0. Internal Audit Plan For the Fiscal Year Ending June 30, 2013

1. Your Internal Audit Team
OOCEA
Audit Committee
OOCEA
General Counsel
Protiviti Engagement Team
Phil Fretwell
Overall Engagement
Managing Director
Michael Porier
Toll Road Industry Advisor
Jeff Tecau
Internal Audit
Director
David Taylor
Information Technology Audit
Erica Klostermeier
Internal Audit
Senior Manager
Mike Ortlieb
Information Technology Audit
Senior Manager
Other Internal Audit Managers, Seniors and Consultants
Level and experience will be matched to project need

2. Background
Risk assessment is a critical element of a high-quality Internal Audit department’s responsibility and provides the opportunity to be “front and center” with senior leadership as a strategic partner in the review and management of key business risks. The objective of the fiscal 2013 risk assessment was to identify and prioritize key areas of risk within the Authority as part of the planning process in designing the fiscal 2013 Internal Audit plan. The approach utilized in conducting the fiscal 2013 risk assessment and in developing the fiscal 2013 Internal Audit plan is depicted below:
Identify Key Areas of Risk to be Assessed
Confirm and update prior year risk areas based upon review of prior year work papers, audit results, and discussions with senior management and the Board
Determine preliminary risk ratings based upon prior year results
Review areas of potential fraud risk as identified in prior years
Conduct interviews with management and the Board to confirm and validate the current enterprise risk model as well as the fraud risk model and to gain additional insight around risk trending
- Aggregate and compile resulting information
- Prioritize areas of risk (both enterprise and fraud) and finalize the enterprise risk model
Assess & Prioritize Areas of Risk
- Evaluate risks based upon the prioritization process and management and Board commentary to determine focus areas
- Develop and define a preliminary listing of proposed Internal Audit projects to address areas of focus
Select Focus
Areas
Establish high-level scope statements and levels of effort for proposed projects
Finalize budget allotments and propose projects for Audit Committee approval
Finalize proposed timing for selected projects
-Finalize Audit Plan and obtain Audit Committee approval
Develop & Approve Audit Plan

3. Interview List
The following twenty one (21) members of the Board of Directors, management and outsourced vendors were interviewed in gathering information for the fiscal year 2013 Internal Audit Plan:
Name
Title
Walter Ketcham, Jr.
Chairman of the Board
Joann Chizlett
Director of Information Technology
Scott Batterson
Vice Chairman of the Board
Glenn Pressimone
Project Manager, Engineering
Noranne Downs
Board and Audit Committee Member
Ben Dreiling
Director of Construction
Teresa Jacobs
Board Member and Secretary/Treasurer
Neel Long
Director of Human Resources
Tanya Wilder
Board Member and Audit Committee Chair
Michelle Maikisch
Manager of PR and Communications
Max Crumit
Interim Executive Director
David Wynne
Manager of Toll Operations
Joe Berenis
Deputy Executive Director
Rod Stroupe
Manager of Maintenance
Laura Kelley
Lance Fisher
Vendor; ACS Project Manager
Joe Passiatore
General Counsel
Dan Goff
Vendor; FTS Project Manager
Nita Crowder
Chief Financial Officer
L.A. Griffin
Manager of Expressway Operations
Claude Miller
Director of Procurement

4. Enterprise Risk Assessment
To assist with the development of the fiscal 2013 Internal Audit Plan, Internal Audit used prior years’ risk models and risk trending data as the starting point for discussions with the Board and management. Internal Audit asked the Board and management to consider the current business environment, critical business initiatives, and prior year audit results to provide input on which risks warranted the most focus in today’s environment. In addition, management was asked to identify any new risks that may not have been considered in past years for inclusion in the current risk model.
Internal Audit utilized the aggregated input obtained during interviews with the Board and management to develop a list of potential internal audit projects for fiscal 2013, with the objective being to help the Audit Committee and management mitigate areas of highest residual risk, monitor areas of high inherent risk, or to mitigate areas where risks are trending higher.
Internal Audit defined risk as follows:
Risk:
Is the possibility of an event occurring that will have a negative impact on the achievement of goals and objectives and could also include the cost of missing an opportunity.
Inherent Risk:
Is the amount of risk to the business given the environment in which it operates, without considering the application of controls. The risks identified on the following page represent the risk areas deemed most important for the Authority to manage and control in order to achieve its goals and objectives.
Residual Risk:
Is the amount of risk remaining after the application of management controls. Residual risk was judgmentally considered for purposes of this fiscal 2013 audit plan in the selection of potential projects for including on the plan.

