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HomeMy WebLinkAboutCOM 0583.002 1998-2000 ~v w ~c~ ~ •~z AL KONISHI DONALD IKEDA County Clerk Depury County Clerk CONSTANCE R. KIRIU Legislative Auditor OFFICE OF THE COUNTY CLERK County ojHawaii Hawaii County Building 15 Aupuni Street Hilo, Hawaii 96720 November 24, 1999 -i'l RECEIVED'~"`^-.. Chairman John Rav and Charter Commissioners By 25 Aupuni Street p°te-'-""-- ~~~'I Gaunty Hilo, H[ 96720 Dear Chairman Rav and Commissioners: [ would like to thank Chairman Ray and several commissioners for approaching me with interest in suggesting improvements to the legislative auditor's office and the charter's mandate that the council conduct a critical review of every program funded in whole or in part by county funds. My work in county government service has spanned an 18-year period, of which the last 5',z years have been as legislative auditor. Prior to that, I have worked as a legislative assistant, a planner, and depute county clerk. My perspective stems from the question: Does the current structure of the legislative branch set forth in the Hawaii County Charter promote an effective legislative auditing and research program as intended by the 1968 Charter Commission% 1968 CHARTER COMMISSION In reading the January 3, 1968, Charter Commission minutes, a discussion between Board of Supervisor Herbert Matayoshi and Board of Supervisor Chairman Shunichi Kimura is particularly enlightening. According to Board Chairman Kimura, the "council should have the benefit of a legislative auditor, or whatever you want to call him: an analyst, a management analyst, or whatever office, but that s the proper office for inquiry on the part of the council because they're coming up with annual budget and review programs." Supervisor Matayoshi then argued that the independent audit should suffice. But Kimura stated an external financial audit performed by an audit firm does not provide the depth of analysis a program audit could provide. He observed that an outside auditor comes in for a very short period of time and couldn't possibly know all the ramifications of a large government organization. While Kimura felt the periodic post-audit was a good thing, having "a legislative auditor like the State Legislature has, it's a function that should be required of the council." Further, Kimura suggested that the legislative branch should have adequate, qualified "staff to review not only the budget when it comes out, but to review the Q~, programs and inaugerate programs and get the facts for materials for the council." Comm, NO. DD2' File No. Ref. To: Ref. Date DEC 1 4 1999 The Charter Commission voted to provide the council with a legislative auditor under the county clerk. The resultant designation of the legislative auditor contained in today's Cbarter has remained unchanged since 1968. [t reads "The council shall appoint the county clerk which shall be exempt from civil service laws and classifications. The county clerk shall [AJppoint the deputy county clerk and the legislative auditor, with the approval of the council, and such positions shall he exempt from civil service laws and classifications." The Hawaii County Charter does not elaborate on the duties and responsibilities of the legislative auditor. Nor will you find them in the Hawaii County Code. You must look to the Council's Rules of Procedure, which states that the legislative auditor (1) shall conduct apost-audit of all transactions of the county, (2) shall be responsible for all projects assigned by the council, and (3) shall be held accountable to the council. While such language allows for maximum council Ilesibility, it raises some interesting problematic issues. ORGANIZATIONAL STRUCTURE AND PROFESSIONAL PROFICIENCY The Legislative Auditor's Office is presently composed oF7legislative assistants, 1 legislative analyst, 1 fiscal/program auditor, apersonnel/account clerk, an administrative assistant to the legislative auditor and the legislative auditor-- for a total of 12 people. This number and the structure of the office are subject to change depending upon the council leadership. There was a period when all legislative assistants worked only for their appointive council members. The office was reduced to the legislative auditor, the legislative analyst and the two support staff. With regards to hiring, except for the legislative analyst, who is protected by civil service laws, the remaining staff are patronage appointments. Depending upon the policy of the council at the time, minimum qualifications and job descriptions may or may not be established. Job performance reviews are superfluous. How does this affect the office? A current snapshot of the legislative auditor's office reveals that the 9 non clerical legislative assistants have accumulated a total of 50.5 years of experience in the office. If you exclude the analyst, who is protected by civil service laws, the total drops to 28 years for S people. This calculates to an average of 3.5 years per person in an office intended or expected to perform policy research and legislative budget and program analysis. Since 1992, there have been four different persons appointed to the legislative auditor position. Since 1992, Che office has seen 13 legislative assistants resign, whether by choice or not. The legislative auditor's office does not offer long-term career potential. These nebulous organizational aspects do not reinforce the value of building a rich foundation of knowledge and experience that can be achieved through continuity and the hiring of qualified professionals. PROGRAM ACCOUNTABILITY Under the system described above, the legislative auditor cannot formulate an auditing and research program with meaningful goals and objectives because of an inherent lack of management control over the program. 2 Such a situation forms the underlying philosophical question with which [struggle. How can the legislative auditor be expected to evaluate programs and management when the basic structure prevents its own house from being in order Despite this quandary, the office has conducted numerous reviews and evaluations over the years. 'these include program reports of the humane society and numerous departments, an analysis recommending the redistribution of the highway fund, an examination of the aeromedivac contract, a study of the pros and cons of a county motor pool, a limited scope performance review of the county's glass recycling and diversion program, a special study oFthe marijuana eradication grants received from the federal government, and an evaluation of construction change orders made by the Department of Public Works to name a few. The office is also involved with contracting the county's post audit to an independent accounting Firm, and reviewing the county's annual budget, which includes the council's review of county departments and their budgets. A significant portion of staff time is spent responding to constituent-related concerns, such as illegal drag-racing, street light outages, barking dogs, road closures, potholes, flooding, and on and on. The mixing of constituent-related assignments with the comprehensive research projects and program studies have been the source of debate over the years. Can the two programs co-exist without impacting the other? [believe the audit function will succeed only if there are changes made to the structure of the legislative branch. The reasons are simple. YELLOW BOOK STANDARDS An audit program should follow standards found in a ,yellow book called "Government Auditing Standards." The yellow book is published by the Comptroller General of the United States and has been adopted by government auditors. This document contains standards for audits of government organizations, programs, activities and functions. These standards are to be Followed, when required by law, regulation, agreement, contract, or policy. The standards pertain to auditors' professional qualifications, the quality of audit effort, and the characteristics of professional and meaningful audit reports. The general standards are that (1) staff should collectivelypossess adequate orof~ essional proficiency for the tasks required; (2) in all matters relating to the audit work, the audit organization and the individual auditors, whether government or public, should be free from personal and external imRairments to independence should be organizationally independent and should maintain an independent attitude and appearance; (3) due professional care should be used in conducting the audit and in preparing related reports; and (4) an appropriate internal quality control system should be in place and the audit organization should undergo an external quality control review. Portions of the yellow book are copied as Appendix 1. The County of Hawai'i's legislative auditor's office does not and can not follow the yellow book standards. Staff positions are patronage and, consequently, the office is organizationally and politically tied to the council. Work products generated by the office have not been called audits, but rather special studies, reviews, or reports. In order to conduct an °audit° that meets the yellow book standards, an independent audit firm must be contracted to do the work. 3 EXAMPLES OF LEGISLATION ESTABLISHING AN AUDCf PROGRAM To develop an effective audit function, changes would be desirable at the Charter level. The National Association of Local Government Auditors (NALGA) has published the attached document called "Guidelines and Model Legislation for Local Government Auditors" (Appendix [I). It provides charter language for an appointed or an elected auditor. Notable differences from Hawaii Countv~s Charter include (1) the council, not the county clerk, makes the appointment, (2) the auditor's duties are specified; and (3) auditor removal is for cause. Surfing the Internet for sample charter language, I found a section of King County's