Performance audit, Department of Health Services, office of vital records

              PERFORMANCE AUDIT
DEPARTMENT OF HEALTH SERVICES
OFFICE OF VITAL RECORDS
Report to the Arizona Legislature
By the Auditor General
September 1989
89- 5
DOUGLAS R. NOR'TON. CPA
AUDITOR GENERAL
S T A T E OF ARIZONA
OFFICE OF THE
AUDITOR GENERAL
LINDA J. BLESSING, CPA
DEPUTY AUDITOR GENERAL
September 25, 1989
Members of the Arizona L e g i s l a t u r e
The Honorable Rose Mofford, Governor
Mr. Ted Williams, D i r e c t o r
Department ot Health Services
Transmitted herewith i s a report of the Auditor General, A Performance
Audit of the Arizona Department of Health Services! O f f i c e o f V i t a l
Records. This report i s i n response to a June 2, 1987, r e s o l u t i o n of the
Joint L e g i s l a t i v e Oversight Committee.
This report i d e n t i f i e s ways DHS can b e t t e r protect v i t a l records and
improve service to the p u b l i c . Physical s e c u r i t y for the department's
records room i s not adequate to deter i l l e g a l entry and records t h e f t .
F i r e suppression and climate c o n t r o l a l s o need improvement. In a d n i t i o n ,
the department lacks c o n t r o i s needed to prevent unauthorized use of v i t a l
records by i t s s t a f f .
The department can speed up service to the pub1 i c by issuing more
computer generated b i r t h c e r t i f i c a t e s . Time saved by using computer
records w i l l enable the department to reduce turnaround times for mail
requests. F i n a l l y , a larger w a i t i n g area i s needed to accommodate
persons request ing copies of v i t a l records.
My s t a f f and I w i l l be pleased to discuss or c l a r i f y items i n the r e p o r t .
S i n c e r e l y ,
las R . Norton
DRN : I mn
STAFF: William Thomson
Mark Fleming
Anthony James Guarino
Margaret McNamara Jackson
2700 NORTH CENTRAL AVE. a SUITE 700 0 PHOENIX, ARIZONA 85004 0 ( 602) 255- 4385
The O f f i c e o f the Auditor General has conducted a performance audit of
the Arizona Department of Health Services, O f f i c e o f V i t a l Records, i n
response to a June 2, 1987, r e s o l u t i o n of the J o i n t L e g i s l a t i v e Oversight
Committee. This audit was conducted as part of the Sunset Review set
f o r t h i n Arizona Revised Statutes ( A. R. S) 9541- 2351 through 41- 2379.
This i s the f i f t h i n a series of reports issued on the Department of
Health Services ( DHS). The report focuses on the functions of the O f f i c e
of V i t a l Records which operates w i t h i n the D i r e c t o r ' s O f f i c e .
Better Protection and Oversight
o f the State's V i t a l Records Are Needed ( see pages 5 through 12)
Adequate security of v i t a l records i s important. In March 1989, a t h i e f
broke i n t o Delaware's v i t a l records o f f i c e and s t o l e more than 1,700
blank record forms and the o f f i c i a - l s t a t e s e a l . The o f f i c e d i r e c t o r
believes the t h i e f w i I l use these materials to create and sel I
c o u n t e r f e i t b i r t h c e r t i f i c a t e s . Counterfeit records have sold f o r p r i c e s
of up to $ 1,500 each. Because Arizona's f a c i l i t y lacks adequate
s e c u r i t y , a s i m i l a r t h e f t could happen at Arizona's O f f i c e of V i t a l
Records ( OVR). The agency could g r e a t l y improve i t s physical s e c u r i t y by
i n s t a l l i n g alarms and video cameras at an estimated cost of $ 14,000.
The OVR f a c i l i t y i s also susceptible to f i r e and environmental hazards
which could damage or destroy the S t a t e ' s v i t a l records. The agency can
remedy these problems w i thout undue expense. Halon, a popular f i re
p r o t e c t i o n system, would cost OVR approximately $ 12,800, while
temperature and humidity controls would cost approximately $ 40,000.
In a d d i t i o n , l i m i t e d inventory controls and u n r e s t r i c t e d employee access
to v i t a l records and forms provide opportunity for OVR employees to make
unauthorized use of records. Weak controls may have contributed to
several recorded i n c i d e n t s o f i I legal employee a c t i v i t y . For example,
one employee was recently caught sending a c e r t i f i e d copy of a b i r t h
record to a f r i e n d without the proper request, a u t h o r i z a t i o n , o r fee.
Since v i t a l records are a valuable commodity, OVR should l i m i t employee
access to v i t a l records and reconcile forms used to make c e r t i f i e d copies
with the actual number of c e r t i f i e d copies sold each day - t r e a t i n g these
materials, i n essence, l ike cash.
