To View The Audit on Philadelphia Prison System FY 05 and 06
Transcription
To View The Audit on Philadelphia Prison System FY 05 and 06
OFFICE OF THE CONTROLLER CITY OF PHILADELPHIA PENNSYLVANIA PHILADELPHIA PRISON SYSTEM AUDITOR’S REPORT FISCAL YEARS 2006 and 2005 Alan Butkovitz City Controller INTRODUCTION September 28, 2007 Leon A. King II, Esquire Commissioner Philadelphia Prison System 7901 State Road Philadelphia, PA. 19136-3407 We have examined the financial affairs and operations of the Philadelphia Prison System for fiscal years 2006 and 2005 pursuant to the requirements of Section 6-400 (c) and (d) of the Philadelphia Home Rule Charter. A synopsis of the results of our work is provided in the executive summary to the report. We discussed our findings and recommendations with your staff at an exit conference and included your written response to our comments as part of the report. Our recommendations have been numbered to facilitate tracking and follow-up in subsequent years. We believe that, if implemented by management, these recommendations will improve internal controls and the effectiveness and efficiency of your department’s operations. We would like to express our thanks to you and your staff for the courtesy and cooperation displayed toward us during the conduct of our work. Very truly yours, ALAN BUTKOVITZ City Controller cc: Honorable John F. Street, Mayor Honorable Anna C. Verna, President and Honorable Members of City Council Members of the Mayor’s Cabinet PHILADELPHIA PRISON SYSTEM EXECUTIVE SUMMARY Why The Controller’s Office Conducted the Examination Pursuant to the requirements of Section 6-400 (c) and (d) of the Philadelphia Home Rule Charter, we examined the financial affairs of the Philadelphia Prison System (PPS) as part of our audit of the City of Philadelphia’s (City) basic financial statements. The focus of our examination was limited to determining if department management had suitably designed and placed in operation internal controls and complied with any laws and regulations related to its revenue and expenditure activity. What The Controller’s Office Found We noted that deficiencies continued to exist in the manner that PPS handles and accounts for revenues generated from coin operated lockers located at its various prison facilities for the convenience of visitors. Lockers have no counting devices that aid in verifying how much money should have been collected and deposited; each facility retains the money collected, in some instances, without an adequate accounting of the funds; and generally, each facility designates only one individual to collect the money, instead of more appropriately two. Other conditions requiring management’s attention at PPS include the following matters: • With respect to a private maintenance vendor at the Curran-Fromhold and the Riverside Correction Facilities, procedures for processing payments to the vendor, managing maintenance supplies, and handling scrapped assets need to be modified. In some instances, the procedures have weaknesses that place the PPS at high risk for incorrect payments to the vendor and/or for misappropriation of City assets. • PPS does not follow best-practice procedures that are considered appropriate for reducing the risk of errors that can occur when the payroll is prepared. Specifically, there are no spot-checks of data entry by reference to time clock cards or daily attendance sheets, and prior to distribution of paychecks, no one scans them for unusual amounts. • Annual employee performance evaluations are not always being prepared for PPS employees. Failure to prepare evaluations could have negative effects for both management and employees. PPS did take corrective action on a prior year finding involving bank deposits for its Custodial-Fund. As we previously suggested, management employed use of a signature log to establish a chain of custody for these deposits. What The Controller’s Office Recommends The Controller’s Office has developed a number of recommendations to address the findings. The recommendations can be found in the body of the report. CONTENTS Page INTRODUCTION BACKGROUND Overview .........................................................................................................................1 Prison Organization ...........................................................................................................1 Financial Resources ...........................................................................................................2 REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS ..........................................................3 FINDINGS AND RECOMMENDATIONS REPORTABLE CONDITIONS Revenues from Coin-Operated Lockers Are Still Handled Inappropriately......................5 OTHER CONDITIONS REQUIRING MANAGEMENT’S ATTENTION Improvements Needed For Better Accountability over Prison Maintenance Costs .......... 