Performance audit, Arizona Board of Appraisal 2003

              A REPORT
TO THE
ARIZONA LEGISLATURE
Debra K. Davenport
Auditor General
Arizona Board
of Appraisal
Performance Audit Division
AUGUST • 2003
REPORT NO. 03-06
Performance Audit
The Auditor General is appointed by the Joint Legislative Audit Committee, a bipartisan committee composed of five senators
and five representatives. Her mission is to provide independent and impartial information and specific recommendations to
improve the operations of state and local government entities. To this end, she provides financial audits and accounting servic-es
to the State and political subdivisions, investigates possible misuse of public monies, and conducts performance audits of
school districts, state agencies, and the programs they administer.
The Joint Legislative Audit Committee
Senator Robert Blendu, Chair Representative John Huppenthal, Vice Chair
Senator Gabrielle Giffords Representative Tom Boone
Senator Peter Rios Representative Ken Clark
Senator Thayer Verschoor Representative Ted Downing
Senator Jim Weiers Representative Steve Yarbrough
Senator Ken Bennett (ex-officio) Representative Jake Flake (ex-officio)
Audit Staff
Dot Reinhard, Manager and Contact Person
Channin DeHaan, Team leader
Pam Eck
Copies of the Auditor General’s reports are free.
You may request them by contacting us at:
Office of the Auditor General
2910 N. 44th Street, Suite 410 • Phoenix, AZ 85018 • (602) 553-0333
Additionally, many of our reports can be found in electronic format at:
www.auditorgen.state.az.us
2910 NORTH 44 th STREET • SUITE 410 • PHOENIX, ARIZONA 85018 • (602) 553 -0333 • FAX (602) 553 -0051
DEBRA K. DAVENPORT, CPA
AUDITOR GENERAL
STATE OF ARIZONA
OFFICE OF THE
AUDITOR GENERAL
WILLIAM THOMSON
DEPUTY AUDITOR GENERAL
August 7, 2003
Members of the Arizona Legislature
The Honorable Janet Napolitano, Governor
Ms. Deborah G. Pearson, Acting Executive Director
Arizona Board of Appraisal
Transmitted herewith is a report of the Auditor General, A Performance Audit of the Arizona Board
of Appraisal. This report is in response to A.R.S. §32-3604(J) and was conducted under the
authority vested in the Auditor General by A.R.S. §41-1279.03. I am also transmitting with this report a
copy of the Report Highlights for this audit to provide a quick summary for your convenience.
As outlined in its response, the Arizona Board of Appraisal agrees with all of the findings and
plans to implement all of the recommendations.
My staff and I will be pleased to discuss or clarify items in the report.
This report will be released to the public on August 8, 2003.
Sincerely,
Debbie Davenport
Auditor General
Enclosure
Services:
The Board was established in 1990 in response to changes in federal banking regulations that
required federally regulated financial institutions to use licensed or certified appraisers for real
estate-related transactions and allowed all states to establish agencies to regulate them. The
Board has the following responsibilities:
􀁺􇩌 Licensing appraisers—Issuing licenses and certifications to applicants who meet the
national education and experience standards. As of January 2003, there were 1,757
active appraisers.
􀁺􇩒 Resolving complaints—Receiving and resolving complaints and taking disciplinary
action against appraisers who violate the Uniform Standards of Professional Appraisal
Practice. In fiscal year 2002, the Board received 222 complaints.
􀁺􇩒 Registering property tax agents—The Board is required to register property tax agents,
who advocate for property owners involved in property valuation matters with the county
assessor. As of January 2003, there were 292 registered property tax agents.
Personnel:
The Board consists of the following nine Governor-appointed
members, who may serve a maximum of two 3-year terms:
􀁺􇩆 Four members must be appraisers.
􀁺􇩏 One member must be a property tax agent.
􀁺􇩏 One member must be employed by a lending institu-tion
that purchases or makes use of commercial or
residential appraisals.
􀁺􇩔 Three must be members of the public.
The Board is authorized four full-time equivalent (FTE) posi-tions,
which were filled as of May 2003.
Facilities and equipment:
The Board leases space from the Department of
Administration in a state-owned building at 1400 West
Washington Street in Phoenix. In addition to typical office
equipment such as furniture and staff computers, the Board
owns ten laptop computers that board members and an
Assistant Attorney General use at meetings.
PROGRAM FACT SHEET
Arizona Board of Appraisal
Program revenue:
Fiscal Years 2001, 2002, and 2003 a
Office of the Auditor General
a Licensing revenues fluctuate significantly between fiscal years
because most of the Board’s licensees renew their licenses in
odd-numbered years. In addition, licensing fees increased by
$100 for new licenses and by $200 for renewals as of December
1, 2000. These increases were in effect for only 7 months in fis-cal
year 2001; consequently, projected licensing revenues are
significantly higher for 2003.
b Fiscal year 2003 revenues are estimates.
$0
$100,000
$200,000
$300,000
$400,000
$500,000
$600,000
FY 2001 FY 2002 FY 2003
$395,159
$292,443
$595,400 b
Mission:
The Board’s mission is to promote quality real estate appraisal in Arizona that protects the health,
safety, and welfare of the public.
Board goals:
1. To ensure that license/certification is granted only to candidates who are competent
and who meet the Appraisal Qualification Board standards and state standards, and
adhere to the current Uniform Standards of Professional Appraisal Practice.
2. To efficiently process applications and license/certify appraisers.
3. To expedite investigation of complaints and provide remedial discipline or take stronger
regulatory measures when necessary to protect the public from incompetent and
unethical conduct. (This goal is worded to “provide remedial discipline”; however, the
Board has statutory authority to take remedial or disciplinary action.)
4. To maintain up-to-date lists of all licensed and certified real estate appraisers, all regis-tered
property tax agents, and all approved qualifying and continuing education cours-es
and providers.
Adequacy of goals and performance measures:
Although the Board’s goals appear to be reasonably aligned with its mission, auditors identified
some problems with the Board’s performance measures. For example:
􀁺􇩔 The Board has efficiency measures for timeliness of applications and complaints.
However, it does not currently collect information such as the date an application is
received or approved, or the date that a complaint is closed in a database, but rather
reports only estimates.
􀁺􇩔 The Board has an outcome measure under its third goal to report on individuals who
recidivate after they have been disciplined, but the Board does not adequately define
recidivism. The Board should clarify its definition to include all repeat offenders instead
of only those who commit the same violation twice. Further, staff must manually identify
these individuals and research individual complaint files to evaluate the Board’s per-formance.