OVR Can lmprove Operational
E f f i c i e n c y and Customer Service ( see pages 13 through 18)
OVR could improve e f f i c i e n c y and customer service i n several ways. For
example, although the agency developed an in- house computer to f a c i l i t a t e
a more timely and e f f i c i e n t records storage and r e t r i e v a l system, the
computer i s c u r r e n t l y u n d e r u t i l i z e d . Instead of using the computer to
routinely produce records, OVR produces many records by manually
photocopying the o r i g i n a l documents. By more f u l l y u t i l i z i n g i t s
computer system, OVR could: 1) process records faster and free s t a f f to
perform other d u t i e s , and 2) increase customer s a t i s f a c t i o n by improving
turnaround time. Turnaround time and, consequently, customer
s a t i s f a c t i o n for m a i l - i n requests could also be improved by e l i m i n a t i n g
the 20- day check- hold procedure.
OVR Should Enlarge I t s Waiting Area
to lmprove Service t o the Publ i c ( see pages 19 through 21
OVR's customer waiting area i s not adequate to serve the p u b l i c . Up to
56 people have been observed using the 12 by 22 foot area which was
designed for no more than 15 people. During busy times, many people must
wait outside ( o f t e n in the heat) for up to an hour to get service.
Although DHS has i n i t i a t e d plans to expand OVR's s t a f f areas, the plan
needs to be modified to provide enlargement of the w a i t i n g area.
TABLE OF CONTENTS
Page
INTRODUCTION AND BACKGROUND . . . . . . . . . . . . . . . . . . . 1
FINDING I: BETTER PROTECTION AND OVERSIGHT OF THE
STATE'S VITAL RECORDS ARE NEEDED. . . . . . . . . . . . . . . 5
Adequate Protection of the State's Vital
Records Is Necessary. . . . . . . . . . . . . . . . . . . . . 5
OVR's F a c i l i t y Does Not Adequately Protect
Vital Records from Theft or Destruction . . . . . . . . . . . 6
Controls over Vital Records
Are Weak in Several Areas . . . . . . . . . . . . . . . . . . 9
Recomnendations . . . . . . . . . . . . . . . . . . . . . . . 11
F l ND l NG I I : OVR CAN IMPROVE OPERAT I ONAL
EFFICIENCY AND CUSTOMER SERVICE . . . . . . . . . . . . . . . 13
Full Benefits of OVR's In- House Computer
Are Not Being U t i l i z e d . . . . . . . . . . . . . . . . . . . . 13
F u l l U t i l i z a t i o n of Computer Technology
WouldResult inGreater Efficiency. . . . . . . . . . . . . . 15
Customer Service Could Be Improved I f
OVR Changed I t s Check- Handling Procedure. . . . . . . . . . . 16
Recomnendations . . . . . . . . . . . . . . . . . . . . . . . 17
FINDING I l l : OVR SHOULD ENLARGE ITS WAITING AREA
TO IMPROVE SERVlCE TO THE PUBLIC. . . . . . . . . . . . . . . 19
Current Lobby Situation I s Inadequate . . . . . . . . . . . . 19
OVR Should lnclude Lobby Expansion in I t s
P l a n s t o E n l a r g e t h e O f f i c e . . . . . . . . . . . . . . . . . 20
Recommendations . . . . . . . . . . . . . . . . . . . . . . . 20
AREAS FORFURTHERAUDITWORK. . . . . . . . . . . . . . . . . . . 23
AGENCY RESPONSE
INTRODUCTION AND BACKGROUND
The Office of the Auditor General has conducted a performance audit of
the Arizona Department of Health Services, O f f i c e of V i t a l Records, i n
response to a June 2, 1987, r e s o l u t i o n of the J o i n t L e g i s l a t i v e Oversight
Committee. This audit was conducted as part of the Sunset Review set
f o r t h i n Arizona Revised Statutes ( A. R. S.) 6541- 2351 through 41- 2379.
This audit i s the f i f t h i n a series of reports issued on the Department
of Health Services ( DHS). The report focuses on the functions of the
Office of V i t a l Records which operates w i t h i n the D i r e c t o r ' s O f f i c e .
Func t ions
The O f f i c e o f V i t a l Records ( OVR) d i r e c t s and supervises a statewide
system of v i t a l records and p u b l i c health s t a t i s t i c s , and i s the
custodian of those records. Records maintained consist p r i m a r i l y of
b i r t h and death c e r t i f i c a t e s . OVR also issues c e r t i f i e d and n o n c e r t i f i e d
copies of b i r t h and death records to e l i g i b l e persons upon request, and
makes corrections to records when necessary. "' Our ing f i s c a l year
1987- 88, OVR :
0 Recorded 65,477 b i r t h s and 29,221 deaths.
0 Issued 109,687 c e r t i f i e d b i r t h records, 63,497 c e r t i f i e d death
records, and 26,195 n o n c e r t i f i e d records.