6 Key Procedures to Ensure Payroll Accuracy Are Not Performed .....................................9 Annual Employee Evaluations Are Not Always Prepared ................................................9 CORRECTIVE ACTION TAKEN ON PRIOR YEAR FINDINGS Audit Trail to Establish Custody of Custodial Fund Deposits Is Now In Place .......................................................................................................................10 APPENDIX I: PHILADELPHIA PRISON SYSTEM ORANIZATION CHART ...........11 AGENCY RESPONSE Leon A. King II, Esquire, Commissioner ..................................................................12 INTRODUCTION BACKGROUND Overview The Philadelphia Prison System (PPS) was established as a separate department under the managing director by Executive Order 5-88 (April 6, 1988).1 Its reported mission is to provide a secure correctional environment that adequately detains persons accused or convicted of illegal acts; to provide programs, services, and supervision in a safe, lawful, clean, humane environment; and to prepare incarcerated persons for reentry into society. The PPS operates five major correctional facilities — the Curran-Fromhold Correctional Facility, the Detention Center, the House of Corrections, Philadelphia Industrial Correctional Center, and the Riverside Correctional Facility2 — on State Road in Northeast Philadelphia, as well as several smaller Alternative and Special Detention facilities in various locations of the City. Each of the prison facilities is under the immediate direction of a warden, who is assisted by one or more deputy wardens and support staff. Prison Organization The commissioner of the PPS, as executive director of the entire prison system, has responsibility for fiscal control; for overall supervision of operations and coordination of activities; for planning, development, and execution of policy; for administrative studies and reviews; and for interaction with City and other government officials, the community, and public and private agencies. The commissioner reports to the City’s managing director, who appoints the commissioner, and a seven-member Board of Trustees whose members include the commissioner of the City’s Department of Human Services (ex officio) and six citizens appointed by the mayor. As chief executive officer of the PPS, the commissioner has the assistance of four deputy commissioners, a human resources manager, an administrative services director, a contract administrator, and an information technology development group. Each of the deputy commissioners has responsibility for one of four different areas — Policy Training and Special Services; Administration, Operations, and Treatment. During the fiscal years under audit, the PPS employed approximately 2,200 employees, most of which were appointed through the civil service system. A complete organization chart of the PPS is presented in Appendix I. 1 Prior to April 1988, the PPS had been under the direction of the Department of Human Services (formerly, the Department of Public Welfare). 2 The Riverside Correctional Facility is also known as the Women’s Correctional Facility. 1 INTRODUCTION Financial Resources Management has responsibility for establishing and maintaining controls to safeguard the financial resources for which it is accountable. Safeguarding controls are designed to (1) prevent or timely detect unauthorized acquisition, use, or disposition of assets, (2) ensure the reliability of financial reporting and (3) to ensure compliance with applicable laws and regulations. During fiscal years 2006 and 2005, management of the PPS was accountable for the following appropriations, budgeted revenues, and assets: Fiscal Year Appropriations: 2006 Operating funds Capital funds Total Appropriations 2005 $ 186,663,381 7,980,000 $ 194,643,381 $ 179,975,799 11,165,000 $ 191,140,799 $ 600,000 2,375,000 $ 2,975,000 $ $ $ Budgeted Revenues Locally generated non-tax revenue Revenue from other governments Total Budgeted Revenues 600,000 5,285,000 5,885,000 $ Reported Assets (June 30) Petty cash funds Materials and supplies inventory Personal property inventory Fiduciary funds: Prison Custodial Fund Prison Industries Fund Prison Inmate Welfare Fund Total Reported Assets 19,000 1,524,949 7,659,707 1,719,852 955,178 1,228,116 $13,106,802 2 19,000 1,572,819 7,027,306 1,579,042 1,035,769 1,101,930 $12,335,866 REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON COMPLIANCE AND OTHER MATTERS We annually audit the basic financial statements of the City of Philadelphia, Pennsylvania as of and for its June 30 fiscal year end and issue a report thereon. Those statements include financial transactions of various city departments and agencies. We conduct our audit in accordance with auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States. Internal Control Over Financial Reporting In planning and performing our audit, we consider the City of Philadelphia’s centralized and departmental internal controls over financial reporting in order to determine our auditing procedures for the purpose of expressing our opinions on the basic financial statements and not to provide an opinion on the internal control over financial reporting. Our consideration of the Philadelphia Prison System’s (PPS) internal control over financial reporting was limited to determining if its internal control components for revenue, payroll, and other expenditure activity were suitably designed and placed in operation during fiscal years 2006 and 2005. Our work identified that revenues generated from coin operated lockers at the PPS are not being controlled to ensure all amounts received are being appropriately accounted for by PPS employees. We consider this condition to be reportable. Reportable conditions involve matters coming to our attention relating to significant deficiencies in the design or operation of the internal control over financial reporting that, in our judgment, could adversely affect the PPS’ ability to initiate, record, process, and report financial data consistent with the assertions of management in the financial statements. This reportable condition is more fully described in the accompanying findings and recommendations section of the report. 