The Board should maintain this information in its database.
􀁺􇩔 The Board reports a rating for customer satisfaction based on a scale from 1 to 8.
However, the rating number is based on staff’s perception of public and appraiser sat-isfaction
with the Board’s performance, rather than on survey results.
􀁺􇩔 The Board has not appropriately classified all of its performance measures. For
instance, the Board’s performance measure on disciplinary actions taken during a year
is classified as an efficiency measure, but this measure should be classified as an out-put
measure because the numbers of actions are not assessed against other meas-ures,
such as timeliness.
State of Arizona
The Office of the Auditor General has conducted a performance audit of the Arizona
Board of Appraisal pursuant to Arizona Revised Statutes (A.R.S.) §32-3604(J) and
under the authority vested in the Auditor General by A.R.S. §41-1279.03. Unlike most
state agencies, the Board does not receive a Sunset review to determine if the
agency should be continued, because each state is required by federal statute to
have an agency that regulates real estate appraisers. However, the Auditor General’s
Office reviewed the Board in 1998 in response to a Joint Legislative Audit Committee
resolution. After that review, the Legislature established a 10-year review cycle for the
Board with the first review due by December 2004.
The Arizona Board of Appraisal was established in 1990 in response to the federal
Financial Institutions Reform, Recovery, and Enforcement Act of 1989, which required
federally regulated financial institutions to use licensed or certified appraisers for real
estate-related transactions, and allowed states to establish agencies to regulate
them. Real estate appraisers value, or perform appraisals of, all types of real proper-ty,
including homes, buildings, and land. The Board’s responsibilities include licens-ing
real estate appraisers, resolving complaints regarding appraisers, and disciplin-ing
appraisers when violations of standards and statutes are determined. The Board
consists of nine Governor-appointed members, including four appraisers, three pub-lic
members, a property tax agent, and a member who must be employed by a lend-ing
institution. The Board derives most of its revenues from licensing and certification
fees, and remits 10 percent of its revenues to the General Fund.
Board needs to improve its complaint process and seek
statutory authority to recover costs (see pages 9 through
13)
Overall, the Board’s complaint-handling process has improved since the the Auditor
General’s 1998 report (see Report No. 98-6). For example, the Board has begun
using contract investigators in place of volunteer investigators and has reduced its
backlog of complaints. In addition, the Board is processing most complaints in a
Office of the Auditor General
SUMMARY
page i
timely manner, and based on a review of the complaint files of four appraisers with
multiple complaints, appears to take appropriate disciplinary action for subsequent
offenses.
Although the complaint process has improved, it still allows a board member to act
both to investigate a complaint and to participate with other board members in adju-dicating
the complaint. The current process includes an initial file review during which
one of the appraiser board members presents the complaint to the Board based on
his or her review of the available evidence. The board member then recommends
whether the complaint should be dismissed or investigated further. Because of this
participation in the investigation, the board member’s impartiality in making future
adjudicatory decisions is compromised. Further, the Board’s initial review process
conflicts with the Attorney General’s Arizona Agency Handbook, which implies that
board members involved in adjudicating a complaint should not also participate in
investigating the complaint.
To avoid even the appearance of bias, the Board needs to separate the two func-tions.
The Board could modify its current review procedure to require the member
who presents the complaint to the Board to refrain from making motions or voting on
adjudicatory decisions, such as dismissal, remedial action, or discipline. This option
would separate the two functions but would not require additional costs to imple-ment.
The Board could also decide to send all complaints first to an in-house or con-tract
investigator for review and investigation. Although this option would eliminate
any board members acting in an investigating capacity, it would require additional
monies to implement. The Board sent 19 of the 104 complaints it received between
July and December 2002 to an investigator. According to the Board, cases might be
sent to an investigator if they appear to involve multiple violations.
Regardless of the option chosen, the Board should request statutory authority to
recover investigative and hearing expenses arising from complaints that result in dis-ciplinary
action. The Board already has this authority for the property tax agents it reg-isters,
but not for the appraisers it regulates. This authority should assist the Board in
offsetting its complaint-handling costs. At least nine other Arizona regulatory boards
have statutory authority to recover investigative and/or hearing costs from licensees
who have violated board regulations and statutes. However, to assist the Board of
Appraisal in cost recovery as well as other budget decisions, the Board needs to bet-ter
track its complaint-handling costs. The Board currently lacks a system that can
capture costs on a case-by-case basis.
State of Arizona
page ii
Board needs to provide complete and accurate com-plaint
information (see pages 15 through 18)
Although the Board has implemented a public information policy, additional actions
are needed to ensure the public receives complete and accurate information about
complaints. Auditors received incomplete complaint information for all five telephone
inquiries that they made about appraisers. For example, two of the inquiries regard-ed
appraisers who were on probation, but the callers were not informed that either
appraiser was on probation. The Board needs to ensure staff are fully trained on how
to provide such information. Another caller was not informed of the nature of the com-plaint
against the appraiser, perhaps because staff currently must determine how to
classify complaints on their own. One way to ensure that the public receives this infor-mation
would be to adopt a system the Board has considered implementing for clas-sifying
complaints so that staff can more easily describe the nature of complaints.
Finally, the Board is not informing callers about letters of remedial action, which it
uses to warn an appraiser to change his or her practice. Although the Board consid-ers
these complaints to be dismissed, public record laws require that information
about such letters be made available to the public.
Office of the Auditor General
page iii
State of Arizona
page iv
Office of the Auditor General
TABLE OF CONTENTS
continued
1
9
9
10
11
11
13
15
15
16
17
18
Introduction & Background
Finding 1: Board needs to improve its complaint
process and seek statutory authority to recover costs
Complaint process has improved since 1998
Current process does not separate investigation from adjudication
Board should modify its complaint process
Board should seek statutory authority to recover costs
Recommendations
Finding 2: Board needs to provide complete and accu-rate
complaint information
Public not provided with complete complaint information
Additional steps needed to ensure complete information provided
Information needed about letters of remedial action
Recommendations
Agency Response
page v
State of Arizona
TABLE OF CONTENTS
Tables:
1 Number of Licensed and Certified Appraisers with Education and
Experience Requirements
As of January 2003
2 Statement of Revenues, Expenditures, and Changes in Fund
Balance
Years Ended or Ending June 30, 2001, 2002, and 2003
(Unaudited)
Figure:
1 Number of Complaints Received
Years Ended June 30, 2000, 2001, and 2002
3
6
4
concluded
page vi
The Office of the Auditor General has conducted a performance audit of the Arizona
Board of Appraisal pursuant to Arizona Revised Statutes (A.R.S.) §32-3604(J) and
under the authority vested in the Auditor General by A.R.S. §41-1279.03. Unlike most
state agencies, the Board does not receive a Sunset review to determine if the
agency should be continued, because each state is required by federal statute to
have an agency that regulates real estate appraisers. However, the Auditor General’s
Office reviewed the Board in 1998 in response to a Joint Legislative Audit Committee
resolution. After that review, the Legislature established a 10-year review cycle for the
Board, with the first review due by December 2004.
