Department of Public Safety and Correctional Services Division of Parole and Probation Supervision Fee Collection Rates

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1 Performance Audit Report Department of Public Safety and Correctional Services Division of Parole and Probation Supervision Fee Collection Rates Supervision Fee Collection Rates For Certain Types of Cases Ranged from 16.2 Percent to 63.9 Percent Over a Three-Year Period November 2005 OFFICE OF LEGISLATIVE AUDITS DEPARTMENT OF LEGISLATIVE SERVICES MARYLAND GENERAL ASSEMBLY

2 This report and any related follow-up correspondence are available to the public through the Office of Legislative Audits at 301West Preston Street, Room 1202, Baltimore, Maryland The Office may be contacted by telephone at , , or Electronic copies of our audit reports can be viewed or downloaded from our website at Alternative formats may be requested through the Maryland Relay Service at The Department of Legislative Services Office of the Executive Director, 90 State Circle, Annapolis, Maryland can also assist you in obtaining copies of our reports and related correspondence. The Department may be contacted by telephone at or

3 November 21, 2005 Delegate Charles E. Barkley, Co-Chair, Joint Audit Committee Senator Nathaniel J. McFadden, Co-Chair, Joint Audit Committee Members of Joint Audit Committee Annapolis, Maryland Ladies and Gentlemen: We conducted a performance audit to examine the Department of Public Safety and Correctional Services (DPSCS) Division of Parole and Probation s (DPP) supervision fee collection rates. The purpose was to determine the supervision fee collection rates for parolees, probationers, and Drinking Driver Monitor Program participants during the three-year period ending June 30, We conducted this audit in response to a request made in April 2005 by the Chairmen of the Senate Budget and Taxation Committee and the House Committee on Appropriations. We were advised by legislative staff that this information was requested because DPP planned to rely on an increase in one type of fees that is, probationer supervision fees to fund increased costs for certain agency operations. Specifically, DPP projected that, assuming a 50 percent collection rate, collections for probationer supervision fees would increase by $1.3 million annually if the monthly fee was increased by $15. Our audit disclosed that the average supervision fee collection rates for parolees, probationers, and Drinking Driver Monitor Program participants during this threeyear period were 16.2 percent, 33.5 percent, and 63.9 percent, respectively. Moreover, DPP s projected collection rate of 50 percent for probationer supervision fees greatly exceeded our calculated rate of 33.5 percent. A flawed estimation methodology was used to calculate the probationer supervision fee collection rate of 50 percent. For example, even though DPP was estimating the collection rate for probationer supervision fees only, the rate was based on data from three types of open cases (probation, parole, and mandatory supervision cases). In addition, DPP used actual fee collections from both open and closed cases. In contrast, we used data from only closed cases, which provides a more meaningful measure of ultimate collectibility by capturing historical data over the life of each case.

4 The objective, scope, and methodology of the audit are explained on page 9. We wish to acknowledge the cooperation extended to us during our audit by DPP and DPSCS staff. Respectfully submitted, Bruce A. Myers, CPA Legislative Auditor 2

5 Table of Contents Background Information 5 Audit Scope, Objective, and Methodology 9 Findings and Recommendations 11 Finding 1 Actual Supervision Fee Collection Rates Ranged From Percent to 63.9 Percent Finding 2 OBSCIS Was Not Programmed to Produce Reports of 13 Supervision Fees Assessed With the Related Amounts Collected to Identify the Related Collection Rates Exhibit A Excerpt From Department of Legislative Services Analysis 14 of the Fiscal Year 2006 Executive Budget Exhibit B Excerpt From Division of Parole and Probation s Response 15 to the Department s Analysis of the Fiscal Year 2006 Executive Budget Agency Response Appendix 3