Home Rule Charter (Appendix 1[I). The last paragraph of this section defines the level of independence required of the auditor's office. It says "The organization and administration of the auditor's office shall be sufficiently independent to assure no interference or influence external to the organization shall adversely affect an independent and objective judgment by the auditor and the auditor shall be provided a discrete budget and staff allocation." The City and County of Honolulu's Charter allows the legislative branch to establish an office of council services (Appendix IV). Additionally, the Charter contains procedures for conducting financial performance audits (Appendix IV). The Revised Ordinances of Honolulu elaborates on the purpose of the office of council services, the appointment of the director of council services (six years), and the authority oC the director (Appendix V). [n its implementation, the director has been able to establish an audit division consisting of 2.5 positions. Since the 1968 Charter Commission seemed to want to mirror the functions of the state auditor, a spreadsheet containing information about the state auditor and the director of the legislative reference bureau is attached (Appendix V[). After looking at these examples, it is remarkable that the County of Hawai`i's legislative auditor's office tries to deliver both auditing services and research/reference services together with constituent-based services. Certainly, all are equally important. But they cannot be equally and effectively performed under the current structure of the legislative branch. If the desire of the Charter Commission, past or present, is to establish a strong legislative support branch, the details should be set forth in the Charter and then codified. The idea of a strong organizationally-independent auditing and research team is attractive if you are considering the merits of an appointed administrative manager or if you are looking at maintaining the mayor-council form of government. MANDATORY PROGRAM REVIEW ' Moreover, the proposed independent structural framework would provide a backdrop for executing the council's mandate of critically reviewing every program of the county every four years. As long as this mandate is in the charter, it can and will be used against the council or a county program, when necessary, regardless of the comprehensiveness of the review. 4 In reading 1980 Hawaii Charter Comission transcripts, the program review was likened to the state's process of `sunsetting' a program. Specifically, the state legislature includes sunset provisions for evaluating new professional and occupational licensing programs to determine whether the program should be terminated, continued or modified. The county rarely includes a 'sunset' clause in its laws. Thus, the council's annual review of county departments, their programs, and their budgets has been the process used to meet the Charter mandate. Department and program budgets are cut or increased based upon the review. During the course of their critical review or during the course of the fiscal year, the council will request in-depth studies or reviews of a particular issue or problem. Except for eliminating the mandate entirely, there is no change to the Charter that helps the council out of its perceived predicament Strengthening the audit and research operations under the legislative branch could be one solution. CONSIDERATIONS There will probably be an increase in the legislative cost of county government. At the minimum, council members must still hire employees loyal to their individual efforts. The legislative auditor's office should maintain a separate budget similar to the county clerk's-elections division. Although there is nothing that precludes a separate budget from being formulated under current practices, there is no overwhelming reason to do so. In past financial audit reports, the independent auditors have recommended the county consider hiring an internal auditor. This suggestion does not require a Charter amendment and it will add a professionally qualified audit function to the County. However, an internal auditor usually serves the need of management by monitoring activities top management cannot itself monitor, identifying and minimizing risks, helping managers manage, and supplying or validating data to make management decisions. (/ntcrna/ Auditing-The PrdCtiCC o£Modern Internal Aaditin~p. Lawrence B. Sawyer, ]D, CIA, PA. 1996) The time is not right. The county is not large enough to warrant amore-independent audit and research function. The council lives and dies by its appointments. The services of the legislative auditor's office are adequate. Yet there is value in the goals of greater accountability, effectiveness and efficiency these are consistent with the growing public demand. D[SCLiSSION PROPOSAL For discussion purposes, I have crafted proposed Charter language that specifies the scope of duties of the legislative auditor's office. The proposal also creates independence by setting a term of appointment and acknowledging its organizational and administrative independence, especially as it relates to audit functions. 5 The council may cstabh'sh an olTice of the lcgfslati re auditor and create such positions therein as it deems necessary to assist it in the exercise o£its Icyis/ati~r poi+cr, pros ided the positions sha// be exempt From cfri/ service laws and classifications. The Icgr's]a ti vc auditor shall be appointed by a majority oFthe county council For asix- year term. The council may remove or suspend the /egrslativeauditor by atwo-thirds rote o£the counci/. The o~cc oF[hc /cgislatirz auditor shall (I) conduct, or cause to he conducted the independent post audits ofthe county's financial transactions, and other audit scrr ices as may be requested by the council followinggorernment auditingstandards; (1) assist the counci/ in the review and adoption of the operating and capital budgets; (3) assist the council in complying with sccUbn 3-16, Hawai i County Charter, (4) provide comprehensive research and reference services For the council; and (S) perForm other support duties as may be assigned by the council. The organization and admim'stration oFthc /cgislativc auditor's ofpcc shall be suflicicntly independent to assure that no intcrtcrcncc or rnflucncc to the organization shall adverse/y afFect an fndependentand objective judgment by the legislative auditorand its auc/itstaff' The /c{~islati re auditor sha// he provided a discrete budget and stafTallocation. CONCLUSION Thank you again for the opportunity to submit my thoughts to you. Please understand that it was done independent of the council and its members. Hopefully, the information provided you has been able to elevate the issues from the self-interest of any person or group to permanent, public interest. Sincerely, ~ Constance R. Kiriu Legislative Auditor Enclosures 6 ':~-~,s~c~~ ve ~uctrfo,-- United States General Accounting Offfce GA~ By the Comptroller General of the United States - June 1994 Government Auditing Standards 1994 Revision APPENDIX I ~ E •o `o o ° ~ v°i E~° a~i ~ ~ao"~ r°i. a od d °2 °od E°aFnu T~~ ~ ~ g I ~ `3 w C `ea O ~ ~pY ~ ~ 9 G ~ U =y ~ O 7 d} ~n ~j y ~j' ~ ~ ; id 7 ~ . ~ Q yy°FF ~ C i0 O ~C W N ~ ~ •p ~j e v ~ •u~' ~ `Oy 5 ' OV C ~ -5 ~ G~~ ~N~bO td O9 D~ C~. ~ 3.~ 9a~i j ate, '8i udy .5~°~ ~ a d ~'c ~06 L O ai O ~ ~d ~ < ~ `o 3 8 k ~,7 O a c V Uy C ~p S ay ~ ~ O Q G ~ ~ ~ ` C ~ '3 ed U V ~ V ~ < ~ ~ C u G G C, ~ w 3 G G ~ s ~y, `~77 ~ sgg Cd y~`pJ .eVd E C~ p ~ T ~ 9 Z o ~ z c ~II~~ ~~Eu dU 3~G ~SDO ryJ ~ce~ 6a~~y~~~od~ ~ ~r ~a~~~s r rte. ~c C O C 9 G w d N d O~ G G d~ G d Y a O 9 ~ ~ n 'o d.~ ~.~';;3 g'~ ° d ova. o `~a.~ < 0'3 ~`•°o•o E ~ Y9 dw W a c ~ E ° ;t 2fi ° a ~ % I wt~v ~Ea,3 $y vE~'CE3o ~C'c oCU~ ~ e ~ 9 ~ N O d d~ O° 'J U 'O ro p~p~, Q V td w G~ N ttl a ~y a .o~~oveo3 d. ~ vu 288i a+ox uc ° d o dsocrL 'S so5wu ~du `a < L' I Emooero~'~°'+co'°- .6~o~~va.c.`~3a ~0~~~~0 ~.~~Co ~ ~ a ' I O O~ G N r~ 7 V G 7 ~ N N 9 y~ V f V 6 cv~~E~"•GG irc ~e°io~or.~ o ~~~a~ N3 `o o O E S R pG O Q N C rY+ of vOtl aGi U d d L E 0 ~ ° N ~ ° U 7 ~ E G. ° ~ ~ r0 ~ ~ O 9 m V ~ ~ ~ ~ ~ c~ a C y GG ~`?~'d m0' e7~ m~~~yu~ w~ ~5 ~ i .i e°p V G v~ tOd ~ u k R U O d N v O .i n~ m 9 .•i u 9 F Q •ry Y d 0 ~ ~.7 ~ a d ~ m d V G O ~ h 9o~O> ~3~~c~~ ~.5dd~~c' ~ye".o°' ~~'S'~E~L'~ ~2sO.. 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Kentucky ~IU503 IJ you rrrut/d hke ro download the ,Acfuhc Acrobat version of This report fair hest(<r forrnrntec! f~rintittg) c/ick here. NATIONAL ASSOC[AT10N OF LOCAL GOVERNMENT AUDITORS GUIDELINES AND MODEL LEGISLATION FOR LOCAL GOVERNMENT AUDITORS APPENDIX II i c,r i o,».