of the auditstested successfully limited claims to the appropriateservice level. For example, one audit intended to denyclaims after a 40-unit-per-month limit allowed paymentsfor claims that totaled 252 units for one client during a one-month period. As a result, OMAP overpaid the providerof these services $2,811 for the 212 units of service notallowed according to regulations. Through our tests weidentified approximately $800,000 in recoverableoverpayments made to providers during fiscal year 1995-

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96 for the seven limitation audits tested. Based on theresults of our tests, we concluded that the risk is significantthat all 240 MMIS programmed audits may have beenfaulty for an indefinite period of time.

These invalid claims were paid because MMIS limitationaudits were not functioning as intended. Furthermore,OMAP and OIS have not provided system support orcontrols sufficient to identify and resolve systemapplication errors in a timely manner. A detaileddiscussion regarding insufficient MMIS system support canbe found in the Inadequate System Maintenance sectionstarting on page 11 of this report.

Agency AccomplishmentsIn response to the conditions described above, OMAP iscurrently developing procedures to recover theapproximately $800,000 in overpayments specificallyidentified by our audit.

Audit RecommendationsWe recommend that OMAP work quickly to recover theapproximately $800,000 in overpaid claims identified byour audit. We further recommend that OMAP, inconjunction with OIS, make necessary corrections toMMIS to effectively limit services. In addition, werecommend that OMAP and OIS provide sufficient systemsupport, controls, and procedures to identify the full extentof errors caused by faulty limitation audits and recoveroverpayments when identified.

OTHER CONTROLWEAKNESSES

According to federal and state regulations, claims must besubmitted to OMAP within one year of the date service isrendered in order to be valid. In cases where serviceinvolves an inpatient hospital stay, the claims must besubmitted for payment within one year of the date ofhospital discharge. OMAP relies on MMIS programmededits to ensure that these criteria are met. The editscompare the submission date with the appropriate servicedate and reject claims failing the criteria.

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Our tests revealed that a small number of claims notmeeting the above payment criteria were inappropriatelypaid through MMIS. These few instances, however,totaled approximately $62,000 for fiscal year 1995-96.Our review of those claims failing our test revealed thatthe majority of the invalid claims were from nursing homeproviders. We examined the specific audit responsible fordenying such claims and found that it included a provisionallowing a two-year window for paying all nursing homeclaims. Further inquiries confirmed that the edit wasaltered in 1992 at the request of a Senior and DisabledServices Division manager. Current employees of thedivision, however, confirmed that the change request wasinappropriate and that they assumed that MMIS wouldcurrently deny payment for claims submitted past therequired one-year deadline.

We also found that OMAP, in conjunction with OIS, didnot have sufficient controls to ensure that data processedthrough MMIS was balanced to inputs. These controls areto prevent errors from occurring during the processing ofdata and include procedures for balancing applicationoutputs to relevant control totals.

Our review of controls revealed that OMAP does notmaintain control logs to facilitate the reconciliation justdescribed. As a result, during one month of our audit wefound that several claim batches totaling $1.4 million wereprocessed and paid twice. OMAP, made aware of theerror by providers who detected the mistake, made theappropriate correction and recovered the funds.

Agency AccomplishmentsOIS is currently developing controls to prevent batchesfrom being submitted into MMIS more than once. Inaddition, OMAP is developing procedures to identify andrecover claims submitted after one year from the date ofservice, including the $62,000 specifically identified byour audit.

Audit RecommendationsWe recommend that OMAP and OIS implement in atimely manner the controls as outlined in the AgencyAccomplishments section above and that OMAP makeappropriate restitution to the federal government for its

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proportionate share of funds. In addition, we recommendthat OMAP and OIS modify the MMIS edits designed todeny claims submitted past the required time limit toconform with the one-year deadline for all claims.

INADEQUATE SYSTEMMAINTENANCE

OMAP is responsible for handling public resources andfor applying those resources both economically andeffectively for their intended purpose. Thus, OMAP andOIS are responsible for ensuring that MMIS is secure andadequately maintained. System maintenance includesproviding timely system modifications. Thesemodifications involve mandatory adjustments madenecessary because of changing state or federal legislation.They also include corrections to resolve system processingerrors and system modifications to allow for timelycompletion of program functions.

The MMIS system changes originate from written systemrequests that department employees generate as problemsor needs are identified. These requests includeinformation regarding the need for proposed changes aswell as estimates of associated costs and benefits. Keydepartment managers review the system requests duringweekly committee meetings. During these meetings,managers evaluate, prioritize, and refer system requests toOIS for implementation. Requests that are not referred toOIS are maintained on a pending list of projects and arereconsidered during subsequent meetings. Managersprioritize projects according to whether they involvefederal or state mandates, have critical deadlines, orinclude financial benefit. System requests are often basedon incomplete information, however, because necessarydata are often difficult or costly to derive.