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7 Background Information Overview The Department of Public Safety and Correctional Services Division of Parole and Probation (DPP) provides supervision and investigation services related to criminal offenders. Specifically, DPP supervises the conduct of parolees and regularly informs the Maryland Parole Commission of parolee 1 activities. DPP also conducts investigations for the Commission, and performs probationary 2 services for the Circuit and District Courts of Maryland. When requested by the Governor, DPP conducts investigations of persons who have applied for pardon, commutation of sentences, or clemency. Furthermore, DPP administers the Drinking Driver Monitor Program (DDMP), a specialized supervision service for individuals convicted of driving while intoxicated or driving under the influence of alcohol. Finally, DPP is responsible for the collection and disbursement of fines, costs, fees, and restitution funds assessed in certain criminal cases. DPP headquarters is located in Baltimore, Maryland, with four regional offices located in Baltimore, Upper Marlboro, Easton, and Frederick. The regional offices monitor and supervise the operations of 48 field offices. According to DPP records, as of June 30, 2005, there were 112,250 parole, mandatory supervision, and probation cases under its jurisdiction. DPP headquarters collects court-imposed victim restitution payments, fines, costs and fees. Periodically, these collections are distributed or transferred to the proper parties, such as crime victims or the courts. DPP field office personnel record the court-imposed restitution, fines, costs, and fees and the related collections and distributions on the Department s Offender Based State Correctional Information System (OBSCIS). According to DPP s records, during fiscal year 2004, these collections and disbursements, which were processed as non-budgeted funds, totaled approximately $15.8 million and $16 million, respectively. Supervision Fees Supervision fees are imposed by the courts and deposited to the State s General Fund. Under guidelines established January 1, 1992 by the Chief Judge of the Maryland Court of Appeals, any collections received from an offender by DPP, on behalf of victims and the courts, must be accounted for and disbursed in the following order: 1 Parole refers to conditional release from confinement granted by the Maryland Parole Commission. 2 Probation refers to a disposition under which a court in lieu of or in addition to the sentence provided by law prescribes terms and rules for a defendant while not incarcerated. 5

8 1. Restitution 2. Fines 3. Court costs 4. Public Defender costs 5. Restitution collection fees 6. Supervision fees As noted above, supervision fees in a criminal supervision or DDMP supervision case are the last ones to be collected and disbursed. Each offender enrolls in a payment plan to pay any levied restitution, fines, costs, and fees through the duration of the subsequent supervision period, which may last several years. As a result of the judicially-determined priority ranking, supervision fees are usually collected toward the end of the supervision period, if at all, after other payment obligations are met. Also, assessed supervision fees are often reduced as offenders may receive exemptions or waivers from the courts or the Maryland Parole Commission. Audit Issue We were requested by the Chairmen of the Senate Budget and Taxation Committee and the House Committee on Appropriations to determine the supervision fee collection rates for parolees, probationers, and Drinking Driver Monitor Program participants during the three-year period ending June 30, The basis for this audit was DPP s assertion that a $15 increase (from $25 to $40) in monthly probationers supervision fees, coupled with an estimated 50 percent collection rate on imposed fees, would result in an annual increase in General Fund revenue of $1.3 million. During its analysis of the fiscal year 2006 DPP budget request, the Department of Legislative Services (DLS) questioned the reliability of the estimated 50 percent rate and an audit of actual past rates was requested (see Exhibit A). In its written response to the DLS analysis (see Exhibit B), addressed to the Chairman of the Senate Subcommittee on Public Safety, Transportation, and the Environment, DPP provided background on the fee collection issue and described the methodology used to estimate the increased collections. 6

9 Briefly, DPP arrived at the estimated $1.3 million in increased annual collections using the following methodology: 1. DPP determined that, annually, approximately 40,000 offenders were under probation at any given time (active cases). 2. DPP assumed that 36.4 percent, or 14,560 (40,000 x 36.4%), of those active cases would have had a supervision fee ultimately imposed (after considering waivers and exemptions). 3. Then $15 monthly fee increase was then applied to the 14,560 offenders to arrive at annual increase in revenue of $2,620,800 (14,560 x $15 x 12). 4. DPP applied the estimated 50 percent collection rate to fees subject to collection to arrive at $1,310,400 ($2,620,800 x 50%). There were a number of approximations used and assumptions made by DPP in this methodology, including the decision to use active cases as the baseline to build the collection model and the decision to use a 50 percent collection rate. 7