Board history and purpose
The Arizona Board of Appraisal was established in 1990 in response to changes in
federal banking regulations. Specifically, following the savings and loan crisis of the
late 1980s, Congress passed the Financial Institutions Reform, Recovery, and
Enforcement Act of 1989. The law requires federally regulated financial institutions,
such as federally insured banks, to use state certified or licensed appraisers for real
estate-related transactions, and allows all states to establish regulatory agencies for
the licensing and certification of real estate appraisers.1 Real estate appraisers value,
or perform appraisals of, all types of real property, including homes, buildings, and
land. For example, when an individual purchases a home, the mortgage lender will
request that an appraiser value the home in order to ensure that the home’s value
and the mortgage amount are comparable. The Board’s mission is to promote qual-ity
real estate appraisal in Arizona that protects the health, safety, and welfare of the
public.
The federal law also established that appraisers should operate within defined stan-dards
of professional practice, which are developed and revised by a nonprofit edu-cational
organization called the Appraisal Foundation. These standards, known as
the Uniform Standards of Professional Appraisal Practice, guide all real estate
appraisers in Arizona and throughout the United States and require, in part, that
appraisers act independently to determine the value of real property, use appropriate
Real estate appraisers
value homes, buildings,
and land.
1 Federal regulatory agencies include the Federal Deposit Insurance Corporation (FDIC), the National Credit Union
Administration, the Office of Thrift Supervision, the Board of Governors of the Federal Reserve System, and the Office of
the Comptroller of the Currency.
Office of the Auditor General
INTRODUCTION
& BACKGROUND
page 1
methods, and keep for 5 years all materials used in producing an appraisal. In addi-tion,
through its Appraiser Qualifications Board, the Appraisal Foundation sets the
minimum education and experience requirements for real estate appraisers. Arizona
has adopted the uniform standards and the appraiser qualifications in statute (A.R.S.
§32-3605(B)).
Finally, the federal law established the Appraisal Subcommittee, which reviews
states’ regulatory agencies on a 3-year cycle. The subcommittee focuses on how
states’ agencies operate within federal laws and standards. The Arizona Board’s
most recent review was completed in October 2002. The review identified some
minor issues with the Board’s operations, such as the need to submit all disciplinary
actions to the Appraisal Subcommittee and the need to correct inaccurate references
in its regulations. The Board responded to the Appraisal Subcommittee and devel-oped
a plan to address all of the issues identified.
Board responsibilities
The Board’s primary functions are licensing real estate appraisers and resolving
complaints regarding appraisers. It also disciplines appraisers when violations of
standards and statutes are determined. In addition, statute requires the Board to reg-ister
property tax agents who represent property owners in disputes with county
assessors’ offices.
􀁺􇩌 Licensing—To ensure quality real estate appraisal in Arizona, the Board issues
licenses to qualified appraisers. As of January 31, 2003, there were over 1,700
active appraisers. To become licensed, a candidate must first submit an appli-cation
to the Board. Under board rules, the Board has 90 days to complete a
review of the candidate’s application. Auditors determined that the Board
reviews applications in an average of 26 days, and actual days for the review
ranged from 5 days to 46 days. Once the Board has reviewed the application,
the candidate then has up to 1 year to complete a qualifying exam in order to
receive a license.
Currently, the Board licenses or certifies three types of appraiser classifications
defined by the Appraiser Qualifications Board: licensed real property appraiser,
certified residential real property appraiser, and certified general real property
appraiser. As shown in Table 1 (see page 3) the appraisers’ classifications vary
in terms of scope of practice, education, and experience requirements, and
each subsequent level of license builds on the previous one, requiring greater
education and experience. Licenses and certifications must be renewed every 2
years, and to remain active, an appraiser must complete at least 14 hours of
continuing education every year. The Board also provides temporary licenses
and certifications for out-of-state appraisers and has reciprocal agreements with
State of Arizona
page 2
Board fees are currently $400
for an initial application plus
$100 for the examination fee
and $425 for a renewal.
Nonresidential temporary
licenses or certificates are
$150.
24 states to license or certify real estate appraisers already licensed in these
other states without further education or testing.
Many states regulate appraiser trainees, a fourth classification defined by the
Appraiser Qualifications Board. The Board does not currently regulate apprais-er
trainees, but plans to implement regulations for this category in the future. The
Board intends to begin the process of changing its rules to include trainees after
the Appraisal Qualifications Board publishes new policies on monitoring
trainees in the summer of 2003. Additionally, the Board plans to seek statutory
authority to assess trainees a nominal fee to cover the administrative costs asso-ciated
with regulating trainees.
􀁺􇩃 Complaints—The Board is also responsible for handling complaints made
against appraisers. Homeowners are the most frequent source of complaints,
but many also come from appraisers, such as review appraisers. Review
appraisers develop and communicate an opinion or conclusion about the qual-ity
of another appraiser’s work as part of business, government, or legal situa-tions.
When resolving complaints, the Board must determine whether apprais-ers
violated the Uniform Standards of Professional Appraisal Practice. The
Board does not have the authority to address complaints regarding fees.
Between fiscal years 2000 to 2002, the Board received over 550 complaints (see
Office of the Auditor General
page 3
Classification
Scope of Practice
Education1
Experience
Number of
Active
Appraisers
Licensed real property
Appraiser
Typical 1 to 4 family residential units
valued under $1 million and complex
residential units valued under
$250,000
90 hours
2,000 hours
464
Certified residential real
property appraiser
1 to 4 family residential units without
regard to value or complexity
120 hours
2,500 hours
661
Certified general real
property appraiser
All types of real property
180 hours
3,000 hours
632
Total appraisers
1,757
Table 1 Number of Licensed and Certified Appraisers with
Education and Experience Requirements
As of January 2003
1 Includes seven hours of class time on the Uniform Standards of Professional Appraisal Practice.
Education can be cumulative for higher classification levels.