~» e a~ r MuJd Lcg~~lainm i99Jl Lup ao~c ualc~oig uipunit nuiJlcp~a Llud Table of Contents From the President _ i N. A. L. G. A. Board Members (I 999-20U1q ii Introducliou.._..... _ _ _ _................._l Guidclmcs for Establishing Audit Functious._......._......._ _..............2 LEGISLATIVE/APPOINTED AUDITOR Model Charter Language Establishing a Legislative/Appointed Function ......................4 Model Codc/Ordinance Language to huplewent Charter Provisions Establishing aLegislative/Appointed Local Govenuueut Auditor ....................._......._....5 ELECTED AUDITOR Model Charter Language Establishing an Elected Auditor iu Local Govenuuent....... .l2 Model Codc/Ordinance Language to Implement Charter Provisimis Esmblishing a Legislative/Appointed Local Govenunent Auditor ....................................li NATIONAL ASSOCIATION OF LOCAL GOVERNNIENT AUll1TORS September 1, 1999 Dear Local Government Decisionmaker, 2 0l 25 1027 9`) 9.dJ 1'~ Model I c.,;.l~non to 99i hnp_ ~~~ltenalg~ urg nrcunv_ modleeiv.html The National Association of Local Government Auditors (N A.L.G.A.) believes that audits of local government programs, functions, activities and organizations are essential. As an integral part of the governance process, the audit function plays a key role in providing accountability for management's performance. The greater the separation between a policy or oversight body and its management, the more critical the need for an independent function within the organization to ensure the accountability of its management The primary mission of the auditor is to require an accounting of the activities and accomplishments of the organization. [n the public sector, the contribution of the audit function to management accountability is significant, because the ultimate form of performance accowrtability, bankruptcy, is not a major threat to public sector organizations. There is little likelihood that government will "go out of business", even when it experiences severe financial difficulties. Private sector organizations have some inherent motivation to evaluate and control their risks if only to ensure survival, public sector entities seldom share this motivation. The importance to the public, our ultimate customer, of the functionally independent auditor function can be demonstrated by the emergence of numerous federal, state and local laws and ordinances establishing internal auditors. This trend has emerged because government officials, both elected and appointed, have realized that an independent oversight function is particularly important because of the unique relationship that ,government auditors have with their primary stakeholders, the taxpayers. The taxpayers and, for the most part, elected representatives want assurance that their scarce tax dollars are being protected by audit functions which operate with reasonable independence from the supervisory chain. Anything less severely limits the credibility of the auditor in terms of the public trust. In 1992 the National Association of Local Government Auditors issued its first edition of "Guidelines and Model Authorizing Legislation for Local Government Audit Functions" This document was based on the first comprehensive set of guidelines and model legislation for local government auditing promulgated by the National Intergovernmental Audit Forum in 1987. The purpose of this document is to foster accountability and improved government services and programs in cities, counties, special districts and taxing jurisdictions. It is our sincere hope that this document will provide local government officials with a clear understanding of the role of the local government audit function and assist in providing a blueprint for the development of model legislation authorizing local government audit fimetions. Feel free to contact N.A L_G_A_ at (606) 276-0686 or kpnasaet~mmis net. Sincerely, Helen Niesner, President 3 0l 2z l0 27 9I 9 JJ PM h1oJd I rer;lunwi i9 99) hap nalga om organic muJle~~i~. hinil N.A.L.G.A. Board Members (1999-2001) Helen Niesner, President Jerry J. Heer, Past President City Auditor Director of Audits City of Austin Milwaukee Co. Dept of Audit Austin, TX Milwaukee, WI 512/499-2805 FAX 499-2078 414/278-4206 FAX 223-1895 helen.neisnediz)ci.austin.tx.us jheer;c~ex~ccom Alan D- Ash, Presiden!-L/ect R.D. MacLean City Auditor Director of Management Audit City of Gainesville City of Calgary Gainesville, FL Alberta, Canada 352/334-5020 FAX 334-2096 403/268-5670 FAX 268-5411 ashad(cici eainesville.fl.us rmcleanr eov_calgar ay b.ca Susan McNitt. Secreau~v J. C. Squires Citv Auditor Assistant City Auditor Oklahoma City, Oklahoma City of Long Beach 541/774-6021 FP.X 774-6455 Long Beach, CA Susan mcnitt cdci.okc-ok.us 562/570-6989 FAX 570-6167 jcsquir'a~ci lone-beach.ca.us Mike Taylor, Treas~aer Quarterly Editor City Auditor Douglas C. Jenkins City of Stockton Deputy Director of Audits Stockton, CA Milwaukee, WI 209/937-8918 FAX 937-7026 414/278-4229 FAX 223-1895 tnita~l~rYclci ~t~ckton_ca_us milc~aud c execs c.coal BOARD MEMBERS AT LARGE J of 2? t0 27 99 ~ a4 PM Moael Lr,_nluiwn i 9 `)`Il htlp nalgu ur_ ur_am~ niod!e,~ie html Peggy J- Gamble Internal Auditor Membership Services County of Volusia N.A L.G.A. Deland, FL 2401 Regency Road, Suite 302 9041736-5920 FAX 522-5707 Lexington, KY 40503 p~~ambler"c~cavolusia.fl us 606/276-0656 FAX 278-0507 k~nasact ~~mis.net Joe Harris Auditor General Detroit, MI 313/224-4037 FAX 224-4091 harri sj (rc cnc I_ci. detroit_mi, ii s NATIONAL ASSOCIATION OF LOCAL GOVERNMENT AUDITORS GUIDELINES AND MODEL LEGISLATION FOR LOCAL GOVERNMENT AUDITORS INTRODUCTION Audits are essential in providing reasonable assurance that local governments are 1) operating in accordance with laws, rules, regulations and policies; 2) responding to citizen needs; and 3) functioning economically, efficiently and effectively. Local governmental managers are responsible for designing and implementing effective internal controls to ensure that assets are safeguarded, records are reliable, reports on operations are sufficient and fairly presented, fraud, waste and abuse are deterred, and programs, functions, and activities are conducted economically, efficiently and effectively- Audits of local government are an essential element of public control and accountability. By independently reviewing and reporting on programs, functions, activities and organizations, and by conducting or causing to be conducted independent audits of financial statements, auditors provide the public, elected officials and management with a fair, objective and reliable assessment of local government performance. Local government auditors can also make other contributions such as recommending improvements in policies, organizational structure, accounting procedures and management control systems and operations. Auditing is especially important in local government because: 5 01 2? 10 27 9`J 9 J4 YM M„~cl , m,lutiun i9 11 i hlip n+~lau ui e ui ~unv.. mudlcma html 1 Unlike the private sector, profit cannot be used readily as a key indicator of performance in government. Other measures of governmental efficiency, economy and effectiveness are needed. ? Governments must function in compliance with laws, policies and established procedures while exercising good judgment in their stewardship of finite resources and following sound management principles The audit function should be organized and structured to make the greatest possible contribution to economical, efficient and effective government conducted in accordance with legislative and management directives. We, therefore, endorse the following guidelines for establishing the audit function in local government entities GUIDELINES FOR ESTABLISHING AUDIT FUNCTIONS Local government charters, ordinances or policy statements establishing an independent audit function (either legislative/appointed or elected) should: 1 Provide for an "independent" auditor either through election or appointment by the legislative body or chief executive officer. Appointment or removal of an appointed auditor by a chief executive officer should be subject to legislative approval. 2. Authorize the auditor to conduct financial and performance audits in accordance with sovernment ~uditin~_standards as promulgated by the United States General Accounting Office. Government auditing standards provide for various types of audits which generally fall into one of the following categories a. Financial audits include financial statement and financial related audits. l Financial statement audits provide reasonable assurance about whether the financial statements of an audited entity present fairly the financial position, results of operations, and cash tlows in conformity with generally accepted accounting principles. 2 Financial related audits include determining whether (1) financial information is presented in accordance with established or stated criteria, (2) the entity has adhered to specific financial compliance requirements, or (3) the entity's internal control structure over financial reporting and/or safeguarding assets is suitably designed and implemented to achieve the control objectives. b. Performance audits include economy and efficiency and program audits. 1. Economy and efficiency audits include determining (a) whether the entity is acquiring, protecting, and using its resources (such as personnel, property, and space) economically and efficiently, (b) the causes of inefficiencies or uneconomical practices, and (c) whether the entity has complied with laws and regulations concerning matters of economy and efficiency. 2. Program audits include determining (a) the extent to which the desired results or benefits established by the legislature or other authorizing body are being achieved, (b) the effectiveness of organizations, programs, activities, or functions, and (c) whether the 6 10 27 99 J JJ PM M„dcl I rc, elation f`~ `~)1 hnp nul~_a wg rn~ .min modl.~ci. hiinl entity has complied with laws and regulations applicable to the program. c. Other Activities of an Audit Organization Auditors may perform services other than audits. For example, some auditors may. 1. assist a legislative body by developing questions for use at hearings; 2. develop methods and approaches to be applied in evaluating a new or a proposed program; 3 forecast potential outcomes under various assumptions without evaluating current operations; 4. review proposed contract terms and conditions; and 5. perform investigative work. The following key elements are crucial in providing for an effective independent audit function: l Require a written report containing relevant background information, findings and recommendations regarding audited activities and communicate the results of the report to the Audit committee, Legislative Board and management. 2. Assure that the auditor has full, free and unrestricted access to local government employees, officials, records, vendor contracts and reports. 3 Ensure that all contracts contain a right to audit provision. 