OVR has established r e g i s t r a t i o n d i s t r i c t s throughout the State t o a s s i s t
i n processing b i r t h and death c e r t i f i c a t e s transmitted from h o s p i t a l s ,
mortuaries, midwives, and, i n some cases, p r i v a t e i n d i v i d u a l s . These
d i s t r i c t s are administered by local r e g i s t r a r s appointed by the State
Registrar. R e g i s t r a t i o n d i s t r i c t s i n Maricopa and Pima counties are
designated as class A . They are responsible for reviewing the b i r t h and
C e r t i f i e d records contain t h e State seal and may be used i n l e g a l t r a n s a c t i o n s ,
while noncerti f i e d copies can be obtained and used f o r research purposes on1 y.
death records sent to them for accuracy and completeness. Class A
d i s t r i c t s r e t a i n records for 30 days, and may issue c e r t i f i e d copies of
the records while they remain i n t h e i r possession. In c o n t r a s t , other
local r e g i s t r a t i o n d i s t r i c t s , designated as class B, send records
d i r e c t l y to OVR and cannot issue copies of records to the p u b l i c .
Orqanizat ion and S t a f f i n g
OVR i s supervised by an Assistant S t a t e R e g i s t r a r who reports d i r e c t l y to
the d i r e c t o r of DHS, the l e g a l l y designated State R e g i s t r a r . The o f f i c e
consists of four u n i t s , and employs a s t a f f of 30 including the Assistant
State Registrar.
e The Revenue Control U n i t - This u n i t serves the p u b l i c d i r e c t l y .
I t processes over- the- counter applications for c e r t i f i e d copies of
v i t a l records. The u n i t reviews a p p l i c a t i o n s and supporting
documentation t o e s t a b l i s h an a p p l i c a n t ' s e l i g i b i l i t y and c o l l e c t s
fees. M a i l - i n requests are also processed through t h i s u n i t . The
revenue control u n i t consists of s i x f u l l - t i m e employees ( FTEs),
including a supervisor.
e The Records Room Unit - The S t a t e ' s v i t a l records are permanently
stored i n OVR's records room. The records room u n i t i s responsible
for f i l i n g v i t a l records and for maintaining the records' s e c u r i t y .
In addition, records room s t a f f receive a p p l i c a t i o n s processed
through revenue c o n t r o l , search for the records applied f o r , and
produce the c e r t i f i e d copies requested. Copies are produced e i t h e r
by photocopying or by the agency's in- house computer. This u n i t
consists of seven FTEs, including a supervisor.
e The Coding Unit - This u n i t prepares the b i r t h and death
c e r t i f i c a t e s sent by local r e g i s t r a t i o n d i s t r i c t s , h o s p i t a l s , and
mortuaries for permanent f i l i n g i n the records room. Documents are
reviewed for completeness, consistency, and accuracy. Records are
then coded by s t a f f to f a c i l i t a t e data entry - the DHS automation
group inputs coded data from death c e r t i f i c a t e s onto the agency's
mainframe computer, while b i r t h c e r t i f i c a t e s are keyed d i r e c t l y onto
OVR's computer by OVR's coding s t a f f . The coding u n i t employs 6
FTEs, including the u n i t ' s supervisor.
a The Corrections Unit - This u n i t makes c o r r e c t i o n s to o r i g i n a l
records. The group amends records, when necessary, to correct e n t r i e s
on b i r t h and death c e r t i f i c a t e s such as the time or place of the
occurrence. I n a d d i t i o n , the u n i t can amend b i r t h records to add the
name of a c h i l d ' s father to the c e r t i f i c a t e in cases where the mother
was unmarried at the time of b i r t h . The c o r r e c t i o n s group also
processes l a t e or delayed b i r t h r e g i s t r a t i o n s . These generally occur
when OVR i s unable to locate an o r i g i n a l record. This u n i t i s
staffed with 6 FTEs, including i t s supervisor.
In a d d i t i o n t o u n i t s t a f f , OVR employs three FTEs who provide
administrative support, and an a d m i n i s t r a t i v e supervisor who oversees the
work of each u n i t supervisor.