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11 Audit Scope, Objective, and Methodology Scope We conducted a performance audit to determine the Division of Parole and Probation (DPP) collection rates for supervision fees for parolees, probationers, and participants of the Drinking Driver Monitor Program (DDMP). This audit was conducted in response to a request made in April 2005 by the Chairmen of the Senate Budget and Taxation Committee and the House Committee on Appropriations. We conducted the audit under the authority of the State Government Article, Section of the Annotated Code of Maryland and performed it in accordance with generally accepted government auditing standards. Objective The objective of this audit was to determine DPP s collection rates for supervision fees for parolees, probationers, and DDMP participants for the three-year period ending June 30, Methodology To accomplish our objective, we reviewed applicable State laws and regulations as well as policies issued by DPP. We also interviewed DPP and DPSCS personnel responsible for the maintenance of the Offender Based State Correctional Information System (OBSCIS), where case and fee collection data reside. In addition, we analyzed reports (including those generated by DPP) and data files of supervision fees for active and closed cases during fiscal years 2002 through 2004 as reported in OBSCIS. Early in our audit fieldwork, it became apparent that it was not possible to reliably calculate a historically accurate collection rate for active cases. For example, active cases often remain open for several years, and supervision fees are collected toward the end of the supervision period. Accordingly, we limited our examination to the historical collection activity during the lifetime of any case closed during the three years of our audit period. This was deemed by us and by DPP management to provide a more meaningful measure of collectibility than using the activity of open cases, as was the approach used by DPP in its calculation. We also reviewed DPP policies and procedures for recording collections of supervision fees, reviewed controls over OBSCIS data entry procedures, and performed tests to determine the reliability of OBSCIS data deemed relevant to our objective. Finally, DPP refers all appropriate unpaid fines, costs and fees to 9

12 the Department of Budget and Management s Central Collection Unit (CCU) for collection assistance as directed by the courts and the Maryland Parole Commission. Consequently, we reviewed the account transfer and collection process with DPP and CCU officials and included CCU recoveries in the collection rates. Fieldwork and Agency Responses We conducted our fieldwork from July to September The Department of Public Safety and Correctional Services response to our findings and recommendations, on behalf of DPP, is included as an appendix to this report. As prescribed in the State Government Article, Section of the Annotated Code of Maryland, we will advise the Department regarding the results of our review of their response. 10

13 Findings and Recommendations Supervision Fee Collection Rates Conclusion Our audit disclosed that the average supervision fee collection rates for closed cases for parolees, probationers, and Drinking Driver Monitor Program participants were 16.2 percent, 33.5 percent, and 63.9 percent, respectively, for the three-year period ending June 30, Moreover, DPP s estimated probationer supervision fee rate of 50 percent, which was presented during the 2005 budget hearings (see Exhibit A), was significantly higher than the actual historical collection rate of 33.5 percent. Furthermore, we found that, although historical collection data for supervision fees existed in OBSCIS (the database used to record case information), there were no OBSCIS reports produced with sufficient specificity for use in determining fee collection rates. Accordingly, DPP had no mechanism to readily determine the supervision fee collection rates. Supervision Fee Collections Finding 1 Actual historical collection rates for supervision fees from parole, probation, and Drinking Driver Monitor Program cases closed during the three-year period ending June 30, 2004 ranged from 16.2 percent to 63.9 percent. Analysis Our audit indicated that the individual rates ranged from a low of 16.2 percent for parolees to a high of 63.9 percent for DDMP participants, including a collection rate of 33.5 percent for probationer supervision fees. In Table 1, we present the results of our analysis of DPP data to determine the collection rates of supervision fees for the three requested case types: parolees, probationers, and participants in the Drinking Driver Monitor Program (DDMP). The collection rates were determined using data from all cases closed during fiscal years 2002 through

14 Table 1 Supervision Fee Collection Rates For Cases Closed During Fiscal Years Case Type Number of Cases Closed during 3-year period Fees Imposed (less waivers and exemptions) Fees Collected (during life of case) Outstanding Balance Subject to Collection OLA Calculated Collection Rate Parole 6,296 $ 5,556,420 $ 897,898 $ 4,658, % Probation 26,537 13,264,638 4,446,983 8,817, % Drinking Driver Monitor Program 15,693 6,806,411 4,348,888 2,457, % Totals 48,526 $25,627,469 $9,693,769 $15,933, % Mandatory Supervision 12,344 $ 7,472,271 $1,232,354 $ 6,239, % Source: OLA analysis of case data from the Offender Based State Correctional Information System These amounts include any collections of supervision fees by the Central Collection Unit through July 2005 on closed cases. Although not requested by the Committees, we included the supervision fee collection rate for mandatory supervision. Mandatory supervision is a fourth case type, with a $40 supervision fee that is collected by DPP. Mandatory supervision is a nondiscretionary release from incarceration required by law after a criminal offender has served his or her sentence less diminution for confinement credits earned. DPP used a flawed estimation methodology to calculate its probationer supervision fee collection rate of 50 percent, as described in Exhibit B. For example, even though DPP was estimating the collection rate for probationer supervision fees only, the rate was based on data from three case types (probation, parole and mandatory supervision cases). In addition, DPP used actual fee collections from both open and closed cases. Using data from closed cases, as we did, produces a more meaningful rate by accounting for all known historical collections during the lifespan of those cases, regardless of collection timeframe and source. It was not an objective of this audit to recalculate or otherwise verify DPP s assertion that an increase in the monthly probationer supervision fee from $25 to $40 would generate $1.3 million in additional annual revenue. Accordingly, we 12