3 www.philadelphiacontroller.org C I T Y O F OFFICE P H I L A D E L P H I A OF THE CONTROLLER A material weakness is a reportable condition in which the design or operation of one or more of the PPS internal control components does not reduce to a relatively low level the risk that misstatements caused by errors or fraud in amounts that would be material in relation to the financial statements being audited may occur and not be detected within a timely period by employees in the normal course of performing their assigned functions. Our consideration of the PPS initial control over financial reporting would not necessarily disclose all matters in the internal control that might be reportable conditions and, accordingly, would not necessarily disclose all reportable conditions that are also considered to be material weaknesses. However, we do not believe that the reportable condition described above is a material weakness. Compliance and Other Matters As part of obtaining reasonable assurance about whether the City of Philadelphia’s basic financial statements are free of material misstatement, we perform centralized and departmental tests of compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the determination of financial statement amounts. However, providing an opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not express such an opinion. Our consideration of the PPS’ compliance with certain provisions of laws, regulations and contracts was limited to tests of revenue, payroll, and other expenditure activity during fiscal years 2006 and 2005. Grant compliance was tested and reported on as part of our single audit in accordance with Office of Management and Budget Circular A-133. Our departmental tests disclosed no material instances of noncompliance or other matters by the PPS that are required to be reported under Government Auditing Standards. However, we noted certain other conditions that are not required to be reported under Government Auditing Standards, but nonetheless represent deficiencies in internal control over financial reporting, and/or economy or effectiveness issues that should be addressed by management. These conditions are listed in the table of contents and included in the findings and recommendations section of the report. This report is intended solely for the information and use of the management of the City of Philadelphia, the PPS, and City Council and is not intended to be and should not be used by anyone other than these specified parties. October 31, 2006 ALBERT F. SCAPEROTTO, CPA Deputy City Controller 4 FINDINGS AND RECOMMENDATIONS REPORTABLE CONDITIONS Revenues from Coin-Operated Lockers Are Still Handled Inappropriately In our prior report, we disclosed that PPS management permitted deviation from established City procedures in the control of an estimated $35,000 in yearly revenues earned from coin operated lockers installed at five of the inmate facilities. We reported that wardens at each of the facilities had total discretion on how money collected from the lockers was used. Most importantly, however, we reported that there was poor accountability over the funds, making it easy to perpetrate irregularities. We observed, for instance, that: lockers had no counting devices, which would be useful in determining how many coins should have been collected and deposited; money collected from the lockers was retained by each facility, some of which did not maintain an adequate accounting of the funds; and at each PPS facility, there was generally only one individual given responsibility for collecting the coins from the lockers instead of more appropriately two. We also learned and reported that sometimes the individuals responsible for collecting the coin first deposited the money into a personal bank account before subsequently withdrawing and submitting the purported collected amounts to the wardens. Our current review disclosed that the PPS had made little improvement in the way it handled money collected from the coin-operated lockers. Although PPS managers advised us that they had applied to Finance for a specific sub-object code in which to account for the funds in the City’s accounting system, through the end of our fieldwork nothing further had changed. Recommendations: We continue to believe that there needs to be more control and accountability over revenue amounts generated from the PPS lockers, as well as how the money is being used. In our opinion, amounts collected need to be deposited and accounted for through the City’s Department of Revenue, in accordance with Finance Office Standard Accounting Procedure (SAP) E-4281. We suggest that since PPS has already applied to the City’s Finance Office for a specific sub-object code to account for the funds, it follow the process to finality. We also continue to encourage PPS management to formally design, adopt, and follow procedures that will better ensure an accurate and complete accounting over locker revenues. Some of the more significant procedures that we recommend include