5. Fraud Risk Assessment
In addition to the Enterprise Risk Assessment and in conjunction with the Fiscal 2013 Internal Audit planning process, Internal Audit executed a fraud risk assessment with the objectives of:
Conducting a review of the completeness of the Authority’s fraud risk universe and a refresh of the fraud risk assessments completed during fiscal years 2011 and 2012 in accordance with the COSO framework,
Identifying key management activities and prior audits that may help reduce exposure to the highest risk fraud scenarios, and
Proposing Internal Audits projects as part of this plan that may help reduce exposure to the highest risk fraud scenarios that have not been previously audited within the past 4 years or that do not appear to receive a high amount of attention from management.
Per the Institute of Internal Auditors (IIA) International Standards for the Professional Practice of Internal Auditing (“Standards”) Standard 2120.A2 reads, “The internal audit activity must evaluate the potential for the occurrence of fraud and how the organization manages fraud risk.”
The results of the fraud risk assessment work for the top 50% of fraud risk scenarios are provided in Appendix B of this report.

6. OOCEA Risk Model Strategic Execution Financial Reporting Operational
Strategic planning* - Organization structure* Succession planning*
- Regulatory changes - Access to capital Statewide interoperability*
- Governance* - Political environment Ethical behavior*
Communication - Leadership Outsourcing*
RTA/Consolidation
Financial reporting* Contract performance reporting*
Cost containment* Procurement and vendor selection**
Budgeting Management performance reporting*
Fraud* Cash handling**
Bond financing and covenant Treasury and liquidity management
compliance
Financial
Reporting
Operational
Execution
- Toll violations* IT infrastructure* / business continuity
Toll collections** IT security and access**
IT application controls* IT change management*
Human Resources* Insurance Coverage
Regulatory /
Compliance
Public relations* Customer satisfaction
Maintenance & safety Contract management**
Bold indicates new risks added to the Risk Model in 2012
*Represents risks addressed by internal audits in Fiscal 2012, 2011, 2010, or 2009
** represents areas to be addressed by Fiscal 2013 Internal Audit Projects

7. Risks not Addressed through Internal Audit
Controls and/or Oversight outside of Internal Audit
Audit Committee Evaluation of Additional required Internal Audit Effort
Communication
Communication risks are principally managed through Board of Directors and Committee oversight.
None – not typically an area that can be addressed by internal audit
Access to Capital
Capital has been achieved through bond offerings – see related risks below.
Political Environment
The political risks are managed by the Executive Director and frequent communication of issues with the Board and Committees.
Leadership
Leadership risks are managed by the Board.
Budgeting
Budgeting risks are managed by the Board and Finance Committee, including a presentation each year on the budget process and results by the CFO.
None – remaining risks are not significant enough to cost justify additional internal audit resources.
Bond financing and covenant compliance
Outside financial advice is provided by third party firms and the external auditor considers covenant compliance in connection with the annual financial statement audit.
Treasury and liquidity management
Treasury and liquidity risks are managed by the CFO with oversight of the Finance Committee.
Insurance Coverage
An outside advisor is being engaged to provide advice on insurance coverage.
Maintenance and Safety
Standards for Maintenance and Safety related risks and other performance areas are monitored by the Florida Transportation Commission.  The Commission submits a report titled the Transportation Authorities Monitoring and Oversight report annually to the Governor and Legislature. 
Customer Satisfaction
Many customer services are outsourced to third party firms, and the Authority engages an outside firm to do a customer satisfaction survey every other year.
None, due to a collaborative effort to consolidate back office services in the future if cost efficiencies and improved customer service can be obtained.

8. Fiscal 2013 Internal Audit Plan
The Internal Audit plan outlined below has been developed based on an Audit Committee approved budget of $369,000. The expected budget allocation, by type of Internal Audit project, is as follows:
Performance and Compliance
Budget Allocation
Prior Audit Recommendations: Semi-annual Follow-up and Reporting
$20,000
- Contract Billing Audits
$45,000
- Toll Revenue Audit
$85,000
- Procurement Audit – Large Contract Awards
$35,000
-FTC Report Audit
-Dashboard Audit
$39,000
$10,000
Information Technology
PCI Assessment with Report on Compliance
DHSMV Data Security Assessment
$65,000
$25,000
Other
Fiscal 2013 Internal Audit Plan, including Company Risk Assessment and Fraud Risk Assessment
$30,000
Administration
- Board and Audit Committee Meetings
$15,000
TOTAL
$369,000 4% 8%
24%
64%

