Lita McHugh, CPA, CIG Inspector General for Stacy M. Butterfield, CPA Polk County Clerk of Courts
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1 Lita McHugh, CPA, CIG Inspector General for Stacy M. Butterfield, CPA Polk County Clerk of Courts An Audit & Investigation of Hope Now February 3, 2017
2 Objectives Learn how an audit can evolve into an investigation, and vice versa Understand the importance of a complainant in guiding the work Learn the differences in work flow for an audit and an investigation
3 Initial Complaint Anonymous letter sent to: Hope Now board of directors County manager Indigent Health Care director Allegation: Hope Now is using county IHC funds to fund all kinds of projects and persons are benefitting personally Non-specific who? what? how much? when?
4 Background Hope Now NFP organization providing substance abuse and mental health treatment services to inmates coming out of incarceration Contract funded under Indigent Health Care division by discretionary half-cent sales tax $1 million annually at time of complaint Largest individual contract to provider of SA/MH services under IHC program
5 Preliminary inquiries Staff cooperative and dedicated to mission Very small board of directors (5-6) BOD no prior experience running NFP Fairly new program (5 years) grew out of a volunteer ministry in jail Exec Director was formerly Board Member, recently hired as ED Incomplete documentation & recordkeeping
6 Investigation evolves into Audit Complaint was non-specific: Funds spent improperly on what? Who is benefitting? Preliminary investigative inquiries Interviewed HN staff and management Reviewed contract terms Reviewed monthly invoices to county (no support attached) Examined HN supporting records Observed poor record-keeping in support docs Unable to substantiate vague allegation Decided to audit monthly invoicing to county
7 Initial Audit Observations No annual audit required by contract $9,000 in checks written to cash (1 year) Unreconciled bank statements (receipts not provided to bookkeeper) No BOD meeting minutes Exec Director changed invoices to county that were prepared by Assistant Director IHC division did not audit invoices Missing or poor documentation for services
8 Invoice Support Example
9 Initial Audit Observations (cont.) Several property purchases, including 2 former furniture warehouses and large tract of undeveloped land Very few contributions County essentially sole source of income; how did HN pay for real property? Modular buildings located in north Florida documented only by letter from donor $168,000 paid to donor for transport and storage of modular buildings
10 Audit evolves into Investigation Near end of audit fieldwork, anonymous complainant requested a meeting with IG During subsequent investigation, other anonymous complainants came forward Specific allegations and documentation Re-opened investigation Expanded time frame to beginning of contract with county (2011) 36 allegations and specific information to guide investigation
11 Investigative findings Consulting fees totaling $23,000 paid to board member (prohibited by contract) Consulting fees paid to Christian roundtable for business coaching Checks written to cash totaling $23,000 Board member s wife earned commission on purchase of 2 warehouses Warehouses purchased from couple who may or may not have been board members
12 Modular buildings Narrative on modular buildings from E.D. Donor is known personally only to one board member No positive proof of ownership Another party owns land where now stored Property appraiser shows buildings present for at least 2 years on current site IG traveled to north Florida to observe modular buildings
13 Modular buildings
14 Modular buildings
15 Modular buildings
16 Recap of modular buildings $168,000 paid for transport of buildings Buildings transported from North FL to Polk County then back to North FL $7,800 paid for furniture used w/ buildings Furniture being stored either in Ocala or North Carolina Upon inquiry, HN can t locate furniture Also can t locate donor IG found the donor
17 Anthony Hemphill
18 Anthony Hemphill
19 Another Coincidence
20 Audit Findings No annual audit requirement in contract Billed county for participants who had reached treatment goals but were not graduated from the program due to failure to complete their co-pays Billed county for taking clients to outside meetings provided by others (NA, AA, CA, and church based treatment programs) Billed county for dispensing Rx (no permit and pharmacist on staff)
21 Audit Findings (continued) Billed county for treatment sessions with no facilitator signature Billed county for treatments with no participant signatures (attendance sheet completed by facilitator) Billed the county for spiritual studies (program is spiritually based but not allowed to proselytize per contract)
22 Presentation to Commissioners No benefit to the county from a fee-forservices agreement that did not require HN to use funds earned for the program. Real property purchases made by HN were not prohibited under current contract Overall, about 125 participants graduated from 2011 to Contract payments to HN totaled over $5 million during that time.
23 Result Commissioners terminated contract Awarded contract to another agency with long history of good stewardship Program continues at $600,000 annually
24 Successful Investigations Specific allegations Ability to interact with complainant Ask questions Obtain documents Professional skepticism Interview skills
25 3. Fraud, Waste and Abuse FRAUD HOTLINE: Online: Mail: Inspector General P.O. Box 9000, Drawer CC-14 Bartow, FL 33831
26 Lita McHugh Inspector General (863) Polk County Clerk
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