Source: Auditor General staff analysis of the Arizona Board of Appraisal’s licensing database as of January 31, 2003, and the
appraiser qualification criteria developed by the Appraisal Qualification Board of the Appraisal Foundation as of January
2003.
Fee disputes are outside
the Board’s authority.
Figure 1 for the number of complaints received each fis-cal
year). In addition, the Board received 104 complaints
during the first half of fiscal year 2003.
The Auditor General’s Office has found that Arizona regu-latory
boards should typically resolve complaints in 180
days or less. Auditors reviewed a random sample of 79
complaints received between July 2000 and December
2002 and found that the Board resolved approximately 53
percent of these complaints in 180 days or less, with 198
days being the average time it took the Board to resolve
a complaint. However, the Board has a federal standard
that recommends complaints be resolved within 12
months. Of the 79 cases auditors reviewed, all but 7 were
resolved within 1 year. Delays in these cases were due to
circumstances beyond the Board’s control, such as an
appraiser’s family member becoming ill or being unable
to find an investigator.
􀁺􇩄 Discipline—If the Board identifies a violation of Appraisal Standards, it has three
disciplinary options available by statute, including censure, suspension, and
revocation. Statute also indicates that the Board can otherwise discipline
appraisers, and the Board has interpreted the statute to mean that it can define
other disciplinary options in its rules.1 As noted in the text box on this page, the
Board has defined probation as a disciplinary option in its rules. As a part of pro-bation,
the Board can require that an appraiser complete additional appraisal
education classes to keep his or her license, or restrict the appraiser’s practice
to certain types of appraising.
The Board has also developed a mentorship program as part of its probation-ary
discipline. In some complaints, the Board may determine that the appraiser
could improve with additional guidance. In these cases, the Board will require
mentorship for the appraiser from someone who has the same type of license
and works in the same geographic area. The mentor reviews all of the apprais-er’s
work and also works with the disciplined appraiser to ensure that the defi-ciencies
identified in the complaint are corrected.
Sometimes appraisers receive additional complaints after being disciplined by
the Board. Auditors reviewed the complaint files of four appraisers who received
subsequent complaints and found that the Board took appropriate discipline
against these four appraisers for their subsequent offenses. For instance, in the
initial complaint of one appraiser, the Board and an appraiser agreed to a pro-bationary
period with a mentor to settle a complaint. When the appraiser
received additional complaints, the Board suspended the appraiser’s license for
60 days and increased the probationary period by 2 years, with at least 6
1 A.R.S. §32-3605(B).
State of Arizona
page 4
161
181
222
0
50
100
150
200
250
2000 2001 2002
Figure 1 Number of Complaints Received
Years Ended June 30, 2000, 2001, and 2002
Source: Auditor General staff analysis of Arizona Board of Appraisal complaint
database as of February 2003.
The Board has several disciplinary
options available
Defined in Statute:
1. Censure
2. Suspension
3. Revocation
Defined in Rule:
Probation
􀁺􇩅 Education
􀁺􇩍 Mentorship
􀁺􇩒 Restriction of practice
Source: A.R.S. §32-3605(B) and A.A.C. R4-46-301.
months of the probationary period to include mentorship. After an additional
complaint, the Board suspended the appraiser’s license for 2 years or until he
could show the Board that he was mentally and physically able to perform
appraisals.
In 2001, the Legislature also provided the Board with a nondisciplinary option.
When the Board finds a violation or mistake that does not warrant discipline,
such as omitting the property tax costs in the appraisal report, the Board can
issue a letter of remedial action instructing the appraiser not to repeat the mis-take.
􀁺􇩐 Property tax agents—The Board is also statutorily required to register property
tax agents. As of January 31, 2003, there were 292 registered tax agents who
act on behalf of property owners involved in property valuation matters with the
county assessor. Tax agents must pay an initial $50 registration fee and a $25
renewal fee to register with the State to represent property owners. However,
they do not have to meet any licensing requirements, such as education, and
the Board has limited jurisdiction over their actions.
Staffing and budget
The Board consists of nine volunteers who are appointed by the Governor, including
four appraisers. The remaining five board members include a registered property tax
agent, who can also be an appraiser; an employee of a lending institution that pur-chases
or makes use of either commercial or residential appraisals and who cannot
be an appraiser; and three public members. Board members serve for 3-year terms
and may serve for no more than two consecutive terms.
The Board is authorized for four full-time staff positions, which were filled as of May
2003. These positions include an executive director responsible for operations, a reg-ulatory
compliance administrator responsible for complaint procedures, an adminis-trative
assistant responsible for processing applications and accounts payable, and
the administrative secretary, who maintains the front office and telephones and
assists other staff when necessary. In addition, the Board contracts with nine investi-gators
to perform investigations of complaints on an as-needed basis.
As illustrated in Table 2 (see page 6), the Board estimates revenues of approximate-ly
$595,400 for fiscal year 2003 and expenditures of $462,500. The Board mostly
derives its revenue from licensing and certification fees. It remits 10 percent of its rev-enue
to the General Fund, and the rest is deposited into the Board of Appraisal Fund.
In both fiscal years 2001 and 2002, the Board’s expenditures outpaced its revenues
The Board took appro-priate,
progressive disci-plinary
action against
four repeat offenders.
Office of the Auditor General
page 5
in part due to reduced fees and in part because most of the Board’s licensees renew
their licenses in odd-numbered fiscal years. In response to the Auditor General’s
1998 audit report (Report No. 98-6, Finding IV), the Board reduced its fees in order
to reduce its fund balance, which was nearly four times its annual budget. The
Board’s fund balance decreased, and in December 2000, the Board raised its fees
to its statutory limits.
State of Arizona
page 6
2001 2002 20031
Revenues:
Licenses 2 $376,144 $272,801 $576,203
Charges for goods and services 19,015 15,594 15,891
Other 4,048
Total revenues 395,159 292,443 592,094
Expenditures: 3
Personal services and employee-related 197,553 189,410 240,419
Professional and outside services 186,604 167,865 128,017
Travel 10,324 11,041 5,930
Other operating 49,964 72,521 69,551
Equipment 14,387 3,009 11,184
Total expenditures 458,832 443,846 455,101
Excess of revenues over (under) expenditures (63,673) (151,403) 136,993
Other financial uses:
Operating transfers out 7,806 6,803 3,500
Remittances to the State General Fund 4 39,753 28,749 60,694
Total other financing uses 47,559 35,552 64,194
Excess of revenues over (under) expenditures and other financing
uses (111,232) (186,955) 72,799
Fund balance, beginning of year 835,899 724,667 537,712
Fund balance, end of year $724,667 $537,712 $610,511
Table 2 Statement of Revenues, Expenditures, and Changes in Fund Balance
Years Ended June 30, 2001, 2002, and 2003
(Unaudited)
1 Fiscal year 2003 amounts recorded after June 30 were not available for this report and are not included.
2 Licensing revenues fluctuate significantly between fiscal years because the majority of the Board’s licensees
renew their licenses in odd-numbered years. In addition, licensing fees increased $100 for new licenses and $200
for renewals as of December 1, 2000. These increases were in effect for only 7 months in FY 2001; consequent-ly,
projected licensing revenues are significantly higher for 2003.