15 did not provide a revision to that estimate, nor did we attempt to validate other assumptions made by DPP that influenced its estimate, such as the annual number of new cases and the percentage of cases that would ultimately have a supervision fee imposed. Recommendation 1 To improve the accuracy of supervision fee collection rates, we recommend that DPP reevaluate its estimation methodology, and base future calculations on data from closed cases that are applicable to the specific rate being calculated. Finding 2 OBSCIS was not programmed to produce reports of supervision fees assessed with the related amounts collected to allow DPP management to identify the collection rates. Analysis Although historical collection data for supervision fees existed in OBSCIS, that database was not programmed to produce reports of supervision fees assessed with the related amounts collected to allow DPP management to readily identify the collection rates. As a result, management was unable to monitor collection rates and detect unusual fluctuations in a timely manner. We also determined that similar collection reports were also not available from OBSCIS for other imposed costs included in offender payment plans, such as restitution, fines, and court costs. Recommendation 2 We recommend that DPP management, in conjunction with the DPSCS Information Technology and Communications Division, determine the feasibility of developing reports, which could be used by management to periodically monitor the payment plan collection rates. This includes collections for all fines, fees, and costs imposed on parolees, mandatory supervision releasees, probationers, and drinking driver monitor program participants. 13

16 EXHIBIT A Excerpt from Department of Legislative Services Analysis of the Fiscal Year 2006 Executive Budget Issues Q00C02 DPSCS Division of Parole and Probation Analysis of the FY 2006 Maryland Executive Budget, Increased Probation Supervision Fee DPP plans to increase the fee for probation supervisees from $25 a month to $40 a month. Parole supervisees already pay $40 per month. The division expects to raise approximately $1.3 million in general funds from this increase, of which $598,000 is tied to a general fund contingent appropriation. The division plans to use the contingent funds for the purchase of additional motor vehicles and for enhanced drug testing. The division plans to purchase 26 standard State sedans in order to reduce the need for DPP employees to use personal vehicles for DPP business. The increased funds for drug testing will allow for more frequent testing of supervisees. Currently, agents can only request seven tests per month to be divided among their entire caseload. Additionally, costs for in-house urinalysis testing have risen. The division does not have data on how many offenders currently pay the existing fee. The Department of Legislative Services (DLS) has historically had difficulty identifying collection rates for supervisees. However, the division has based revenue estimates on a 50% collection rate. The division calculated this rate based on the number of offenders ordered to pay the monthly supervision fee and what the estimated collections should be, compared to what is actually collected. The division s Managing for Results data estimates that there will be 116,900 cases under probation supervision in fiscal 2006, though the division may exempt some supervisees from all or part of the fees if the supervisee can demonstrate a financial hardship usually inability to obtain employment, student status, disability, or dependents. However, the division does not maintain income and employment data on offenders in its database, so it is difficult to gauge how many supervisees might qualify for an exemption. The division should be prepared to comment on the practicality of a 50% collection rate and how realistic it is to expect to raise $1.3 million in general funds from a $15 increase in probation fees. DLS recommends that the Office of Legislative Audits (OLA) conduct a performance audit in the Division of Parole and Probation to determine the supervision fee collection rate. 14