the following: • • • Collecting locker coin revenues using a two-person team and a lock bag for each facility; Delivering bags of coins, for counting and deposit, to a branch location of the City’s authorized bank; Obtaining a validated deposit slip from the bank, which should then be affixed to a standard Revenue Department “Deposit Summary” and taken to the cashier operations (located in Municipal Services Building) for validation and data entry into the City’s accounting system; and 5 FINDINGS AND RECOMMENDATIONS • At a subsequent date, reviewing the City’s accounting system to ensure the amounts deposited with the bank and validated by the Revenue Department have been accurately recorded [12303.01]. OTHER CONDITIONS REQUIRING MANAGEMENT’S ATTENTION Improvements Needed For Better Accountability over Prison Maintenance Costs PPS management should consider some changes that will improve accountability over City resources associated with maintenance services performed by a private vendor at the CurranFromhold and the Riverside Correction Facilities.3 Our work suggests that changes are needed in three key areas — the processing of monthly vendor invoices for maintenance supplies and services; the managing of maintenance supplies inventory; and the handling of scrapped assets removed from various maintenance-related projects. In our opinion, procedural weaknesses we identified in each of these three areas, as discussed in the sections that follow, can place the PPS at higher risk for incorrect payments and for misappropriation of City assets. Processing Monthly Maintenance Invoices Before approving vendor invoices for payment, City agencies need to perform three major tasks: they need to compare the invoice to the underlying documentation; they must check the invoice and underlying documentation for mathematical accuracy; and they should verify that the goods and or services have actually been received. All of these procedures are necessary to minimize the risk of incorrectly paying vendors. Our observations and limited testing4 of procedures for processing payments to the maintenance vendor suggest that PPS does appear to be performing most of the three major tasks outlined in the above preceding paragraph. For instance, we saw evidence that the clerk checking the vendor’s invoice thoroughly examines the underlying supporting documentation, comparing the documentation to purchase orders and contract terms. The clerk also appears to be checking vendor invoices and supporting documentation for mathematical correctness and verifying that the goods and/or services had been received by examining receiving reports. If the vendor work involves something capital in nature, the employee checking the invoice will request assistance from the point person at the prisons who has operational oversight for the contract. That individual will then physically inspect the work and provide approval. 3 On June 12, 2001, the PPS entered into a multi-million dollar contract with a private vendor engaged to perform services and provide materials necessary to maintain the Curran-Fromhold and the Riverside Correction Facilities. These services and the related materials pertain to preventive and unscheduled maintenance, as well as alterations to a variety of systems, such as electrical, drainage, fire suppression, and electronic security at each of the two facilities. Maintenance services include painting, carpentry, waste removal and disposal, pest control, water treatment for the mechanical cooling and heating systems, lighting, and signage. The vendor has also been engaged for architectural and structural maintenance, as well as for engineering services. From inception of the contract through June 30, 2005, the PPS paid the vendor nearly $16 million. The contract continues to be renewed, even currently. 4 We examined eight transactions, five that we randomly drew; and three, involving monthly maintenance services, which we judgmentally selected. 6 FINDINGS AND RECOMMENDATIONS However, we observed weaknesses that occur in procedures when the invoices submitted to PPS for payments involve charges for vendor-employee work hours and/or certain supplies. For instance, as to the work hours, we noticed that while the clerk makes sure hourly rates charged by the vendor agree with the contract terms, there is no corroboration of the hours billed. The vendor does not submit employee daily attendance sheets or time clock cards, and the clerk does not subsequently request copies of such corroborative documentation. Consequently, the PPS places itself at risk for not detecting errors or irregularities in the employee hours being billed. With respect to supplies, we became aware of instances when these were billed to the PPS, but could not be linked to a work order for a specific maintenance project, or to an item normally carried in the supply inventory. By way of example, on two occasions, we noted that certain reflective tape was purchased by the vendor and then subsequently billed to the PPS. When we asked the clerk who had processed the invoice to link the tape to a particular work order or supply item routinely carried as inventory, she was unable to do so. We were told supervisory personnel of the vendor were permitted to order supplies that were not associated with a specific work order or carried in the inventory, if, in their judgment, the item was necessary