Our examination of outstanding system requests revealedthat OIS was not able to perform necessary MMIS systemmodifications in a timely manner. We found that systemrequests that when completed would result in significantcost savings go months or even years before OIS is able toaddress them. For example, part of the 1994implementation of the Oregon Health Plan includedprovisions to recover capitated payments of clients whomoved out of their service areas. OMAP estimated that

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this system modification would save approximately$135,000 per month. It was not until June 1996, however,that department managers gave the project a priority highenough for OIS to begin work on it. The project wascompleted in March 1997. The actual recoverable costsresulting from the modification averaged $108,000 permonth for the period from November 1996 through April1997. Savings that would have resulted from an earlierimplementation of the project have not been identified andthus will not be recovered.

We also found that OIS was unable to provide requiredsystem support in a timely manner. This support includesresolving known system processing errors and identifyinginvalid claims that may have resulted from those errors.For example, in July 1996 Oregon Audits Divisionauditors found evidence that some limitation audits werenot working as anticipated. The error was reported toOMAP employees, who performed a preliminaryevaluation of the problem. OMAP then generated a systemrequest that was later prioritized as urgent. As of October1997, however, the system request remained in a pendingmode. As was discussed previously in this report, ourtests identified recoverable errors totaling approximately$800,000 that were attributable to the limitation auditsissue described above.

The list of unresolved MMIS system requests has beengrowing. As of May 1997, there were 609 separatepending items. We conclude that current OIS resources areinsufficient to resolve the most significant of those requestsin a timely manner.

The consequences of untimely system modificationsinclude overpayments to providers, resulting in increasedcosts to both state and federal governments. In addition,overpayments resulting from unresolved system errorsbecome more difficult to recover as they age. Eventually,claims may become unrecoverable and the resources lost.Furthermore, the federal government’s Health CareFinancing Administration may find the state out ofcompliance with regulations regarding programs utilizingMMIS. Noncompliance in turn may result in theassessment of financial penalties against the state.

OMAP, in conjunction with OIS, has not providedadequate system support for MMIS. Excessive delays in

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implementing system modifications and resolving systemerrors result from having insufficient staff assigned to thetask. This, in part, results from statewide and agencypressures to reduce staffing. Furthermore, requiredchanges to MMIS relating to the Oregon Health Planincrease the complexity and amount of maintenancerequired by the system. In addition, staffing turnoverwithin OIS result in the assignment of less-experiencedstaff to maintain a more complex MMIS. At the same time,OIS staffing levels for MMIS have declined.

Agency AccomplishmentsOn August 27, 1997, the Office of the Director of theDepartment of Human Resources granted approval for 12additional OIS staff positions to maintain MMIS.Recruitment efforts have begun and OIS anticipates fillingall positions within one year.

Audit RecommendationsWe recommend that OMAP, in conjunction with OIS,provide sufficient staff to ensure timely system support ofMMIS. This support should be a level appropriate notonly to ensure the timely resolution of required systemmodifications, but also to facilitate those system changesthat are cost-effective. To this end, OMAP shouldconsider using contractors or temporary employees to meetcritical needs.

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REPORT DISTRIBUTION

This report is a public record and is intended for the information of theDepartment of Human Resources, the governor of the state of Oregon, the OregonLegislative Assembly, and all other interested parties.

COMMENDATION

The courtesies and cooperation extended by the officials and staff of theDepartment of Human Resources were commendable and much appreciated.

AUDIT TEAM

Cathy Pollino, Deputy DirectorNeal Weatherspoon, CPAPhilip A. Burger, CPADarcy Johnson, CPACurtis HartingerAnn Takamura

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AGENCY’S RESPONSE TO THE AUDIT REPORT

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FACTS ABOUT THE SECRETARY OF STATE AUDITS DIVISION

The mission of the Audits Division is to “Protect the Public Interest and ImproveOregon Government.” The Oregon Constitution provides that the Secretary of State shallbe, by virtue of his office, Auditor of Public Accounts. The Audits Division exists tocarry out this duty. The division reports to the elected Secretary of State and isindependent of the Executive, Legislative, and Judicial branches of Oregon government.The division audits all state officers, agencies, boards, and commissions and overseesaudits and financial reporting for local governments.

DIRECTORY OF KEY OFFICIALS

Director John N. LattimerDeputy Director Sharron E. Walker, CPA, CFEDeputy Director Catherine E. Pollino, CGFM

This report is intended to promotethe best possible management of public resources.

Oregon Audits DivisionPublic Service BuildingSalem, Oregon 97310

503-986-2255 Hotline: 800-336-8218Internet: Audits.Hotline@state.or.us

http://www.sos.state.or.us/audits/audithp.htm

If you received a copy of an audit and you no longer need it, you may return itto the Audits Division. We maintain an inventory of past audit reports, and your

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We invite comments on our reports through our Hotline or Internet address.

Auditing to Protect the Public Interest and Improve Oregon Government