17 EXHIBIT B (page 1 of 2) Excerpt from Division of Parole and Probation Response to DLS Analysis of the Fiscal Year 2006 Executive Budget ISSUES: 1. Increased Probation Supervision Fee: Background: Legislation was enacted during the 1991 legislative session mandating the imposition of monthly supervision fees for offenders supervised by the Division of Parole and Probation. Under of the Correctional Services Article and of the Criminal Procedure Article, the monthly fees of $40 for parolees and mandatory supervision releasees and $25 for probationers have remained unchanged since their inception. The Budget Financing Act of 2005 increases the supervision fee charged to probationers from $25 to $40 per month, making the monthly fee consistent for all supervisees. The supervision fees collected are paid into the General Fund. As previously noted, the Division supervises approximately 66,000 offenders across the State of Maryland. This number includes 40,000 offenders sentenced to probation supervision for the commission of criminal offenses and 16,000 offenders under probation supervision in the Drinking Driver Monitor Program (DDMP). The Division has developed new methods to more effectively supervise offenders by beginning the implementation of a Proactive Community Supervision (PCS) protocol with the objectives of protecting public safety; holding offenders accountable to victims and the community; and helping offenders become responsible and productive. PCS was slated for statewide implementation over a four-year period beginning in Fiscal Year The planned rollout, however, was hindered due to subsequent budget constraints. The Division also dedicates agents and resources to the CSAFE community sites. This legislative change will increase General Fund revenues and help to defray the cost to taxpayers for effectively managing offenders in the community. The Division should be prepared to comment on the practicality of a 50% collection rate and how realistic it is to expect to raise $1.3 million in general funds from a $15 increase in probation fees. DLS recommends that the Office of Legislative Audits (OLA) conduct a performance audit in the Division of Parole and Probation to determine the supervision fee collection rate. As the analyst notes, the Division is basing the estimated 50% collection rate on the number of offenders ordered to pay the monthly supervision fee and what the estimated collections should be, compared to what is actually collected. The Division s data reflect that supervision fees are currently imposed in 36.4% of active criminal supervision probation cases. Due to the prospective nature of the legislation, the Division estimates revenues of $709,635 in FY 06 and $1.3 million in FY 07. Given the limitations of the Division s accounting system, this is the best estimate of potential revenues and the Division chose to err on the side of caution in its calculations. 15

18 EXHIBIT B (page 2 of 2) Excerpt from Division of Parole and Probation Response to DLS Analysis of the Fiscal Year 2006 Executive Budget The Division supervises an average of 40,000 offenders assigned to criminal probation at any given point during the year. Approximately 40,000 individuals are placed on probation supervision during the year. Based on the assumption that the supervision fee will be imposed in 36.4% of the cases (40,000 x 36.4%), the Division estimates that 14,560 new probationers will be assessed the additional new amount. Prorating that 14,560 evenly throughout the initial fiscal year, the Division will collect $709,635 in FY 06. This allows for payments at the current 50% collection rate. During the out-years, the collections will be static at approximately $1,310,400. FY 2005 Intake Fee Collections July 1,213 $15 $18,195 August 2,426 $15 $36,390 Sept 3,639 $15 $54,585 October 4,852 $15 $72,780 November 6,065 $15 $90,975 December 7,278 $15 $109,170 January 8,491 $15 $127,365 February 9,704 $15 $145,560 March 10,917 $15 $163,755 April 12,130 $15 $181,950 May 13,343 $15 $200,145 June 14,560 $15 $218,400 TOTAL $1,419,270 1 st year 50% 709,635 2nd year (14,560 x $15 x 12mos. X 50%) $1,310,400 Another factor that influences the collection of supervision fees is the priority order in which the courts order all monies to be disbursed. In 1976, Chief Judge Robert C. Murphy established Guidelines for the Collection and Supervision of Cases Involving Restitution, Fines, Costs and Attorneys Fees. Theses guidelines were later amended in The Guidelines direct that monies be disbursed in the following order, unless otherwise directed by the courts: restitution, fines, court costs, public defender fees, 2% administrative fee and supervision fees. The Division welcomes any recommendations that may be offered by the OLA in the Division s attempt to increase the collection rate for supervision fees. The Division does not have the authority to exempt offenders from payment of the supervision fee. In some instances the courts waive the fee at the time of sentencing. In other instances where the offender documents to the agent that he/she is unable to pay the fee due to legitimate circumstances and that paying the fee would pose an undue hardship, the agent notifies the court of the offender s circumstances and asks for the court s determination on payment of the fee. The Division plans to refine its criteria for forwarding offenders requests for fee waivers to the court. 16