9. Fiscal 2013 Internal Audit Projects#
Project
Project Description
Risks
Estimated Cost 1
Prior Audit Recommendations: Semi-annual Follow-up and Reporting
This work will focus on semi-annual follow-up on the status of all OPEN action plans from prior year audits. In addition, internal audit will consider re-auditing closed recommendations for selected areas from prior year audits as requested by management or the audit committee. DATE LAST COMPLETED: February 2012
Various
$20,000 2
Annual Contract Billing Audits
This audit will encompass a selection of large engineering, construction, maintenance, operations, or legal contracts on an annual, rotational basis, with the objective of verifying that internal controls are in place to ensure work performed for the Authority under large contracts has been billed in accordance with contractual terms and conditions. The work will include testing pricing and hours worked for accuracy and validity, testing invoice approvals, testing vendor compliance with other contractual obligations, using data analytics to identify high risk vendors and/or change orders, and trending key spend data and other data points for management review and consideration. DATE LAST COMPLETED: April 2012
Contract Management
Contract Performance Reporting
Cost Management
Procurement and vendor selection
$45,000 3
Toll Revenue Audit
The toll revenue audit will focus on the two processes driving Toll Revenue: cash toll collections and electronic tolling collections, with the objectives to review (1) controls exist to ensure revenue data captured at the point of origin is completely and accurately recorded to the financial statements, (2) physical safeguarding controls exist around cash (including the use of security and surveillance, data analytics, monitoring and reporting, and counts / other reconciling activities), (3) review and ensure controls in place around processing revenue adjustments to customer accounts are operating according to policy, and (4) appropriate monitoring and measurements are in place to review toll revenue. We will also test to ensure that the previous audit recommendations around toll revenue have been implemented. Additionally, IT general controls around supporting systems and information technology will be reviewed. DATE LAST COMPLETED: KPMG 2009
Toll Collections
Cash Handling
$85,000 4
Procurement Audit of Large Contract Awards
This audit will encompass a selection of large engineering and construction contract awards. The work will include testing the awarding process of contacts that are not “low bid” awards. Internal audit will also evaluate the process for short-listing vendors and for scoring proposals and consider procedures in place at Orange County and the City of Orlando to the extent they can be obtained. We will obtain the bid packages and awarding criteria for each of the contracts, and verify there is proper justification for the awarding of contractors. We will also review for evidence of excessive vendor preference. This audit will be done in two phases: phase one will be to evaluate the policy that is currently in place, phase two will be to test the award process against the policy.
DATE LAST COMPLETED: County Audit - October 2007
Fraud
$35,000

10. Fiscal 2013 Internal Audit Projects#
Project
Project Description
Risks
Estimated Cost 5
Florida Transportation Commission (‘FTC’) Data Input Audit
The FTC will be conducting a study of the potential for cost savings which may be achieved by sharing of resources between Florida Expressway Authorities (Orlando-Orange County Expressway Authority (OOCEA), Tampa Hillsborough Expressway Authority (THEA), Miami-Dade Expressway Authority (MDX), and Florida’s Turnpike Enterprise (FTE)). The purpose of this audit is to review the data inputs that went into this study to verify accuracy, consistency, and comparability. (CONTINGENT UPON EXTENDED PROCEDURES PERFORMED BY TTI)
Reporting
$39,000 6
Board Quarterly Reporting Dashboard Audit
Test the accuracy and completeness of the new quarterly dashboard that is being prepared for the Board. (CONTINGENT ON WHETHER THE NEW DASHBOARD PROCEDURES REMAIN IN PLACE WITH THE NEW EXECUTIVE DIRECTOR)
Management Reporting
$10,000 7
DHSMV Data Security Assessment
The objectives of this assessment is to review internal controls for gaps in design related to the requirements set forth in Section V – Safeguarding Information, of the DHSMV Drivers License or Motor Vehicle Record Data Exchange Memorandum of Understanding (MOU).
IT Security
$25,000 8
PCI Assessment with Report on Compliance
This project will be to fully test the Authority’s compliance with the PCI Data Security Standard, (PCI-DSS) version 2.0 and issue a Report on Compliance (ROC). The testing will cover all twelve sections of the PCI-DSS. DATE LAST COMPLETED: April 2012 (Gap assessment only)
$65,000 9
Fiscal 2014 Internal Audit Plan, including Company Risk Assessment and Fraud Risk Assessment
We will conduct a risk assessment to highlight the Authority’s current year risk profile, to identify risk trends, and to form the foundation for the fiscal year 2014 Internal Audit Plan. In addition, we will conduct the annual review of the completeness of the fraud risk universe and annual refresh of the fraud risk assessment in accordance with the COSO framework, The information and findings will be utilized to develop the 2014 Internal Audit plan, with a focus on addressing opportunities identified during the risk assessment process.
Strategic Planning
Fraud
$30,000