3 Includes administrative adjustments from the prior year.
4 As a 90/10 agency, the Board remits 10 percent of its revenues to the State General Fund.
Source: Auditor General staff analysis of the Arizona Financial Information System’s (AFIS) Revenues and Expenditures by Fund, Program,
Organization, and Object and Trial Balance by Fund reports for the years ended June 30, 2001 and 2002; and the AFIS Accounting
Event Extract File for the year ended June 30, 2003.
Audit scope and methodology
This audit focused on the Board’s efficiency and effectiveness in licensing apprais-ers,
investigating and resolving complaints, and providing complaint history informa-tion
to the public. This report includes two findings and recommendations in the fol-lowing
areas:
􀁺􇩔 The Board needs to further separate its investigation and adjudication process-es
to avoid the appearance of bias in resolving complaints, and seek statutory
authority to recover investigation and hearing costs.
􀁺􇩔 The Board needs to provide complete and accurate complaint information.
Auditors used a variety of methods to obtain information on the Board and assess its
efficiency and effectiveness, including reviewing and following up on findings in the
Auditor General’s 1998 audit report (Report No. 98-6), reviewing Arizona Revised
Statutes, the Board’s administrative rules, and appraisal standards, and interviewing
board members, staff, and federal reviewers. In addition, the following specific meth-ods
were used:
􀁺􇩔 To determine the timeliness of the licensing and complaint processes, auditors
reviewed 31 application files and 79 complaint files that the Board received dur-ing
fiscal years 2001 to 2003 and calculated the processing times for these files.
􀁺􇩔 To determine whether the Board is providing an appropriate amount of discipline
to repeat offenders, auditors reviewed the complaint files for four appraisers who
had received multiple complaints and the Board’s actions against these
appraisers.
􀁺􇩔 To determine whether the Board is appropriately separating its investigation and
adjudication processes, auditors reviewed the Attorney General’s Arizona
Agency Handbook, attended board meetings, and interviewed board staff, the
Board’s Assistant Attorney General, and several board members. In addition,
auditors contacted seven other Arizona regulatory boards regarding their inves-tigation
and adjudication procedures, and received input from the Auditor
General’s legal counsel.1
􀁺􇩔 To determine standards for recovering costs associated with complaint han-dling,
auditors conducted a search of Arizona Revised Statutes and identified
nine boards that have statutory authority to recover costs. Auditors contacted
1 Auditors contacted five Arizona regulatory boards that have the statutory ability to recover all or some of the costs of their
disciplinary process: The Arizona Medical Board, Board of Chiropractic Examiners, Board of Cosmetology, Board of
Funeral Directors and Embalmers, and Board of Osteopathic Examiners. Auditors contacted two additional boards that
do not recover costs: the Board of Dental Examiners and the Naturopathic Physicians Board of Medical Examiners,
because they use contract investigators as part of their complaint investigation process.
Office of the Auditor General
page 7
five of these boards regarding their ability to recover costs. Auditors also col-lected
information on the range of costs the Board incurs for investigation and
adjudication by requesting investigation costs from the Board, requesting formal
hearing costs from the Office of Administrative Hearings, and interviewing a
board investigator and staff.
􀁺􇩔 To determine whether the Board provides adequate and appropriate information
to the public, auditors reviewed the Board’s policies and procedures on public
information and compared policy requirements to information received from five
telephone calls auditors made to the board office requesting information.
Auditors also reviewed the Board’s complaint and licensing files for complete-ness,
interviewed the Board’s Assistant Attorney General, and sought input from
the Auditor General’s legal counsel.
This audit was conducted in accordance with government auditing standards.
The Auditor General and staff express appreciation to the Board and its staff for their
cooperation and assistance throughout the audit.
State of Arizona
page 8
Board needs to improve its complaint process
and seek statutory authority to recover costs
Although the Board has improved many aspects of its complaint process since its
previous audit, the Board needs to make an additional change and could benefit
from additional statutory authority in cost recovery. First, the Board needs to separate
further its investigation and adjudication functions to ensure that it appears fair and
impartial. To resolve this problem, the Board could modify its current process, which
would not cost any money, or implement a process similar to other Arizona regula-tory
boards. The Board should also request statutory authority to recover investiga-tive
and formal hearing costs to help address the costs associated with complaint
handling.
Complaint process has improved since 1998
Overall, the Board’s complaint-handling process has improved since the Auditor
General’s 1998 audit report (see Report No. 98-6, Finding I and II). At that time, the
Board was using volunteer investigators to investigate complaints and had a sub-stantial
backlog of open complaints. The Board has discontinued its use of volunteer
investigators and now uses contract investigators. The investigators are allowed 30
to 60 days to return an investigation depending on the investigation’s complexity, the
number of properties involved, and the amount of travel that may be required.
Currently, the Board does not report any difficulties in getting timely investigative
reports.
The Board has also reduced its backlog of open complaints. In 1998, the Board had
a backlog of about 100 complaints, half of which had been open over 300 days. As
of February 2003, the Board had only 10 complaints regarding appraisers that have
Office of the Auditor General
FINDING 1
page 9
been open longer than 12 months. In addition, as mentioned in the Introduction and
Background (pages 1 through 8), the Board handles most complaints in a timely
manner and appears to take appropriate disciplinary action against appraisers with
multiple complaints.
Current process does not separate investigation from
adjudication
Although the process has improved overall, the Board needs to further separate its
investigation and adjudication functions. The current process allows board members
who evaluate evidence in a complaint and present this information in board meetings
to also vote on the complaint’s resolution. This lack of separation compromises the
board member’s impartiality and is not in line with the Attorney General’s guidelines
for regulatory boards.