4 Establish an audit committee at the local level to be responsible for review of the auditor's work concerning financial and performance audits. The committee should also work to assure maximum coordination between the work of the auditor and the audit needs of the chief executive ofFcer, the legislative body and external auditors. 5 Assign the auditor responsibility to coordinate and monitor all audits and audit related services received by the local government entity including those performed by public accountants, consultants or audit organizations of the entity and its subdivisions. 6 Negate the influence of partisan politics on the selection and operations of the appointed auditor or on the operations of the elected auditor. 7. Require that responsible government managers promptly respond in writing, within a time specified, to audit recommendations explaining what actions are planned or have been taken to deal with problems identified in audit reports 8 Require follow-up on significant tndings and recommendations from previous audits to determine whether timely and appropriate corrective actions have been taken by management. 9. Provide for periodic quality assurance reviews of the audit function. io z~ ~~y vnn ~ ~r>; MnJcl ~~la~ion i 9 99 ~ h¢p nulca ur_~ o[guniz niudlccu html The concepts identified in these guidelines are divided between establishing alegislative /appointed and elected auditor. They include recommendations for each related to Charter provisions and legislation. MODEL CHARTER LANGUAGE ESTABLISHING ALEGISLATIVE/APPOINTED AUDITOR IN LOCAL GOVERNMENT ENTITIES a ~,i io z~ vv v,aa eM Modc~ I eni,lulion 99 i http nulgiu ui ur,=ume mudle_n h~ml S'E('l70N (NAME UF' ENTI LY) Au(dllOU' The (NAME OF ENT17Y) auditor shall be appointed by a majority of the legislative body/board (or by the chief executive of (NAME OF ENTI"IY) and ratified by a majority of the legislative body). The auditor shall conduct, or cause to be conducted financial, performance and other audit services following government auditin<, standards. The auditor can be removed from office for cause on a vote of at least two thirds of the legislative body. All audit reports are public documents and will be made available for public examination. MODEL CODE/ORDINANCE LANGUAGE TO IMPLEMENT CHARTER PROVISIONS ESTABLISHING ALEGISLATIVE/APPOINTED LOCAL GOVERNMENT AUDITOR AN ORI)/NANCE/RESOLUTION/POLICY STATEMENT ESTABLISHING AN OFFICE OF (NAME OF ENTITY) AUD/TOR AND SETTING FORTH THE CONDITIONS AND SPECIFICS UNDER WHICH SA/D OFFICE SHALL FUNCTION WHEREAS governmeuul auditing independerully reviews', evahuates artd reports on the financial condition, the accm~acy of financial record keeping, compliance with applicable laws, policies, guidelines and procedures, and efficiency and effectiveness of operations; and WHFIZEAS' mauragemeurt and employees nu the public sector are responsible for taxpayer use of public resources and should be held accountable for their use; and WHEREAS' it is vital shat government exercise its power and perform its duties in compliance with /cnv, policy, crud estahlished procedures and apply goad jurdgmenl and sound management practices; and WHF_RF;AS' the indepeneteruce and puhlie accountabiiiry of the auuditor can be assured by provision of an independent, legus'lative/y nppointed (w~ ratified) auditor. NOW THEREFORE BE lT ORDAINED'RESOLG'ED THAT: 1. "1'he Office of (NAME OF ENTITY) Auditor is hereby established. Rh.' IT I IRTH6R ORDAINED RESOL l/ED 1 HA 1': 2. l he auditor sha/1 be named tM~ough appointment by a majority vote of the legislative body: hoard (or appoiuned by the chief axecudive officer arud ratified by a majority vote of the legis/ative body,board). 3. The auditor shall be kruowledgeable in per formance and financial auditing, public administration, and government financial and,frscai practices. a.1'he muditor shall not be actively involved in partisan political activities or the political affairs of (NAME OF ENTl1Y). e,~rzs io n ~~y yaa vnn Mold Lc No ton i') 9)1 hnp ~~~~o nalea ore uraan~t mudlcei~ html .S. l he auditor shall possess adequa7e professional proficiency for the job, demonstrated by relevant certification such as CIA (Certified Irnerrral Auditor), CPA (Certified Public Accountants or an advanced degree in n ralevrnv, field with at /east five years experience in the field of government auditing, evaluation or analysis (CIA or CPA preferred). The cnrditor shall have a bachelors degree in accoarnirrg, business adminisn~ation, ur public administration or related field If financial statement audii.+~ are performed, the auditor must be a CPA. 6. The auditor shall serve a minimum term of _ years, unless removed for cause by a vote of at least nvo-thirds of the legislative body board. The auditor may be re-appointed at the end of the term of office. 7. An audit comminee shah be es7ablished to consul! with the auditor regarding establishment of audit srhedrde, audit progress, audit follow-up, special needs; and shall work to assure maximum coordnurtion between the work of the auditor and the needs of the chief executive officer the legislative body board and external auditors. Audit committee members shall be appointed by the legislative body acrd a1! appointees shall be independent of the local government's management and admirristrntive service. "the legislntive body shall appoint at least one of its members to serve on the committee. N. l he auditor and the auditor's office shall adhere to government auditing standards in conducting its work and shall be considered independent as defined by those standards. CHAPTER (NUMBER) LEGLSLATIVE/APPOINTED AUDITOR Sectiorn: 1. Assistants and Employees 2. Scope of Audits 3. Audit Schedule a. Specrcrl Audits .i. Funding 6. Records 7. Access to Employees, Records and Property 8. Agency Response 9. Audit Reports to Legislative Body'Board 10. Report of hregulnrities L 1. Annual lZeport /l. Audit Follow-up /3. Contract Auditors, Consarltants and Experts l~. Quality Assurance Reviews SECTION 1 Assistants and Employees L The Office shall be provided a separate budget (subject to available resources) sufficient to carry out l0 of--~ 10 27 99 9.J~1 NM Mold i_c.•i.~lunon r`l )9l httr nulc;i.ore uraaniz modleeie htnil the responsibilities and functions established in this ordinance. 2 The auditor shall establish an organizational structure appropriate to carrying out the responsibilities and functions of this ordinance. 3 The auditor shall have the power to appoint, employ, and remove such assistants, employees and personnel as deemed necessary for the efficient and effective administration of the affairs of the office. SECTLON 2. Scope of Audits 1 The auditor shall conduct work in accordance with government auditing standards. Z The auditor shall have authority to conduct financial, performance or other audits of all departments, offices, boards, activities and agencies of the entity in order to independently and objectively determine whether. a. activities and programs being implemented have been authorized by government Charter or Code, state law or applicable federal law or regulations; b. activities and programs are being conducted as prescribed by management/governing body to accomplish the objectives intended by government Charter or Code, state law or applicable federal law or regulations; c activities or programs efficiently and effectively serve the purpose intended by government Charter, Code, state law or applicable federal law or regulations; d. activities and programs are being conducted and funds expended in compliance with applicable laws; e revenues are being properly collected, deposited and accounted for; f resources, including funds, property and personnel, are adequately safeguarded, controlled and used in an effective and efficient manner; g. financial and other reports are being provided that disclose fairly and fully all information that is required by law, that is necessary to ascertain the nature and scope of programs and activities and that is necessary to establish a proper basis for evaluating the programs and activities; h there are adequate operating and administrative procedures and practices, systems or accounting internal control systems and internal management controls which have been established by management; or i there are indications of fraud, abuse or illegal acts which need further investigation. SECTION 3. Audit Schedule At the beginning of each calendar (fiscal) year, the auditor shall submit a one to five year audit schedule to the legislative body/board (audit committee) for review and comment. The schedule shall include the proposed plan for auditing departments, offices, boards, activities, subcontractors and agencies for the period. This schedule may be amended during the period after review with the legislative body/board or audit I I of 1027 99 9'J~ PM Model I ru,,lmion 1`~ `»1 htlp. naleu.org orgona modleeie hlml committee. Additionally, the auditor may spontaneously initiate and conduct any other audit deemed necessary. In the selection of audit areas and audit objectives, the determination of audit scope and the timing of audit work. the auditor should consult with federal and state auditors and external auditors so that the desirable audit coverage is provided and audit effort is properly coordinated. SECTION 4_ Special Audits In the event the auditor receives a request to perform a special audit not included in the annual audit schedule, the auditor may obtain the approval of the legislative body to amend the annual audit schedule to reflect the approved modification. SECTION 5_ Funding Funds sufficient to carry out the responsibilities specified herein shall be provided. The auditor's performance shall be evaluated annually by the appointing authority (and by the audit committee) and the auditor's salary 'shall be adjusted accordingly. SECTION 6. Records The auditor shall retain for three years (or longer if so directed by statute or ordinance), a complete file of each audit report and each report of other examinations, investigations, surveys and reviews made under legislative authority. The file should include audit workpapers and other supportive material directly pertaining to the audit report. SECTION 7. Access to Employees Records and Property l All officers and employees of (NAME OF ENTITY) shall furnish the auditor with unrestricted access to employees, information and records (including automated data) within their custody regarding powers, duties, activities, organization, property, financial transactions, contracts and methods of business required to conduct an audit or otherwise perform audit duties. In addition, they shall provide access for the auditor to inspect all property, equipment and facilities within their custody. If such officers or employees fail to produce the aforementioned access and/or information, the auditor may initiate a search to be made and exhibits to be taken from any book, paper or record of any such of£cial or employee, or outside contractor or subcontractor, except as governed by statute. Further, all contracts with outside contractors and subcontractors shall provide for auditor access to all financial and performance related records, property, and equipment purchased in whole or in part with governmental funds and facilities. 