11. Fiscal 2013 Internal Audit Projects#
Project
Project Description
Risks
Estimated Cost 10
Board and Audit Committee Meetings
Protiviti will attend Board meetings and prepare for and present at all Audit Committee meetings during fiscal year This includes all prep time with management and the Audit Committee in advance of meetings.
N/A
$15,000
TOTAL
Consistent with the Fiscal 2013 Internal Audit Budget
$369,000

12. Other Potential Internal Audit Projects not Selected for Fiscal 2013#
Project
Project Description
Risk
Estimated Cost 1
ISO Information Security Review
This review will compare, at a high level, OOCEA’s information security practices and procedures to the ISO framework. This framework is widely recognized as the benchmark for assessing / creating overall information security programs. Protiviti will utilize an adapted version of the Carnegie Mellon Capability Maturity Model (CMM) to report on the results of this effort.  The CMM helps to identify critical areas that must be addressed before an organization can progress to a more mature state. DATE LAST COMPLETED: N/A
IT Security
$45,000 2
IT General Controls Review
This review will focus on the OOCEA Information Systems area. To accomplish this, we will assess the policies and procedures that are utilized to support the business critical applications and systems at OOCEA. Our approach will be to focus on the IT General Computer Controls which include the following components: Change Management, Logical Security, Physical Security, Security Administration, IT Organization & Management. DATE LAST COMPLETED: N/A
IT Infrastructure
Application Controls
Change Management
$36,000 3
Disaster Recovery Review
This review will focus on the Business Continuity and Disaster Recovery plans, including existing policies and procedures. The review will include an assessment of the documented plans as well as the foundational efforts that were performed to create them (such as a Business Impact Analysis). DATE LAST COMPLETED: N/A
Business Continuity
$40,000 4
Document Retention and Records Management Audit
The Florida Secretary of State has established a documentation retention schedule specific to document classification (different types must be kept for a different lengths of time). Expressway is currently revising it’s policy around document retention and records management and likely won’t be ready for internal audit to look at it until fiscal DATE LAST COMPLETED: N/A
Document Retention and Records Management
$35,000 5
Sensitive Data / Data Management Review
The objectives of the project will be to identify if sensitive data is inappropriately stored in locations on the OOCEA network - in violation of company policy and leading practices. In addition, we will perform a high-level evaluation of the controls over the sensitive data repositories that are identified (if applicable) to determine if potential gaps exist. LAST COMPLETED: N/A

13. Other Potential Internal Audit Projects not Selected for Fiscal 2013#
Project
Project Description
Risk
Estimated Cost 6
Bond Financing Audit
This audit will encompass reviewing the process for bond financing and the use of financial advisors. In addition, we will review the assumptions / inputs used in determining the appropriate structure of recent financing arrangements to verify the assumptions / inputs are reasonable. We will utilize our financing subject matter specialists to assist with this work. DATE LAST COMPLETED: N/A
Treasury and Liquidity Management
$35,000 7
Safety Plan Compliance Audit
The objective of this audit would be to verify that the safety plan in place is being followed/practiced according to policy/plan.
Maintenance & Safety
$30,000 8
EPass Asset Management Review – with a focus on complimentary transponders
The purpose of this audit is to take a full inventory of the complimentary EPass transponders to verify that they are all accounted for on approved vehicles.
Revenue
Asset Management
$20,000 9
Budgeting/Capital Process Review
The purpose of this review is to review the budgeting, forecasting, and change management processes for capital funding and to determine if there are any efficiencies that can be gained in this process or opportunities to improve the current process to manage capital spending. This will include how projects are added and subtracted to the work program and a review of the risks and controls around making sure funding appropriately matches the work program.
Budgeting 10
Marketing and Communications Plan Audit
IA will utilize subject matter experts from it’s Creative Options Group to review the authorities new marketing and communications plan. Specific items that may be included in this review include a review of the communications policies, approach, use of a creative marketing vendor, communications tool, Board member/employee training, social media, and measurement of the plan (short term versus long term impacts).
Communications
$45,000