Board members serve as both investigators and adjudicators—The
current complaint-handling process cannot ensure that all board members remain
objective, because under the current procedure, one member both reviews com-plaint
evidence (investigation) and participates in the Board’s decisions on the out-come
(adjudication). The Auditor General’s 1998 audit found a similar problem, and
although the Board has since made changes to the complaint-handling process, the
changes have not gone far enough in this regard. The first step in the complaint
process is an initial file review during which an appraiser board member conducts an
in-depth review of all evidence in the case and identifies the potential violations sup-ported
by the evidence. The board member then presents this information to the full
Board and recommends whether to dismiss the complaint or refer it for further inves-tigation.
Because of this participation in the investigation, the board member’s impar-tiality
in making a future adjudicatory decision such as dismissal, remedial action, or
discipline is compromised.
The review process conflicts with Attorney General advice—The
Board’s practice also conflicts with standards established by the Arizona Attorney
General’s office. Specifically, the Attorney General’s Arizona Agency Handbook
implies that decision-makers such as board members involved in adjudicating a
complaint should not participate in investigating a complaint. Because the appraiser
board member reviews evidence as an expert and cites violations, he or she
becomes part of the investigation and therefore should not be part of the adjudica-tion.
The Board’s lack of separation between the investigative and adjudicative
processes can give the appearance that the Board is not resolving complaints fairly.
The Arizona Agency
Handbook implies that
decision-makers not be
involved in complaint
investigations.
State of Arizona
page 10
Board should modify its complaint process
To avoid the appearance of bias, the Board needs to change how its members par-ticipate
in the complaint process. The least costly option for the Board is to modify
its current procedure to require that the member who presents the complaint infor-mation
to the Board in the initial review not be part of deciding what adjudicatory
action to take. This member could participate in presenting complaint information,
discussing the complaint with board members, and making a recommendation to
dismiss the complaint or send it to investigation. However, the board member would
recuse himself or herself from making motions or voting on both current and future
adjudicatory decisions on the complaint such as dismissal, remedial action, or dis-cipline.
This option would allow the Board to separate its investigation and adjudica-tion
functions without incurring additional costs.
The Board could consider another option to separate its investigation and adjudica-tion
functions; however, this option would be more costly for the Board and more dif-ficult
to implement. At least seven other Arizona regulatory boards have staff or con-tract
investigators who investigate all complaints prior to board review. For instance,
the Board of Cosmetology has a staff investigator who investigates complaints
before the board reviews them. The Board of Dental Examiners assigns all com-plaints
to a contract investigator before board review. Using an in-house or contract
investigator would allow the Board to completely separate its investigation and adju-dication
functions by eliminating the initial review. However, it would also result in
additional costs to hire an in-house investigator or send all complaints to a contract
investigator. Currently, most complaints do not go to an investigator. For example,
between July and December 2002, the Board sent only 19 out of 104 complaints to
an investigator. According to the Board, a complaint might be sent to an investigator
if a large number of potential standards violations are identified. However, if the com-plaint
involves minor violations, it would not be sent to an investigator.
Board should seek statutory authority to recover costs
The Board should request statutory authority to recover investigative and hearing
expenses arising from complaints that result in disciplinary action. The Board already
has this authority for the property tax agents it registers but not for the appraisers it
regulates. This authority should assist the Board in offsetting its complaint-handling
costs. Some other Arizona regulatory boards already have this authority. However, to
assist it in cost recovery, as well as other budget decisions, the Board needs to track
its complaint-handling costs on a case-by-case basis.
Office of the Auditor General
page 11
Reviewing board mem-ber
should be recused
from future adjudicatory
decisions.
Complaint-handling costs can be high—The Board should seek statutory
authority to recover some or all of the complaint costs from appraisers found in vio-lation
of the appraisal standards. Doing so would assist in offsetting expenses. The
Board’s complaint workload has increased by 38 percent, from 161 complaints
received in fiscal year 2000 to 222 in 2002. To handle complaints, the Board incurs
both investigative and formal hearing costs, among other items. Current costs for
investigations vary by complaint. For example, the investigator who was used most
often in fiscal year 2003 (through April 2003) charged an average cost of about
$1,400 per complaint, with costs per complaint ranging from $600 to $2,600.
Additionally, the Board uses the Office of Administrative Hearings (OAH) for some for-mal
hearings. In this capacity, OAH holds hearings before an administrative law
judge in which the appraiser’s and the Board’s representatives present evidence
regarding the complaint. After testimony is heard, the judge makes a recommenda-tion
on the case to the Board, which the Board may either accept or reject. Over the
past several years, the Board has increased its use of OAH. In fiscal year 2001, OAH
heard five formal hearings for the Board. That number rose to 13 in fiscal year 2002
and to 18 in the three-quarters of fiscal year 2003. While OAH’s annual bills for hear-ings
vary according to the previous year’s costs, they can be significant, depending
on the time individual complaints consume. For example, the cost for one OAH hear-ing
billed in fiscal year 2003 was about $1,150. However, the cost for a longer, more
complex case, which had several hearings in fiscal years 2001 and 2002, was almost
$10,000.
Some other Arizona boards can recover costs—At least nine Arizona
boards have statutory authority to recover investigative and/or hearing costs from
licensees who have violated board regulations and statutes.1 Although there is no
clear pattern as to the specific expenses these boards define as investigative or hear-ing
costs, seven boards can collect formal hearing costs from their licensees. Three
of the boards, the Board of Chiropractic Examiners, the Board of Cosmetology, and
the Board of Funeral Directors and Embalmers, can also require licensees to pay
investigative costs. The Board of Funeral Directors and Embalmers also may assess
the licensee expenses incurred with conducting an informal interview.
Tracking costs is necessary for cost recovery—To have sufficient informa-tion
to recover some of its complaint-handling expenses, the Board needs to begin
tracking its costs per case. Although the Board has information on the hourly rates of
contract investigators and receives invoices from them, it does not keep track of
investigative costs on a case-by-case basis. Additionally, the Board does not track
formal hearing costs for individual cases. Formal hearing costs would include OAH
costs and may also include the costs of an Assistant Attorney General who repre-sents
the State on the complaint, investigator testimony costs, and court transcripts
costs. In addition, the Board needs to identify board-specific costs, such as costs for
subpoenas. Depending on the extent of the statutory authority the Board seeks, it
State of Arizona
page 12
The Board needs to
track complaint-han-dling
costs on a case-by-
case basis.
Statutory authority to
recover costs could off-set
complaint-handling
expenses.