2 The auditor shall not publicly disclose any information received during an audit that is considered proprietary in nature (confidential) by any local, state or federal law or regulation. SECTION 8 A~_encv Response A final drafr of the audit report will be forwarded to the audited agency and the chief executive officer for review and comment regarding factual content before it is released. The agency must respond in writing and specifying agreement with audit findings and recommendations or reasons for disagreement with findings and/or recommendations, plans for implementing solutions to issues identified and a time table to complete such activities. The response must be forwarded to the auditor within (SPECIFY TIME FRAME). The t2 ofzs io 27 vv y as eM Mudd Lcv~+Imrou i9 797 htlp. nalcu ors organ~t mudleu~~-Mml auditor will include the agency's response in the report. If no response is received, the auditor will note that fact in the transmittal letter and will release the audit report. In the case of contracted audits, audits may be released without inclusion of a response. Any subsequent responses shall be distributed to those who received the audit report. SECTION 9 Audit Reports to Legislative Body/Board 1. Each audit will result in a written report containing relevant background information and findings and recommendations, and shall communicate results to the Audit Committee, Legislative Board and/or management. The report shall also be available for public examination. 2 The auditor shall submit each audit report to the legislative body/board and shall retain a copy as a permanent record. A copy shall also be filed with the clerk of record and/or the area public library. SECTION 10- Report of Irreeularities If during an audit, the auditor becomes aware of abuse or illegal acts or indications of such acts that could affect the governmental entity, the auditor shall report the irregularities to the audit committee, the chief executive officer or legislative board/body. In the case of an auditor appointed by the chief executive officer, if the chief executive officer is believed to be a party to abuse or illegal acts, the auditor shall report the acts directly to the legislative board/body. If it appears that the irregularity is criminal in nature, the auditor shall (immediately) notify the appropriate chief prosecuting authority (when appropriate) in addition to those officials previously cited. SECTION I1_ Annual Report The auditor shall submit an annual report to the legislative body within (number of days) after the calendar/fiscal year indicating audits completed, major findings, corrective actions taken by administrative managers, and significant findings which have not been fully addressed by management. SECTION 12 Audit Follow-up The auditor shall follow-up on audit recommendations as practical to determine if administrative managers are implementing corrective action. The auditor may request periodic status reports from audited entities regarding actions taken to address reported deficiencies and audit recommendations. SECTION 13. Contract Auditors Consultants and Experts l Within budget limitations, the auditor may obtain the services of Certified Public Accountants, qualified management consultants, or other professional experts necessary to perform the auditor's duties. An audit that is performed by contract must be conducted by persons who have no financial interests in the affairs of the governmental unit or its officers. The auditor will coordinate and monitor auditing performed by public accounting or other organizations employed under contract by the (NAME OF ENTITY). 2 The auditor will play a key role in the selection of the (NAME OF ENTITY) independent auditor. In contracting for the external audit, the auditor will Follow (ENTITY)'s normal contracting processes The auditor's selection of a certified public accounting firm for the annual financial audit must be approved by the (GOVERNING BODY), Id ~ 2> 10 27 99 9.1~ PM Model I eeivlution l9 9`J) http' ~~n,~.nalga ore on_umz mudlegic html SECTION 14- Quality Assurance Reviews 1. The audit activities of the auditor's office shall be subject to quality review in accordance with applicable government auditing standards by a professional, non-partisan objective group utilizing guidelines endorsed by N.A.L.G.A. A copy of the written report of this independent review shall be furnished to each member of the legislative body. This report shall be available to the public. 2 The quality control review shall determine compliance with government auditing standards and the quality of the audit effort and reporting, including: a. general standards such as staff qualifications, due professional care, and quality assurance; b fieldwork standards such as planning, supervision, and audit evidence; and c reporting standards such as report content, presentation, and timeliness. 3 The local government shall reimburse the costs of the quality control review team from funds budgeted in the auditor's budget or other in-kind support. i~ ~,rzs io z~ yv mas i Mudd Lcenlutum 99l http ~~u~~ nnleu orc oreena modlema html MODEL CHARTER LANGUAGE ESTABLISHING AN ELECTED AUDITOR IN LOCAL GOVERNMENT ENTITIES AN ORDINANCE/RESOLUTION/POLICY STATEMENT PRESENTING a proposed Charter Amendment to the people to establish the elected position of (NAME OF ENTITY) auditor and setting forth the conditions and specifics under which said official shall function. WHLRF.AS the activity of government auditing independently reviews, evaluates and reports on the financial condition, the accuracy of financial record keeping, compliance with applicable laws, policies, guidelines and procedures, and efficiency and effectiveness of operations; and WHEREAS management and employees in the public sector are responsible for the use of public resources and should be held accountable for their use; and WHEREAS' it is vital and fair to effective government that the government exercise its power and perform its duties in compliance with law, policy, and established procedures and apply good judgment and sound management practices; and WHEREAS the independence and public accountability of the auditor can be assured by provision for an elected auditor. NOW 777h.'RF.FY)RE BE 1TORDAlNED-RESOLVED THAT the following Charter amendment be presented to the people for vote at the (TYPE) election to be held on (DATE). SECTION 1. Elected Auditor The office of elected auditor of (NAME OF ENTITY) is hereby established. SECTION Z Term of Office 16 of 2 i 10.27 9`J 9:J~ PM Model L~ ,Iwiou i9 l4 ~ hnp: ~ew~~e _nnleu ore orEan¢ modlee~s_html The term of the auditor shall be Years. SECTION 3 Nonpartisanship The position of the auditor shall be nonpartisan. SECTION 4 Professional Qualifications and Experience The auditor shall possess adequate professional proficiency for the job, demonstrated by relevant certifications such as a CIA (Certified Internal Auditor), CPA (Certified Public Accountant) or have an advanced degree in a relevant field with at least five (5) years experience in the field of government auditing, evaluation, or analysis. The auditor shall have a bachelors degree in accounting, business administration, public administration or related field. If financial statement audits are performed, the auditor must be a CPA. SECTION 5. Compensation The auditor shall be compensated at a rate comparable to other similarly situated elected officials or as otherwise provided by statute. SECTION 6. Fundin> Sufficient funds shall be provided to carry out the responsibilities specified herein. SECTION 7 Restrictions on Other Candidacy Filin_ for another elective office over which the auditor has audit jurisdiction will be the same as a resignation, effective as of date of filing- SECTION 8 Audit Scope Standards and Schedule The auditor shall have the authority and responsibility to conduct financial and performance audits or special studies of all phases of (NAME OF LOCAL GOVERNMENT) government in accordance with government auditing standards. Such audits may include financial, compliance, performance, and program results auditing. The auditor shall consult with the (GOVERNING BODY/AUDIT COMMITTEE) regarding the selection of audit entities, but the final decision of what to audit shall remain with the auditor. The auditor shall furnish the (GOVERNING BODY) with a planned audit schedule by the beginning of each fiscal year. .Additionally, the auditor may modify the audit schedule or initiate and conduct any other audit deemed necessary to undertake. SECTION 9. Access to Employees Records and Property The auditor shall have unrestricted access to employees, officials, records and reports, and as necessary, require all branches, departments, and officials of government to produce documents, files and other records. SECTION l0. Audit Reports l Each audit will result in a written report containing relevant background information and findings and recommendations, and shall communicate results to the Audit Committee, Legislative Board and/or management. The report shall also be available for public examination. n ~rzs iov vy 9:ai Pm Model i_cc~.