14. Other Potential Internal Audit Projects not Selected for Fiscal 2013#
Project
Project Description
Risk
Estimated Cost 11
Call Center Review
The purpose of this review is to develop an understanding of the authority’s current state of operations and determine if there are any factors impeding the authority’s ability to achieve the best possible performance.
Customer Service
$50,000 12
Social Media Policy Audit
The purpose of this audit would be to review the authority’s Social Media program, including reviewing the current social media policy and process documentation; interview senior management to understand how social media is utilized within the authority; identify key risks related to social media and map them to existing controls; perform testing of the controls in place and identify any gaps.
Communications
$25,000 13
Whistleblower Hotline
The purpose would be to review the process for letting people know about the whistleblower hotline, how calls are escalated and what the reporting processes is.
Human Resources
$5,000

15. Internal Audit Timeline
FY 2013 Estimated Project Timeline
July Aug Sept Oct Nov Dec Jan Feb Mar Apr May June
Selected Audits
Prior Audit Recommendations: Semi-annual Follow-Up
Annual Contract Billing Audits
Toll Revenue Audit
Procurement Audit of Large Contract Awards
FTC Data Input Audit
Board Reporting Dashboard Audit
DHSMV Data Security Assessment
PCI Assessment with Report on Compliance
Fiscal 2014 Internal Audit Plan, including Company Risk Assessment and Fraud Risk Assessment
Administration
Board and Audit Committee Meetings

16. Appendix A Internal Audit Charter

17. Internal Audit Charter
Orlando – Orange County Expressway Authority
Fiscal 2013 Internal Audit Department Charter
MISSION
The mission of the internal audit department is to provide the Authority Board with unbiased, objective assessments of whether Expressway resources are responsibly and effectively managed to achieve intended results.
PURPOSE
Internal audit’s purpose is to add value, improve operations, and enhance transparency. It helps the Expressway accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes.
INDEPENDENCE
The Internal Auditor Director is appointed by the Expressway Authority Board, and reports to them through the Audit Committee. The role of the Internal Audit Director may be filled by an outside firm that provides internal audit services to the Expressway Authority on an outsourced basis. For administrative purposes, the Internal Audit Director reports to the General Counsel. To ensure independence, the internal audit function has no direct responsibility or any authority over any of the activities or operation of the Expressway.

18. Internal Audit Charter
AUTHORITY
Everything the Expressway Authority does is subject to assessment by internal audit. Internal Audit shall have full, free, and unrestricted access to all activities, records, properties and personnel. The Internal Audit Director shall have direct and independent access to members of the Audit Committee. The internal audit department is authorized to allocate resources, set frequencies, select subjects, determine scopes of work for projects as approved by the Audit Committee, and apply the techniques required to accomplish audit objectives. In addition, the Internal Audit Director may obtain the necessary assistance of personnel in units of the organization where they perform audits, as well as other specialized services from within or outside the organization, as approved by the Audit Committee.
SCOPE
Management is responsible for establishing and maintaining risk management, control, and governance processes. The scope of work of internal audit is to determine whether management’s processes are adequate and functioning in a manner to ensure:
Risks are appropriately identified and managed.
Interaction with the various governance groups occurs as needed.
Significant financial, managerial, and operating information is relevant, reliable and understandable.
Employee actions comply with policies, standards, procedures, and applicable laws and regulations.
Resources are acquired economically, used efficiently, and adequately protected.
Programs, plans, and objectives are achieved.
Quality and continuous improvement are fostered in control processes.
Significant legislative or regulatory issues are recognized and addressed properly.