1 Arizona Medical Board, Board of Athletic Training, Board of Chiropractic Examiners, Board of Cosmetology, Board of
Optometry, Board of Osteopathic Examiners in Medicine and Surgery, Board of Physical Therapy, Board of Funeral
Directors and Embalmers, and Regulatory Board of Physician Assistants.
should determine which complaint costs it specifically needs to track to appropriate-ly
assess expenses.
Cost information can also guide the Board in budget decisions—The
Board also can use complaint-handling cost information to assist in making deci-sions
on budget issues. For instance, tracking costs would allow the Board to deter-mine
better whether it would be feasible to hire a staff investigator under its current
budget. Additionally, the Board’s fund balance has decreased since fiscal year 2001,
and the Board is considering raising fees to ensure that it maintains a fund balance.
If it is allowed to recover costs from complaint handling, it can use cost information
to determine how much it will need to raise fees.
Recommendations
1. The Board should revise its complaint-handling process to ensure that it remains
fair and impartial by doing one of the following:
a. Requiring board members who review and present evidence on complaints
to recuse themselves from voting on any adjudicatory decisions.
b. Referring all complaints to a contract investigator or in-house staff investi-gator
for investigation before any board review.
2. The Board should request statutory authority to recover investigative costs and
the costs of hearings for complaints against appraisers that result in disciplinary
action.
3. The Board should define the specific costs associated with complaint handling
and track these costs by individual complaint.
Office of the Auditor General
page 13
State of Arizona
page 14
Board needs to provide complete and accurate
complaint information
Although the Board has implemented a policy that specifies the information it will
make available to the public regarding complaints, improvements are needed to
ensure that this policy is followed. Auditors received incomplete information in each
of the five telephone inquiries they made about appraisers with complaints. The
Board needs to ensure staff are fully trained on how to provide complaint informa-tion.
The Board should also consider adopting a system for classifying complaints so
that staff can more easily provide information about the nature of complaints, as
required by its policy. In addition, the Board is currently keeping letters of remedial
action confidential, even though public record laws require that these should be
made available to the public.
Public not provided with complete complaint information
Although the Board has made improvements regarding public access to information
since the Auditor General’s 1998 audit report (see Report No. 98-6, Finding III), the
public still does not receive complete information on complaints. The previous audit
found that board staff did not consistently provide the public with complete and
accurate information by telephone. To address this concern, the Board implemented
a public information policy, which requires that the public receive information on the
disposition and nature of the complaints and contains examples of what information
could be given regarding the nature of the complaint. It is important that the public
receive information on both complaint disposition and nature. Disposition information
explains to the public the sanctions that the Board imposed on the appraiser, such
as the appraiser’s consent to being on probation. Information on the nature of com-plaints
explains to the public what type of violation the appraiser committed, such as
a major breach in ethics.
Office of the Auditor General
page 15
FINDING 2
State of Arizona
page 16
Auditor General staff made telephone calls to the Board to request complaint histo-ries
on five appraisers, but in each case, board staff did not provide the full informa-tion
required by the Board’s public information policy. In some cases, the number
and type of complaint actions taken against the appraiser was not explained; in oth-ers,
important information was not divulged about the nature of the complaint.
Specifically:
􀁺􇩉 Incomplete complaint histories—In three instances, board staff did not provide
complete and accurate information on the appraisers’ complaint histories. Two
of the calls regarded appraisers who were on probation, but the callers were not
informed that either appraiser was on probation. Rather, in one instance, the
caller was told that the appraiser had received one anonymous complaint that
was still under investigation, and in the second instance, the caller was told that
the Board had not received any complaints regarding that appraiser. The third
call regarded an appraiser who had one dismissed complaint. The caller was
informed that the appraiser did not have any complaints.
􀁺􇩉 Incomplete information on nature of complaint—In the two remaining calls, the
callers received complete and accurate information regarding each appraiser’s
complaint history; however, the callers received little information on the nature of
the complaints. In one instance, the caller was informed that the appraiser
received a due diligence letter for violating the appraisal standards’ competen-cy
section. The caller was also informed that the appraiser received a second
due diligence letter, but was not informed of the nature of this complaint. In a
second call, the caller was told that the appraiser had received a due diligence
letter, but that the complaint was “not serious in nature.”
Additional steps needed to ensure complete information
provided
Since the Board already has an appropriate public information policy, other meas-ures
are needed. Specifically, the Board should take two additional steps to ensure
that consumers receive complete and accurate complaint information:
􀁺􇩔 Train staff on how to provide information to the public—The Board has a small
staff and does not do any formal training on procedures. Although the Board
clarified its public information policy in April 2003 to indicate that only the exec-utive
director and the regulatory compliance administrator can provide com-plaint
history information to the public, the Board needs to ensure that all staff
understand who can provide complaint information. In addition, as new staff are
hired, the Board should ensure that they fully understand the policies and pro-cedures
regarding public information and their role in providing that information.
Board staff did not pro-vide
complete complaint
history information.
Office of the Auditor General
page 17
􀁺􇩄 Develop means for classifying complaints—One reason the public may not
receive consistent and complete information on the nature of complaints is
because the Board currently does not classify the nature of complaints and
board staff must determine on their own how to describe the nature of com-plaints.
The Board has considered implementing a set of guidelines that rank
from one to five the violations found in a complaint, with one being the least seri-ous
type of violation. Each ranking has a description of the types of violations
that it would include. For instance, a complaint that is given a rank of level 2
would be one in which a series of mistakes affected the appraisal’s credibility.
The Board should implement these guidelines now so that board staff could use
them to easily and quickly provide the public with complete and consistent infor-mation
on the nature of complaints.
Information needed about letters of remedial action
To comply with public records laws, the Board should also inform consumers about
complaints resulting in letters of remedial action. The Board received statutory
authority to take remedial action in 2001. The Board uses letters of remedial action
when it wants to warn an appraiser to change his or her practices in order to avoid
future problems. Letters of remedial action usually instruct the appraiser not to repeat
the mistake, but they may also require the appraiser to take classes. The Board
requires that complaints in which an appraiser receives a letter of remedial action be
classified as dismissed and considers a letter of remedial action nondisciplinary.
Therefore, anyone seeking information on an appraiser’s complaint history would be
told that the appraiser had a dismissed complaint, but not that they had received
remedial action.
However, according to public records laws, documentary materials made by any
government agency as a result of public business and as evidence of the organiza-tion’s
decisions are public records.1 A letter of remedial action is a public record
because it results from decisions made in an open meeting and documents the
Board’s action involving an appraiser. Thus, the Board should develop a way to
ensure that the public is also informed about letters of remedial action when seeking
information about appraisers’ complaint histories. One way to do this would be to
create two categories of dismissed complaints, one of which includes remedial
action.