~la~nm 99l http nuleo use oreaniz_ modlruu html 2 The auditor shall submit each audit report to the legislative body/board and shall retain a copy as a permanent record. A copy shall also be filed with the clerk of record and/or the area public library. SECTION 11 Responses to Audit Reports The auditor shall furnish a final drag of each audit report to the audited entity for review and comment before it is released. The responsible official must respond in writing to the auditor's recommendations withir working days, or within the time frame specified by the auditor. SECTION l2. External Audits The auditor shall appoint external Certified Public Accountants to conduct certified financial statement audits, as specified by state or local law. The auditor shall coordinate and monitor the conduct of, and responses to, external financial statement audits. The auditor shall work toward the elimination of duplicative audit work through cooperation with state and federal and external auditors. SECT[ON 13. Audit Committee An audit committee shall be established in an advisory capacity to provide recommendations for the auditor's salary, work program, review of the audit function and hiring of external auditor. The committee shall consist of five (5) members, any one of whom is the auditor and two members from the governing body and two (2) members with audit credentials appointed by the auditor. MODEL CODE/ORDINANCE LANGUAGE TO IMPLEMENT CHARTER PROVISIONS ESTABLISHING AN ELECTED LOCAL GOVERNMENT AUDITOR AN ORDINANCE amending the Code of (ENTITY), by adding a new Chapter (NUMBER) entitled "Elected Audit Function," setting forth the specifics under which the audit agency of the (GOVERNMENT) auditor's office shall function. The (GOVERNING BODY) ordains: 1. Accountability is inherent in the governing process of this nation. Officials and employees who manage public programs are obligated to justify to the public their methods and purposes in appropriating, applying, and using public resources. 2. Public officials, government managers, and private citizens want and need to know not only whether government funds are handled properly and in compliance with laws and regulations, but also whether public programs are achieving the purposes for which they were authorized and funded, and, whether they are doing so efficiently and economically. 3 An independent auditing function can provide objective information on the operations of government programs, assist managers in carrying out their responsibilities, and help ensure full accountability to the public. 18 of 3~ 10 27 99 9di NM Model LcuiJut wn t9 99 ~ htlp. «ti~~c nal¢aorg oreamz modlaea.h[ml 4 An effective auditing function requires that audit results be accepted and used by public officials. Acceptance requires that the audit function be understood and recognized as valid, and that it be established on a firm foundation of professional competence. > Standards for the conduct and practice of governmental auditing have been developed by the Comptroller General of the United States. 6 The audit function in the (NAME OF ENTITY) approved by the voters through Charter amendment on (DATE), should adhere to these standards in order to ensure that public officials and employees understand the role and function of auditing, to lend consistency and credibility to ongoing audit work, and to provide a basis for monitoring and evaluating the work of audit staff. NOW, THEREFORE the (GOVERNING BODY) directs: The (GOVERNING BODY) hereby establishes a new Chapter (NUMBER) in the Code of the (NAME OF ENTITY), adding a new Chapter to be numbered, titled and read as Chapter (NiJMBER), (TITLE). Chapter (NUMBER) ELECTED AUDITOR Sections: 1. hrdependence 2. Scope of Audits 3. Audit Schedule -l. Access to Employees, Records and Properly Agency Response 6. Audit Repw9s 7. Repor! of L~regrdarilies X. Audit ho!(ow-rrp J: (~onlrac! Audirors, Corrsullnrvs rnrd Ezperls l0. pualityAssurarreeReviews SECTION 1 Independence L An audit function is hereby created within the elected auditor's office, answerable directly to the auditor in accordance with Charter Section (NUMBER). 2. The audit function will adhere [o government auditing standards in conducting its work and will be considered independent as defined by those standards. 3. [f the audit function conducts an audit of an activity for which the elected auditor is or was responsible, the audit scope will state that the auditors are not organizationally independent with regard to the entity being audited. tv orv io~zrye v as PM 6ludci '..~-s~.nlmion ~N N)i http ~~~~u'.nalga.o[n orean2 mudlzgi~. html SECTION 2. Scone of Audits 1 The auditor may conduct financial, performance and other audits of all agencies, offices, boards, activities, functions and agencies of the (NAME OF ENTITY) to independently determine whether a. activities and programs being implemented have been authorized by government Charter or Code, state law or applicable federal law or regulations; b activities and programs are being conducted as prescribed by management/governing body to accomplish the objectives intended by government Charter or Code, state law or applicable federal law or regulations; c activities or programs efficiently and effectively serve the purpose intended by government Charter, Code, state law or applicable federal law or regulations; d. activities and programs are being conducted and funds expended in compliance with applicable laws; e. revenues are being properly collected, deposited and accounted for; f resources, including funds, property and personnel, are adequately safeguarded, controlled and used in a faithful, effective and efficient manner; g. financial and other reports are being provided that disclose fairly and fully all information that is required by law, that is necessary to ascertain the nature and scope of programs and activities and that is necessary to establish a proper basis for evaluating the programs and activities; h. there are adequate operating and administrative procedures and practices, systems or accounting internal control systems and internal management controls which have been established by management; or i there are indications of fraud, abuse or illegal acts which need further investigation. 2. The auditor shall conduct his/her work in accordance with government auditing standards applicable to financial, performance or other activities of an audit organization. SECT[ON 3 Audit Schedule At the beginning of each calendar (fiscal) year, the auditor shall prepare a one to five year audit schedule to the legislative body board (audit committee) for review and comment. The schedule shall include the proposed plan for auditing departments, offices, boards, activities, subcontractors and agencies for the period. This schedule may be amended during the period as the auditor may initiate and conduct any other audit deemed necessary. SECTION 4. Access to Employees, Records and Property All officers and employees of the (NAME OF ENTITY) shall furnish the auditor with unrestricted access to employees, information and records (including automated data) within their custody regarding powers, duties, activities, organization, property, financial transactions and methods of business required to conduct an audit or otherwise perform audit duties. [n addition, they shall provide access for the auditor to inspect all zo ~,rz; io z~ v~~ y~ai am Model Lee~.luhon .9 9)i http «~r~~ nulgu org oreena mudleeu html property, equipment and facilities within their custody. If such officers or employees fail to produce the aforementioned access and information, the auditor may initiate a search to be made and exhibits to betaken from any book, paper or record of any such official or employee, except as governed by statute, and every once having the custody of such records shall make a search and forward such requested exhibits to the auditor. Further, all contracts with outside contractors and subcontractors shall provide for auditor access to all financial and performance related records, property and equipment purchased in whole or in part with governmental funds and facilities. 'The auditor shall not publicly disclose any information received during an audit that is considered proprietary in nature (confidential) by any local, state or federal law or regulation. SECTION 5. Agency Response A final draft of each audit report will be forwarded to the audited agency for review and comment before it is released. The agency must respond in writing specifying agreement with audit findings and recommendations or reasons for disagreement with findings and/or recommendations, plans for implementing solutions to issues identified and a time table to complete such activities. The response must be forwarded to the auditor within the time frame specified by the auditor. The auditor will include the full text of the agency's response within the final audit report. SECTION 6. Audit Reports 1 Each audit will result in a written report containing relevant background information, findings and recommendations and shall communicate results to the appropriate officials. 2 The auditor will submit each audit report to the (GOVERNING BODY) and will retain a copy as a permanent record. Supporting workpapers shall be retained for at least (greater than auditor's term of office). A copy shall be filed with the clerk of record and/or the area library. 