for some miscellaneous task. As long as the item did not appear “too out-of-the-ordinary” or strictly forbidden under terms of the contract, the clerk would allow it. In our opinion, however, allowing the above-mentioned practice increases the risk of improprieties. For example, the vendor’s supervisor could purchase items for personal use and later present them for payment to PPS. Since the vendor’s invoices to the PPS are frequently voluminous, the clerk reviewing it might easily overlook an inappropriate item, or conclude that an item being charged is reasonably acceptable when in fact it is not. Managing Maintenance Supplies Inventory As part of its contract with the PPS, the vendor handling maintenance at the CurranFromhold and the Riverside Correction Facilities keeps an inventory of various supplies used in its work at the two facilities. The supplies have been purchased with City money and therefore actually belong to the PPS. Our site visit to the facility housing the supplies revealed a fairly large warehouse fully stocked with items ranging from cleaning solvents to plumbing, electrical and building materials. Despite the extensive size of the inventory — about $876,000 according to the PPS — we learned that the value of this inventory is not being reported to the Finance Director for inclusion in the City’s Comprehensive Annual Financial Report. Moreover, the PPS does not adequately oversee the inventory — by way of reviewing reports on inventory utilization, for example, or conducting periodic physical inventories of the supplies on hand as required by the Philadelphia Home Rule Charter.5 Failure to adequately oversee and monitor this inventory raises the level of risk for improprieties. 5 See Section 6-102 of the Home Rule Charter. 7 FINDINGS AND RECOMMENDATIONS Handling of Scrapped Assets City agencies that have assets to be scrapped are required to follow the City Procurement Department’s Directive #67 when disposing of such assets. The directive requires that agencies notify the Procurement Department in a memorandum of the nature and location of the item(s) to be scrapped, the condition of the item(s), along with a contact person and a telephone number. Although Directive #67 is an official City policy, to which agencies must adhere, the PPS has not developed internal procedures to ensure that the policy is always followed, especially at the Curran-Fromhold and the Riverside Correction Facilities where assets to be scrapped may occur during routine maintenance or major renovation work handled by the private vendor. Indeed, the Controller’s Office has received anonymous allegations that the vendor’s employees have removed discarded assets such as shower doors and aluminum light fixtures from the inventory warehouse and sold them privately to scrap dealers. Our review of the PPS contract with the vendor disclosed that it is silent on the topic of items removed from a project site. Additionally, inquiries of both the vendor’s employees, as well as those of the PPS, disclosed that there appears to be a breakdown in communication regarding how to handle the disposal of assets removed from prison property. On a visit to the warehouse holding the maintenance supplies inventory, for example, we observed numerous televisions that had been removed from the Curran-Fromhold facility because they were replaced with newer models. Inquiries of the vendor’s employees revealed that they were awaiting word from PPS personnel as to what to do with the televisions. Our discussion with the PPS employee responsible for coordinating the disposal of scrapped assets with the City’s Procurement Department revealed she was unaware that the televisions sat in the warehouse. In fact, she told us that unless someone contacts her about the removal of such items, she has no way of knowing and, consequently, does not notify the Procurement Department as required by Directive #67. When asked if she had been notified of the removal of the shower doors or aluminum light fixtures, she responded no. Because of higher audit priorities, we did not confirm the allegations regarding the shower doors and aluminum light fixtures as described earlier. However, in our opinion, based on inquiries and observations we made during this review, the risk of such scenarios is quite possible due to the apparent failure of PPS management to design and implement procedures to ensure compliance with the Procurement Department‘s Directive #67. Recommendations: To improve oversight of the outsourced contract for maintenance work at the PPS, we recommend that management take the following steps: • Request that that vendor include corroborative documentation to support the labor hours charged on periodic invoices for labor costs. Such documentation should include daily attendance sheets or time clock cards. The PPS clerk responsible for checking these invoices should (at least on a test basis) compare the hours billed to these time records, and as always, the review should be documented [12305.01]. 