The Board uses letters
of remedial action to
resolve complaints it
deems not serious in
nature.
The Board should
implement a complaint
classification system.
1 A.R.S. §§39-121.01(B) and 41-1350.
Recommendations
1. The Board should ensure all staff are fully trained on how to correctly provide
complete and accurate complaint information to callers requesting information
about appraisers’ past performance.
2. The Board should implement a method of classifying complaints that staff can
use to provide complete and accurate information about the nature of com-plaints.
3. The Board should inform the public about letters of remedial action. It could do
so by developing two categories of dismissed complaints, one being dismissed
but with a letter of remedial action sent to the appraiser.
State of Arizona
page 18
Office of the Auditor General
AGENCY RESPONSE
State of Arizona
July 30, 2003
Ms. Debra K. Davenport, CPA
Auditor General
2910 North 44th Street, Suite 410
Phoenix, AZ 85018
Re: Audit of the Arizona State Board of Appraisal
Dear Ms. Davenport:
The Board has received a final draft of your audit of the Arizona State Board of Appraisal dated July 24,
2003. Enclosed is the Board’s response to your audit. A diskette is also enclosed with this response.
The Board and its staff would like to express appreciation to your auditing staff for performing the audit
with as little disruption of the Board’s business as possible.
If you have any questions regarding the enclosure, please do not hesitate to contact me.
Sincerely,
Deborah G. Pearson
Acting Executive Director
Enclosures
RESPONSE TO FINDING 1
BOARD NEEDS TO IMPROVE ITS COMPLAINT PROCESS
AND SEEK STATUTORY AUTHORITY TO RECOVER COSTS
Audit Recommendations
1. The Board should revise its complaint-handling process to ensure that it remains fair and impartial
by doing one of the following:
a. Requiring board members who review and present evidence on complaints to recuse
themselves from voting on any adjudicatory decisions.
b. Referring all complaints to a contract investigator or in-house staff investigator for
investigation before any board review.
Board’s Response: The finding of the Auditor General is agreed to and a different
method of dealing with the finding will be implemented. To resolve any perceived conflict
of interest, the Board voted at its July, 2003, meeting to implement by December 31,
2003, a new procedure whereby complaints will not be assigned to an individual Board
member for summary at the Board meetings. Instead, staff will summarize the complaints
to be followed by open discussion, comments, recommendations, motions and voting by
all Board members. As in the past, all Board members will be furnished copies of all
complaint files for review prior to the Board meetings.
2. The Board should request statutory authority to recover investigative costs and the costs of
hearings for complaints against appraisers that result in disciplinary action.
Board’s Response: The finding of the Auditor General is agreed to and the audit
recommendation will be implemented. The Board will be approaching the legislature in
calendar year, 2004, requesting statutory authority to recover investigative and formal
hearing costs associated with complaint handling and resolution.
3. The Board should define specific costs associated with complaint handling and track these costs
by individual complaint.
Board’s Response: The finding of the Auditor General is agreed to and the audit
recommendation will be implemented. The Board has already implemented a process
whereby the costs of investigations, formal hearings before the Office of Administration,
and court reporter costs are being tracked by individual complaint.
2
RESPONSE TO FINDING 2
BOARD NEEDS TO PROVIDE COMPLETE AND
ACCURATE COMPLAINT INFORMATION
Audit Recommendations
1. The Board should ensure all staff are fully trained on how to correctly provide complete and
accurate complaint information to callers requesting information about appraisers’ past
performance.
Board’s Response: The finding of the Auditor General is agreed to and a different method
of dealing with the finding will be implemented. Of the four full-time employees, all are
new hires, except one. Because there will be a tremendous learning curve for all new staff
members and to ensure that accurate information is furnished, only the established
employee will provide callers with information about appraisers’ past performance. As
each new staff member demonstrates the ability to understand the process, he/she will be
trained on how to accurately provide callers with information.
2. The Board should implement a method of classifying complaints that staff can use to provide
complete and accurate information about the nature of complaints.
Board’s Response: The finding of the Auditor General is agreed to and the audit
recommendation will be implemented. After a complaint has been adjudicated, the Board
will classify the complaint as: (a) dismissed with no violations (nondisciplinary); (b)
dismissed with violations and a letter of remedial action (nondisciplinary); or (c) findings
of violations of USPAP, statute or rule (disciplinary). The caller will be advised of the
classification. If violations are found, information regarding the violations will be made
available to the caller either verbally or by requesting that the caller file a Public Records
Request Form to obtain a copy of the final finding. If a complaint has not been resolved,
a caller will be advised that a pending complaint exists.
3. The Board should inform the public about letters of remedial action. It could do so by developing
two categories of dismissed complaints, one being dismissed but with a letter of remedial action
sent to the appraiser.
Board’s Response: The finding of the Auditor General is agreed to and the audit
recommendation will be implemented. Although there was some initial confusion, the
public is now informed of letters of remedial action.
02-01 Arizona Works
02-02 Arizona State Lottery
Commission
02-03 Department of Economic
Security—Kinship Foster Care
and Kinship Care Pilot
Program
02-04 State Parks Board—
Heritage Fund
02-05 Arizona Health Care Cost
Containment System—
Member Services Division
02-06 Arizona Health Care Cost
Containment System—Rate
Setting Processes
02-07 Arizona Health Care Cost
Containment System—Medical
Services Contracting
02-08 Arizona Health Care Cost
Containment System—
Quality of Care
02-09 Arizona Health Care Cost
Containment System—
Sunset Factors
02-10 Department of Economic
Security—Division of Children,
Youth and Families, Child
Protective Services
02-11 Department of Health
Services—Health Start
Program
02-12 HB2003 Children’s Behavioral
Health Services Monies
02-13 Department of Health
Services—Office of Long Term
Care
03-L1 Competitive Electric Metering,
Meter Reading, and Billing
and Collections
03-01 Government Information
Technology Agency—
State-wide Technology
Contracting Issues
03-02 Registrar of Contractors
03-03 Water Infrastructure Finance
Authority
03-04 State Board of Funeral
Directors and Embalmers
03-05 Department of Economic
Security—Child Protective
Services—Foster Care
Placement Stability and
Foster Parent Communication
Performance Audit Division reports issued within the last 12 months
Future Performance Audit Division reports
Arizona State Board for Charter Schools
Department of Commerce