3 If appropriate, the audit report shall contain the professional opinion of the auditor or the contract auditor concerning the financial statements issued by the agency or board or if the audit is an expanded scope audit, the report will contain the professional conclusions of the audit regarding the management activities audited. 4 The auditor shall include in the audit reports: a. a precise statement of the scope encompassed by the audit; b a statement that the audit was performed in accordance with government auditing standards; c. a statement that an examination for compliance with applicable laws, policies and regulations was conducted and presentation of the findings associated with that examination; d. a statement of the significant audit findings, including a statement of the underlying cause, evaluative criteria used and the current and prospective significance of the findings; e. a statement that internal control systems were examined and a report of any material weaknesses found in the internal control systems; f statement of response submitted by the audited agency, board or agency relevant to the audit 21 of 2~ 10 27 99 9_JS PM tiluJd Lem,latnw ~ J 99 ~ hnp o~~~~_nalcanrc oremuz mudlcg~n html findings including, if possible, a concise statement of the corrective actions previously taken or contemplated as a result of the audit findings and a time table for their accomplishment; and g. recommendations for additional necessary or desirable action. SECTION 7 Report of Irregularities if the auditor detects apparent violations of law or apparent instances of malfeasance or nonfeasance by an officer or employee or information that indicates wrongdoing may be reasonably anticipated, the auditor shall report the irregularities to the (PRESIDING OFFICER) of the (GOVERNING BOARD). If the irregularity is potentially criminal in nature, the auditor shall notify the prosecuting attorney, when appropriate in addition to those previously cited. SECTION 8. Audit Follow-up The auditor shall follow-up on audit recommendations as practical to determine if administrative managers are implementing corrective action. The auditor may request periodic status reports from audited entities regarding actions taken to address reported deficiencies and audit recommendations. SECTION 9. Contract Auditors, Consultants and Experts Within budget limitations, the auditor may obtain the services of Certified Public Accountants, qualified management consultants, or other professional experts necessary to perform the auditor's duties. An audit that is performed by contract must be conducted by persons who have no financial interests in the affairs of the govermnental unit or its officers. The auditor will coordinate and monitor auditing performed by public accounting or other organizations employed under contract by the (NAME OF ENTITY) to assist with audit related activities. Contracting for the external audit will follow (ENTITY)'s normal contracting processes. The auditor's selection of a certified public accounting firm for the annual financial audit must be approved by (GOVERNING BODY). SECTION 10 Oualitv Assurance Reviews The audit activities of the auditor's office shall be subject to a quality review in accordance with applicable government auditing standards by a professional, nonpartisan objective group utilizing guidelines endorsed b} N.A.L.G.A. A copy of the written report of this independent review shall be furnished to each member of the (GOVERNING BODY). The quality review will use applicable government auditing standards to evaluate the quality of audit effort and reporting. Specific quality review areas shall include staff qualifications, adequacy of planning and supervision, sufficiency of workpaper preparation and evidence, and the adequacy of systems for reviewing internal controls, fraud and abuse, program compliance, and automated systems. The quality review will also assess the form, distribution, timeliness, content, and presentation of audit reports. The government shall reimburse costs of the quality review from funds budgeted in the auditor's budget. zz.~rz~ io z~ w vas em KmE Couun Home Rule Charter, Section 2>0 http: www.me[rokagocauditor charter.htm King Goon#y, Washington l~L,IL~1#f King County Home Rule Charter, Section 250 Section 250. County Auditor The county auditor shall be appointed by a majority of the county council and shall be responsible to the council for conducting, or causing to be conducted, independent post audits of county agencies for the purpose of reporting to the council regarding the integrity of the function of the financial management system, the quality and efficiency of agency management, and the effectiveness of programs. In carrying out this purpose, the auditor shall pertorm the following audits within guidelines established by the county council by ordinance: financial and compliance audits to supplement those performed by the state pursuant to general law, economy and efficiency audits, and program result audits. In addition, the auddor shall pertorm such special studies as may be requested by the council. The auditor shall report the results of each agency audit to the county council. Annual audits shall continue to be performed by the state in accordance with general law. The organization and administration of the auditor's office shall be sufficiently independent to assure no interterence or influence external to the organization shall adversely affect an independent and objective judgment by the auditor and the auditor shall be provided a discrete budget and staff allocation. (Ord. 8649, 9/6/88). Updated: 07/27/J9 About Our Office ~ Work Program ~ Audit Report Index ~ Job Vacancies King County ~ News ~ Services ~ Comments ~ Search Links to external sites do not constitute endorsements by King County. ey visiting this and other King County web pages, you expressly agree to be bound by terms and conditions of the stte. The details, APPENDIX III I oI I l l 23.99 7:00 AM 1 i,S ~ ~ ~ Ml.o-.. i~~~ Y~- ' y^ ~ ~ ° . , ,o 4^~yi ,,K , ~ ~;a x r2 :x:: "'j',. i g . 'w - ~ 2 <a~ ~ _k ~ ~Vr~~~~y^y rte` Y j„ , J ~ .I APPENDIX IV Gul V 9~ O N ~ 'A N L+ L ~ 0? ~ O N L T G 3 C ~ 4T, ~ N osi ~ ~ v N s m ~ L u 'v u 5 N v E m ~ o ~ c c u s m s ~ 3 CG .c 'N E o~° u u o o a N o ~ ~ c~ d r L A o v N~ s s mu u vv~~ E ~ s' m a c c .E v u o s o .o E c E v m° ~ 3= o ~ u N L C° t C E>° ~ L v v 6 rsii 6 b T `ti' .ll+ U L b c0 L ° C .Q u N d~ Y u - ~ ~ r E m ~ ~ s o H ~ E ~ ~ ro o ~ ~ o ° d v i o ° a°'i F w' O e.°_ m 3$ m a E aEi ~ c v° m r v a o ~ E ~ u •O o m ~ ~ ~ .ENE ~ ~ E o ~ h ~ s > v o o °E' m `c° v e o ~ o ~ .N 3 `u' u l s Y ~ a ~ o u o 3 u E D o m.E E v E ~3 i A d~ a ~ 'a v y.: ° v c c c `~c U T.c o o r s o o .o ~ u c 2° n m v o m c E E T~ o. y am.>_ o o as ~ v ~ c e v E L r ~ ~ o o ~ ~ ~ o• ~ ~ H ~ ~ r n Q ° n ~ ~ .h D o W E v° ~ o~ H s° d e m o ~ o Y .n c h ~ a ° A ~ a~ A ° m m e ~ e`~ s~~ fi d ~ o t t ~ o s L s E 7~ T E E a i~~ m E E E °a o N ~ .c ~n' E °LU. D v~~ o f c~ E y e s o c - c .O a c E c - L o a O~ ~ o v c- ~ u u m~ c N 3 D O A~ N E v 'C o, w~ o u ~ 0 9 0 0~ °w' E E o c E cis m L T e o ~ u ° L ~ a N o p u r 'y U U al y ~y u v m CC11 L 6 u m C w U N O y d N ° y 7 y e0 T y a.. N y y N d W N •E y y K 0 s tdd ro ~ - v u ° E E y •'~e s y a L N~ s ~ C a 'd s E E- s o c v s N c F. o n v r c~ c E d~ ~ o F v o F' F" c u T y ~ u u c F• ~ a F u .c oo.~opoN.~ N~ oo u~ E.E~~:d o,_y° 'o~u c ~ ti L C ~ u 'U' N G A c ~ N o c 3 N E ~ a"i o A yri E ~ri'y o~ coo E o Cvi v c a~~o•'" o ~ w o a> u S. w rJ' ~ E- E v °1 Cy u u pop ~>~yy y c~ e v~y ~ ~ ~ E ~n t'~ tTC ~ d N ~ ~ v W L' ~ d ttl L ~ N .p O .7 y °7 Gq ~ O N H K sv:-ai'SuuaodmN~c ~t. 3u ~.~'3umE u•$N~ Omu N"~~:. A T d y sue. a - n E u> v~ v O ~'~ah v • t L C N ~ u C pq UU_ 0.1 O y U 1.. y L' y M1 V i) p u 7 W NL+ .L+ NL. 7 v 3 •u w t ~3 d v eci o m_ ai e`~a c o~ y oyE n°' o ..e,~mv oDNo,~c E i U E v W N „ y '6 ~ ° T'" E ~ ~ L U~ ~ y T L v^., L 7 w T n L ? U? ~ u G O L y y~ 'd O d~ N m a N nl a O C u V~ C C td N>> C u a C N U K N T~ t t~ ~ ~ M E o T'~ n °i u E o N y ~ d r v d u.'y m up ~ c o o ~ c 0J G V C~ t V N d U L u T~ N~ C O N Y h E E s d a .o ~ ~ 'c t d w° E> T 3 N c o L ; m c s aui 6 0~ E u m V A u N~ a V ti ~ N.~ R w C i 6 y L U m C cua p C D tad < o v° o p ~ c E ~ E s«u. fi~ D N ° T i. ~ 7 U> ~ 'aocv Z ::c Ogd~~ " `oE~ O 4. ~n U L O C ~ ~ C .C O 4= ~ Cam/ ~ C yW-i T ° u_ y aui ~ a°~i ~ v ~ v ' a .u5 S v o .N. $ o ~ o. ~ u ~ C u 3 > v p w° o s n OI c o c k E w E~ c h E ~ 4 o E x 7 ~ > c0 N Y N u~ ~ 3> ~ ca m° ~ u o u c v c u G PG E E aDVUO~m~, >svv~DCE'usotyo~ruv~ c mr Et E E'=- ~ 7 s`°',4.D g~.'auis ~ ~ ~ `OS¢ D y N y O~ VI A.W..-~ L N L N ~C V u r N t° C u y O O E E g~ r> E E m m N O c ~ u y m s m=- ~ fi v o f 's E c E e G .E .~.'C 'u d d v u u t°' u .u C c nt v O u 'd R j ~ F° E o `O' v~ y~ E~ o• ~ i~ a ~ ~ y E d~ a~ o° a 7 u o ssu. ~ r7j °u ~ > ro o sj ~ i > $ ~ v .°~..c v a u a a 3 a U I N vi O O O t N C N w T.C v ' ?.v ~ E L q ~ L u I m ro" y avi u u N~ F.y t > y td rn E- n ~ `0 3 a v° c~~ c u.°_ " s E c ,LV, w ~ O ~ v w 0 h N L O U t b b lC t L K q c t A p C ~ 'U T t ~ C N y y C L ~ i>y C U U ~ 0~0 y n o y F c ~ A a, ~ ~ N c ~ m u.. N L 0~~ U? O I.n y E IVl N y e G7 NL~ r u M N 'd q C~ 3 ri ~ r O r/1 Y E C C y V o 'p rv~ d v N 7 'p0 0 h O L v~ w N T T ¢N C N y a C d y N Cp u 00 Op '0~0 N~ ~ 4! ~ 00 O v N O O O L o c c~~ E ~,c,c a+~ u o m v > Nb t "v o. v v w O J C C i v> O v v CL„ v t 7 '7 7 y A y O ~i y L? ~ 'G t p v R N µa°Eo'a° W°'o v4."s~,'°~~°`o H~ F-~~~ W~~o iOro y L G) _ C> L N T C O C L N 'O p0 I ~ N- O ~ v. A o As Bey f-Fy~y Lu~;?cma~ Ee' ucat nNi ~ y O d CJ N 6 0 y A y I y ~ n '-V' L ~ ~ L tCC U y C T.. .0.. o N> Cent.°_.. a,, ,,q us Cu oouo- 'w=3t°o v ~ 9'~ 3 a >,.E N°r v ov 'O ? ~ o.° m ~ Ns° m `o ° v v L v r^ C7 N O CJ ? 7 u_ N ~ (y ~ u ~p v ~ v 0 ~ L R N w C y O.~ ~ N E O O ~ p C it in C> ,p ~ L 0 9 vi a 0 .d N O a0 E 6 0 O E L v p L 'v t.+ v 7' v m T N T N L K > r> E a, O O T v C ~ y t y ~ bn N N d'C s E C y O t~ id L A y y v > .N ~ T T.E y0 C~ DD Gr, v L N C On ~ i-~ - y 9 6 V C aN~;">c01 o~nc °~E~ ¢uEam'E'ocd. vAA3m_'_'d'._.N C= y.u o v~ ~ ~ E oLOun U us s o rov o L o 0.' o- L u u u E L U y .O L W> T ~ N CC fO QI ~ U V~~ 4J c` ~ d~ C ~v.. y '~C ~ •v+ .