8 FINDINGS AND RECOMMENDATIONS • Require that the vendor link purchased supplies to either a maintenance work-order or to a commodity regularly carried in the supplies inventory. In those instances when this cannot be done, the vendor should be directed to supply adequate explanation to justify the purchase. [12305.02]. • Require that periodic physical inventories be taken of supplies purchased through the contract and report the fiscal year-end balances to the City’s Procurement Department for inclusion in the annual financial report. Preferably, the physical inventories should be taken by PPS personnel [12305.03]. • Require the vendor to provide management reports showing inventory usage by commodity. PPS management should, in turn, review these reports for abnormal utilization of supplies [12305.04]. • Design and place into operation procedures to ensure compliance with the Procurement Department’s Directive #67 dealing with the disposal of City assets [12305.05]. Key Procedures To Ensure Payroll Accuracy Are Not Performed The PPS has not placed in operation best-practice procedures normally considered appropriate for reducing the risk of errors that can occur when payroll clerks prepare the payroll. More specifically, no one independent of the payroll preparation process at PPS periodically spot-checks — by reference to time clock cards or daily attendance sheets — the accuracy of data entry of employee work time into the payroll system. Additionally, the PPS does not require that, prior to distribution of its paychecks, someone scan them for unusual amounts. Although we did not find any discrepancies when we reviewed payroll transactions, our testing was very limited. Because of the numerous prison employees and the variety of working schedules, which involve special pay rates —such as shift differential and overtime rates — we believe that the PPS is at a higher risk for errors occurring in its payroll, and therefore needs to implement procedures designed to mitigate this risk. Recommendations: To lessen the chance of failing to detect errors that might occur during preparation of the payroll, we encourage PPS management to require that someone, independent of payroll preparation, spot-check data entry of employee work time by reference to time clock cards or other attendance records [12305.06]. Additionally, we recommend that management adopt the practice of having someone scan the bi-weekly payroll registers for unusual amounts [12305.07]. Lastly, we suggest that individuals charged with performing any of these procedures, in some manner, document that they have done them. Such documentation, for instance, might consist of initialing and dating the clock cards or attendance records that have been checked for data-entry accuracy, or keeping a log of signatures and dates showing who performed the scan of payroll checks and when it was done [12305.08]. Annual Employee Evaluations Are Not Always Prepared Civil Service Regulation 23.033 requires that annual performance evaluations be prepared for all permanent civil service employees. For three of six employees we randomly sampled (50 percent), current annual performance evaluations were not prepared. For one of the selections, 9 FINDINGS AND RECOMMENDATIONS the most current performance evaluation for the employee was dated in August 2001. The other two evaluations were more recent, both having been prepared in August 2003. Failure to complete performance reports, as required, deprives employees of the opportunity to review and discuss their strengths and weaknesses in a timely fashion with supervisors. It could penalize employees who may be entitled to performance bonus points on promotional tests. Further, as an integral part of the City’s progressive discipline system, not having up-to-date performance reports could weaken management’s position when dealing with poorly performing employees. Recommendation: To comply with Civil Service Regulations and to ensure proper human-resource management, we recommend that PPS prepare annual performance evaluations for all its civil service employees [12305.09]. CORRECTIVE ACTION TAKEN ON PRIOR YEAR FINDINGS As part of our work for this auditor’s report, we followed up on conditions brought to management’s attention in our last report. We routinely monitor uncorrected conditions and report on them until management takes corrective action or until changes occur that resolve our recommendations. Our follow-up has disclosed that PPS had taken corrective action in the area discussed below, and we would like to acknowledge their efforts. The corrective action taken by management has strengthened PPS’ internal controls and improved accountability over its assets. We commend PPS on its efforts. Audit Trail to Establish Custody of Custodial Fund Deposits Is Now In Place In our prior year report, we commented about how corrections officers who picked up sealed deposit bags from the cashiers did not sign a log stating that they had received the bags from the cashiers. We advised PPS management that by failing to keep such a log, accountability over the deposits was not fixed. Consequently, if deposits became missing, the PPS would not have documentation acknowledging who had last custody of the funds. To improve this situation, we recommended that PPS management employ use of a signature log to serve as an audit trail and document the transfer of money between cashiers and the corrections officers who are responsible for transporting deposits to the bank. During our current work, we observed that PPS management had established a written policy for handling custodial fund deposits and had instituted a signature log as we suggested [12303.02]. 10 APPENDIX I 11 RESPONSE TO AUDITOR’S REPORT 12 RESPONSE TO AUDITOR’S REPORT 13