19. Internal Audit Charter
RESPONSIBILITY
The internal audit department’s responsibility includes, but is not limited to:
Develop a flexible annual audit plan using appropriate risk-based methodology, including any risks or control concerns identified by management, and submit that plan to the Audit Committee for review and approval.
Implement the annual audit plan, as approved, including, and as appropriate, any special tasks or projects requested by management and the Audit Committee.
Maintain a professional audit staff with sufficient knowledge, skills, experience, and professional certifications to meet the requirements of this Charter.
Establish a quality assurance program by which the Internal Audit Director assures the operation of internal auditing activities.
Perform consulting services, beyond internal audit's assurance services, to assist management in meeting its objectives. Examples may include facilitation, process design, training, and advisory services.
Evaluate and assess significant merging/consolidating functions and new or changing services, processes, operations, and control processes coincident with their development, implementation, and/or expansion.
Issue periodic reports to the Audit Committee and management summarizing results of audit activities as well as results of internal and external assessments conducted in association with the Quality Assurance and Improvement Program.
Keep the Audit Committee informed of emerging trends and successful practices in internal auditing.
Provide a list of significant measurement goals and results to the Audit Committee.
Assist in the investigation of significant suspected fraudulent activities within the organization and notify management and the Audit Committee of the results.
Consider the scope of work of the external auditors and regulators, as appropriate, for the purpose of providing optimal audit coverage to the organization at a reasonable overall cost.

20. Internal Audit Charter
STANDARDS
Internal audit shall comply with the International Standards for the Professional Practice of Internal Auditing of The Institute of Internal Auditors. Consistent with the IIA Standards, internal audit recognizes the mandatory nature of the Definition of Internal Auditing, the Code of Ethics, and the IIA Standards.

21. Appendix B Fraud Risk Assessment Results

22. Fraud Risk Assessment Results
Risk assessment results and a gap coverage analysis for the top 50% of fraud risk scenarios are depicted below, considering management control activities, prior Internal Audits, and potential next steps / proposed future audits.
Fraud Scenario
Relative Rating / Trend
Management Key Activity
Prior Audits
Potential Next Steps / Audits 1
Unauthorized / improper use of corporate credit cards / misuse of company funds
High
1. The Director of Procurement reviews all monthly statements for receipt support.
2. Periodic P-Card audits are performed by the Deputy Director Administration.
Prior Audit Recommendations: Semi-annual Follow-up and Reporting
2011 Fraud Risk Assessment with P-Card Audit
None 2
Management disclosure of confidential information during procurement
Bids / proposals are sealed and opened only after the due date.
2011 and 2012 Contract Audits
Procurement Audit - Large Contracts - Will be considered in 2013 3
Theft or misuse of confidential financial information, e.g. credit card numbers, bank account information, etc.
Call center employees cannot see customer financial information once it is entered into the system.
PCI Assessment with Report on Compliance
2013 PCI Assessment 4
Circumvention of procurement
Procurement policies and procedures are in place.
2011 Limited Procurement Compliance Audit 5
Theft of cash
Reconciliations are performed between cash collected, what the collector's system says should have been collected, and the treadles.
2009 Toll Revenue Audit
Toll Revenue Audit - Will be considered in 2013

23. Fraud Risk Assessment Results
Fraud Scenario
Relative Rating / Trend
Management Key Activity
Prior Audits
Potential Next Steps / Audits 6
Toll violations
High
Unpaid Toll Notices are sent to violators
2012 Violations Audit
None 7
Payment of false invoices / invoices do not match contract terms
Invoices are reviewed on multiple levels prior to payment
2011 and 2012Contract Audits
2011 Vendor Billing Audits
 2013 Annual Contract Audit 8
Bribery / kickback to award bids
Procurement policies and procedures are in place.
 None; typically reviewed as part of a whistleblower complaint 9
Adjustment to customer accounts
Customer service personnel cannot adjust customer accounts without supervisor approval.
2011 Contract Audits (ACS)
 2013 Toll Revenue Audit 10
Selective disclosure to Board or public (Intentionally omitting detrimental information, debt covenant violations, ethics violations, etc.)
2010 Ethics Policy Compliance Review
2009 Corporate Governance Review
2013 Board Reporting Dashboard Audit 11
Billing for work not performed or vendor overbillings
2011 and 2012 Contract Audits
2010 Purchasing Spend Audit
2013 Annual Contract Audit

24. Fraud Risk Assessment Results
Fraud Scenario
Relative Rating / Trend
Management Key Activity
Prior Audits
Potential Next Steps / Audits 12
Solicitation (the act of a Company purchasing agent or other representative demanding payment to allow the contractor to continue)
High
Procurement policies and procedures are in place.
2010 Ethics Policy Compliance Review
 None; typically reviewed as part of a whistleblower complaint 13
Off-contract agreements
None
 None proposed; typically reviewed as part of a whistleblower complaint 14
Counterfeit cash
Toll collectors use counterfeit detection pens on large bills
2009 Toll Revenue Audit
2013 Toll Revenue Audit