-I O v ctl C N etl w .L, A m y C. v OD cdd v N v u O itl ~d O ~ C ai O .y w .L., 'p ~ O j O ^y v ~ .O O y T~ ~ ~ . ~ ~ ~ A m eOa m m v ~ M m~°- •rd 3 n E aci e%~ t ~ o ~ N e%o c s a eo s e+~ E ~ > c y v 'o C s u. s u E~ e ~ h a'a e c E o s ao E o 'u° o .o o a f o s ~ v u F a~i .d L v.. O' K v ~ O s Y v 7 L ~ L L 7 C E ~ L O L F o u d N o E u c N VVV777 v a N F N o. s C o m ro~ E E n~ u s g b yO 7 w C ~ C v s 'O C s° C - p t iC h L 3 C 0 3 C y O > vi ° u o ~ u? ~ ~ L_ y Q~ H o 3 N o ai 7~ ° y c v O N E 00 v y U a d ~ ,Lv, b u N¢ ~ N° N w U d b O 7 ~ aci 'v- O 7 p L D d. ~ ~ C G U y V E• C C ,a ~ c m ~ c ~ d s ° W ~ °u N ~ ° :d ~ c > ~ E 3 r .c G T.i y ~ ~ W ~TUE~~s~3vvu O m~dm=,..ec..ON~'~, egESg e >~~~s°'.~m'.so°""°'vE .~OTLi~"'~~9m~EE~O~L~.ccd. L N .L+ _ O v « v y L O C O w iO iy V o y~ 3 N V o T 3 u e C V n 'v y 3 s u E ro eo v p E$ q i ~ U C t o~ G- 9~ t rvn v 000 v~ v~ v~ v N .fl y y •C p a~ O 'r n A v g c r, L ~ 0 3 m> ~ E ~ L~ s ~ 5° E u~ c ~ D m o ° c ~o ° o u o y G L " ° v 3 nn on s H~ 'E o o. E T'C °q a ~o c d s h ° ~ 'N O N C ~ o ~ o ° s° ¢ Z` E O Q 3 ~O °N' E a ~ ~ ~ _a ~ ^ e U O ~ C ~ ~ N N S O U 'v i~ A O v u> G r U v N' .v+ u T N N u N ~d .C ~ O N C ~ v G p, ° v qal E ie G v 7~ v p p 7 .E ~ A y° r H U 'y v_ o o. 5 .o ~ e ~ u A N~ y~ vC °u E'9 m'a G. N E E u_ 3 v y y E aui n v ~ ~ ~ o° cy T m~~ o "u u o s c° ^ a °o. ~y o ~ ~ o. K c » C N . ~ C ~ ~ ~ c ~ ' o U 7 ~ p, . °O- 'o v E s l o e .E y W v c n- o~ a e0 o E y ~ o y c A u° M o, " u " E ayi > v Ta u v s E o u v ° B N d s ep y H c~ C D a.~ ° L a v n ~ ~ c y o b o a f ~ s u 9~ v H C OA ~ U a y ~ v s v b N fL" ° ~ L N C ~ v 0~ is r v m N v s y E " o`. m a n" N~ 3 v .o ~ ie E E G.CS~d~3NF'V .v.y VUCVVi~~6TU'C G~ENCG•~>~NC Cj.yO 0 0 ~ - ~ m s ~ a ~ ~ ~ ~ ~ d ° s `3c ~ c E v o ~ ° ~ ~ ° E ~ U ' a`v ct'~sw o;a o W N ~ o E~~4- ~ °L v ~ u am o0u A d s N n o 0 m a> N ~ $ oq a a~ c ° C a W N ? T s w N N T u V w u_ m C i`tl y ~ C G rc a d~ ° ` c y N o u> $ m 3 ~ ~`a ~ L e' m ~ L °0'.: u~.~~~Ka ~yDaT e°'nsxm ENyac. o a`", u a .c° c s o s n a o w `o ~ o e v$ e f y .c I d s a~ os°, ~ a s <°e y. ~ ~ °o ~n u a 2 E v 3 v a y ~ o. u 0. o ~ m 3 ca q ° o ~ a ~ 4- ~O ~ w " N a$ d= c 3 s a u ~ u a N u u c E q' s ro aE o d v, y O y 0~ SO C T~~ G. y y T.~, y i p G1 N~ ,O b " vii ~ O .h L w o v s u~ E c. o c~~ ~ a'O ~ s ~ ~ .O 3 °o ° o c 9° v N~. a$ o v u v L u c ~ v 3 3 C .r ~ 'y is o~~ a ~'=9 ~ o ~ c° 3.5 °F':~o o` v'~'`.a ~ >'°$U for E o Ga T~ E C N y N n N 'E H~ T N G b N O L h o f K w ~ .y ~ E Q o. ~ ° ~ o. N ~ o n u ~ u c, 3 q c u ~ o ~ `Z' K y s o u c p, a w u~ o y~ s T m ~ U u c a , s i t s ~ e' o 'E ~ moo T N a m .o L c i v a v .e v ~ y~ F y o. r a u v fi t~ N .ter d~ ~ ,o a c .N d d o ~ 9 q ~ a ~ E a. W~ ti .Dp F a° ~ O O y~ C A L ~ 'N E U W~ N "T' C E O` U~ ~ p d c~tl h = ~ p, ~7 3 OC ~,o o cab `oJ o E 5 'y°~~.e"_o°a°'. EN'=a° L°'~s~,ea_o u o a .°1. E s c 'm n .y°c `o ~ ~i o a r E o a s •5 eiOi ao w ~ ~ i m 0 ~ ,D vi .E ~ F t C _ N lE r~ ro v ~p E" ~a o 0 o u a m ayi - 3 'S m e coi y o s e .p u t y `O 9 ,E ~ O~ N m N `a' c< ~ C .'T' u C y .u ~ 's pvC id N p D i~ '3 N ~ C C v N T.~ N~ y 0 .E 'O L y y T oJ0 y 'C O N v d ctl d T~ C vui u L E O LaV, u u> .u t N 7 a«~i N V O~~ O 'd ~ NP' O w a N N t V E G P ~ C O s U 'C ~ o~ r, o u e a m C a `o ~ t v°~~ m <v m°~~ o .u. ~ e 3 v u 4. ~ N da, ° P u u y 0 u T w A y u ~ a C .~L.. N ~ N 6 u N u V U ~ ~ O~ N C o r ~O ~O r h `c" $ $ e ? v d = $ = ~ 3 a o o ~ ° c m °c mL`"• E aci ~ ~ v U ° ~ w° dy ~ o a ~ a v v ro .°e r o. ~ ° y ~ r ~ E e E`a ~ ,c = ~ a s ~ u ,o s E u a .L. u is N a u S v c o T C s° v 5 ~ ~ .d y y a .o .N a m c m c ~ ~ o g $ ~ a A o y w i° ~ ~ ,o N ~ a v ~E ~ pp ~ v o ~o N ~o ~o O° E', L u O N. ~ O y O N d w T a a O E 'O 3 ~U 9 ~a+ N~ O~ N 9 C~ N ~ G U d a C v w N U U T C O N j, O t0 F a. p, A N A 7 G y O N~ O~ VI N U 'Y c_.a w3 ~ = Tw Aa u ~ c au v ° ~ ~ o o N ° u o. ~ ° o ~ E g. W y `c° w = m ~ h E ~ s ~ t u d ~ $ ~ " p ~ "u ~ ~ ~ cEa m ~ ° d v ~ ~ ~ u c"2 $ c " a an N ~ 3 d d u ~ ~ ~ ~ w 'E a ~ d E A $ v o ,u E ~ ai ~ ~ d y ro ~ F~ ~a ~ o~~ a, v u E~ o vm11 0 0 ` j o a u W ~ .°c° ~ E C k~~ C J W U U U C« O cO 0 u u T E v u N N 'V V 9C~y~ w .0 u vi N y W ~w.~~ w~~~3ya=usu~~w~,o6sH~„°'=vNyy~°T"°~~~~ i+i r a~i ~ n ~ Ii `o c ro Y o w c t `v A c t on u ~ ° E ~ 3 A °c ° « o. c o, `o w c u r p, ~ ai o T .5 ro u_ E a E ~ ~ o ~ $ rl C O O ~ G ~ C O N y .p d. N O t~ e.°. N~ Q M oDb C y U w OJ 3 G .E ~ 7P.+ w CO ~ y N N G E° t T ~ 6 G W s C«~ o 0o c E~° c u° c J 4. m~~ N 9~°~ U y o. N a w o E v o a 2 K$~ rh a ~ o°a c.o~3 °L o~ co ~s ht Y 4-2.6 REVISED ORDINANCES OF HONOLULU Sec. 42.6 Separability. It is the intention of the council that this article and every provision thereof shall be considered separable, and the invalidity of a~ section, clause, provision or part thereof, shall not affect the validity of a~ other portion of this article. (Sec. 42.4, R.O. 1978 (1983 F.d.); Am. Ord. 91-27) Article 3. Ottice of Council Services' Sections: 4-3.1 Ot6ce established. 43.2 Purpose. 433 Authority of the director o[ council services. 43.4 Director-Appointment, tenure, removal, compensation, vacancy. Sec. 4.3.1 Office established. The office of council services is established. (Sea 43.1, RO. 1978 (1983 Ed.)) Sec. 43.2 Purpose. The purpose of the office of council services shall be: (a) To provide a comprehensive research and referentx service for the council; (b) To conduM research, including legal research, as may be necessary for the enactment or consideration of legislation; (c) To sern in an advisory or a consultative capacity to the council and its committees on all matters within its competenaes and responsibilities; (d) To assist the council to carry out its responsibilities under Revised Garter Section 3-114: (1) To conduct an annual financial audit of all operations of the city and all operations for which the city is responsible and of then funds and accounts for each fiscal year, and (2) To conduct performance audits of any or all of the agencies and operations of the city and all operations for which the city is responsible; (e) To serve as special counsel to the council consistent with the provisions of the charter, (f) To serve as the revisor of ordinances pursuant to Chapter 1, Article 16; and (g) To perform such other duties as may be assigned by the council or by the presiding officer of the wuncil. (Sec. 43.2, R.O. 1978 (1983 Ed.); Am. Ord. 9452, 94-89) Sec. 433 Authority o[ the director of council services. The dvector of council services shall: (a) Have the same powers with respect to the personnel of the officx of council services as department heads of the executive branch, unless otherwise expressly limited by charter or ordinance. The attorneys in the office of council services shall be licensed to practice in Hawau and in good standing before the Supreme Court of the State of Hawaii. • Editor's Note: Salaries, Chap. 5, Art. 3, ROH 1990. APPENDIX V (HoaolWu 8-9'n 4-6 LEGISLATIVE AGENCIES 4-3.3 (b) Be authorized to administer oaths and, in the name of the council, subpoena witnesses and compel the production of books, papers, documents, records, and any government record as that term is defined in HRS Section 92F-3, relevant to a financial or performance audit authorized by the council. This authorization is granted to the director or a person duty designated by the director in exercise of the council's investigative power established in Revised Charter Section 3-120. (Added by Ord. 9452; Am. Ord. 9489) Sec. 43.4 Director-Appointment, tenure, removal, rnmpensation, vacancy. (a) The presiding officer of the council shall appoint, with the concurrence of the council, a director of the office of council services, who shall serve for a term of six years, and thereafter until a successor is appointed. The council, lry a two-thirds vote of its entire membership, may remove or suspend the director from office, but only for neglect of duty, misconduct, or disability. (b) If the office of the director becomes vacant, the deputy director shall become the acting director until a successor is duly appointed. (c) The salary of the duector shall be equal to that of the head of a department of the executive branch. (Added by Ord. 9489) Article 4. Legislative Hearings and Procedures Sections: 4ri.1 Purpose. 4.4.2 Definitions. 4-4.3 Establishment of investigating committces. 4-4.4 Finances and staff. 4~tS Membership-Quorum-Voting. 4-4.6 Hearings. 4-4.7 Issuance o[ snbpcenas. 4~.g Notice to vritnesses. 4-4.9 Conduct of hearing. 4-0.10 Right to rnunsel and submission o[ questions. 4.4.11 Testimony. 4-4.12 Interested persons. 4-4.13 Contempt. 4-4.14 Penalties. 4rt.15 Government officers and employees to cooperate. 4.4.16 Limitation. Sea 44.1 Parpose. The purpose of this article is to establish procedures governing legislative investigating committees to provide for the creation and operation of legislative investigating committees in a manner which will enable them to perform properly the powers and duties vested in them, including the conduct of hearings, in a fair and impartial manner, consistent with protection of the constitutional rights of persons called m testify at such hearings and preservation of the public good. (Sec. 44.1, R.O. 1978 (1983 Ed.)) Sea 4~.2 Definitions. As used in this article: "Hearing" means arty meeting in the course of an investigatory proceeding, other than a preliminary conference or interview at which no testimony is taken under oath, conducted by an investigating committee for the purpose of taking testimony or receiving other evidence. A hearing may be open to the public or closed to the public in conformance with HRS Section 92-5. 4-7 (Noeolulu 2-97) APPENDIX VI T _ N U_ N O 7 D a L O O ~p ~ ~ U U y- U Jw ~ y C C L 6 O J L N ~ N ~ N U C ~ y N~ N~ d t L L ; 0 0 H G~ a a L~ N C N LL maN NNC=L.. N- N T... 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