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21 Agree. DPP agrees with the auditor s recommendation that management, in conjunction with the Department of Public Safety and Correctional Services (DPSCS) Information Technology and Communications Division, will determine the feasibility of developing reports which could be used by management to periodically monitor the payment plan collection rates. This includes collections for all fines, fees, and costs imposed on parolees, mandatory supervision releasees, probationers and Drinking Driver Monitor Program participants. The Division believes that it is good management and in the public interest to be able to measure the Division s success in collecting court-ordered monies and statutorily authorized fees. The recommended reports will allow the Division to track major trends in collections and highlight regions that are experiencing significant difficulty in their collection efforts; however, the reports will not provide a true accounting of the Division s collection rate as a total or the individual categories of monies that offenders are ordered to pay. By way of background, the Division has had numerous discussions with the Department s technology division over the years to explore the reporting capacity of the Offender Based State Corrections Information System (OBSCIS) and its ability to age accounts and provide measurable data that would reflect the Division s collection rate for restitution and other monies the Division collects. OBSCIS does not have the ability to produce account aging reports. This issue was discussed and studied in depth as a result of the enactment of Chapters 359 and 640 of the Acts of the General Assembly of 1997 that required the Division of Parole and Probation to establish a pilot program to contract with a private vendor to collect certain court-ordered costs, fines, restitution payments and fees. The Department of Public Safety and Correctional Services final report on the project issued in March 2003 stated that it would be illadvised to proceed with further privatization initiatives until the Division had an information system that enabled it to accurately assess its success in collecting money owed by offenders and thus set a standard for comparison by which to measure the effectiveness of future privatization initiatives. The impediments to obtaining the desired data stem from a number of factors, some of which are due to the age and lack of sophistication of OBSCIS and others are due to related business practices. The OBSCIS system is over 20 years old and was not originally intended or designed as a billing and accounts receivable system. When an offender is placed under the Division s supervision, a monthly payment plan is established based on the total amount of money the offender owes and the length of time the offender will be under supervision. Disbursements of monies collected from offenders are made in a specific priority order according to former Chief Judge Murphy s guidelines*, with all restitution being paid first, unless otherwise ordered by the court. Each of the succeeding priorities is paid off completely before proceeding to the next priority. As a result, OBSCIS cannot report an offender s compliance with payments by specific category. Although the offender is charged a supervision fee for each month, and the offender is paying in accordance with the payment plan, there may not be any money disbursed to the General Fund for the supervision fee if higher priority debts are owed. Because disbursements are processed separately from collections and collections are based on a payment plan while disbursements are based on a priority schedule, it is not possible to determine the time when the supervision fee was due versus the time when the funds were disbursed to pay that fee. The reports recommended by the auditor will give a general idea of the overall collection rate. A comprehensive billing and accounts receivable system would be needed in order for the

22 Division to generate reports that reflect actual collection rates overall and by category. Holding offenders accountable to victims of crime and the community is an integral part of the Division s supervision model. The ability to accurately measure collection rates for monies offenders are ordered to pay as a part of their sentences would enable to Division to more fully realize this goal. Developing this system entails: Defining what data needs to be captured Analysis of DPP business requirements to ensure that both supervision and collections data are part of a unified, user-friendly, case management system that will interface with essential business partners including the Central Collection Unit of Department of Budget of Management Analysis of the accounting functions that must be incorporated in the program Implement the technical solution along with appropriate changes in business practices The Division disburses in excess of $16 million annually and fully recognizes the importance of being able to measure and report whether this is the optimum outcome. The Division welcomes the continued assistance of the Office of Legislative Audits and any recommendations it may have for the Division to improve and accurately reflect its collection activity. report. Please advise if you have any questions regarding the Division s responses to the audit c: G. Lawrence Franklin, Deputy Secretary for Administration Joseph M. Perry, Inspector General Wilson H. Parran, Chief Information Officer *In June 1976, former Chief Judge Robert C. Murphy issued guidelines for the Collection and Supervision of Cases Involving Restitution, Fines, Costs and Attorneys Fees that establish the order in which court-ordered and statutorily authorized fees are disbursed. The guidelines were last revised in January 1992 to address the new monthly supervision fee and its place in the disbursement order.

23 AUDIT TEAM Timothy R. Brooks, CPA, CFE Audit Manager Abdullah I. Adam Senior Auditor