Revenue and Expenditures
A. R. S 336- 342 authorizes DHS to assess fees ' Ifor searches, copies of
records, a p p l i c a t i o n s to f i l e delayed records, and requests for
supplementary b i r t h c e r t i f i c a t e s , f o l lowing adoption, l e g i t i m a t i o n ,
p a t e r n i t y determination, . . . or amendments to e x i s t i n g records." Fees
range from $ 2 to $ 13, or more depending on the service performed:
a $ 2 for a copy of a n o n c e r t i f i e d record,
a $ 5 for a c e r t i f i e d computerized copy of a b i r t h c e r t i f i c a t e or a
photocopy of a death c e r t i f i c a t e ,
a $ 8 for a c e r t i f i e d photocopy of a b i r t h c e r t i f i c a t e , and
a $ 13 f o r c o r r e c t i n g a b i r t h c e r t i f i c a t e .
In addition, record searches are performed by the o f f i c e for persons
t r y i n g t o obtain a c e r t i f i e d copy of a b i r t h or death record, b u t who do
not know the date of occurrence. OVR charges $ 3 per record year searched
for the f i r s t 10 years researched, and $ 2 per record year t h e r e a f t e r .
The agency co I l ec ted $ 805,878 dur i ng f i sca I year 1987- 88. A I l monies
c o l l e c t e d are deposited i n t o the general fund.
OVR's operating budget i s derived from general fund appropriations, and
i n f i s c a l year 1988, OVR expended $ 745,816.
Aud i t Scope and Purpose
Our audit of OVR concentrated on issues related to operational e f f i c i e n c y
and effectiveness. Detailed work was conducted to determine whether:
e OVR's c o n t r o l and s e c u r i t y of the S t a t e ' s v i t a l records can be
improved,
e operational e f f i c i e n c y and customer service can be improved, and
0 the customer w a i t i n g area provides adequate space for the p u b l i c
The section e n t i t l e d Areas for Further Audit Work ( page 23) addresses
issues i d e n t i f i e d during the course of the a u d i t which we were unable to
research due to time c o n s t r a i n t s .
This a u d i t was conducted i n accordance w i t h generally accepted
governmental a u d i t i n g standards.
The Auditor General and s t a f f express appreciation to the D i r e c t o r of
DHS, the Assistant State Registrar of OVR and her s t a f f , for t h e i r
cooperation and assistance throughout the a u d i t .
FINDING I
BETTER PROTECTION AND OVERSIGHT
OF THE STATE'S
VITAL RECORDS ARE NEEDED
P r o t e c t i n g v i t a l records i s more important than i s generally recognized.
I n March 1989, a t h i e f broke i n t o the Delaware O f f i c e of V i t a l Records.
Entering through a window, the t h i e f s t o l e more than 1,700 blank forms
and the o f f i c i a l s e a l . The o f f i c e d i r e c t o r i n Delaware b e l i e v e s t h a t the
t h i e f intended t o f o r g e b i r t h c e r t i f i c a t e s and s e l l them. C o u n t e r f e i t
records have been s o l d f o r p r i c e s of up t o $ 1,500 each. Our review
suggests that a s i m i l a r t h e f t could happen i n Arizona. The Arizona
O f f i c e o f V i t a l Records has l i t t l e s e c u r i t y to prevent such a break- in.
I n a d d i t i o n , the current f a c i l i t y i s susceptible to f i r e and
environmental problems that could damage or destroy the records. OVR
also needs to strengthen i n t e r n a l c o n t r o l s to prevent possible t h e f t and
misuse of records by employees.
Adequate P r o t e c t i o n o f the S t a t e ' s
V i t a l Records I s Necessary
V i t a l records are a valuable commodity. They are important source
documents, and t h e r e f o r e , they are commonly used f o r fraudulent
purposes. Special care must be taken w i t h these records because they
are, i n many cases, the primary documentation of b i r t h s , adoptions, name
changes, and deaths i n Arizona. According to a recent report by the
O f f i c e o f the Inspector General, U. S. Department of Health and Human
Services, " f a l s e i d e n t i f i c a t i o n . . . i s estimated to cost s o c i e t y b i l l i o n s
of d o l l a r s annually." F u r t h e r , " The b i r t h c e r t i f i c a t e has been c a l l e d a
' breeder' document because w i t h a f a l s e one a person can o b t a i n other
f a l s e i d e n t i f i c a t i o n ( ID) documents w i t h which to defraud Government or
business, or create a new i d e n t i t y . " Securing these documents from
t h e f t , therefore, i s a necessity. Because of t h e i r importance, State law
requires DHS to adequately protect v i t a l records. A. R. S. $ 36- 302. B
mandates t h a t :
''[ Tlhe department of health services s h a l l provide f i r e p r o o f and
t h e f t proof f a c i l i t i e s to insure the permanent and safe
preservation of a l l v i t a l records received and f i l e d under t h i s
chapter ." ( emphas i s added)
In a d d i t i o n , Arizona law establishes s t r i n g e n t c o n f i d e n t i a l i t y
requirements and s t r i c t l y l i m i t s access to v i t a l records. Persons
requesting copies of records must prove they are e n t i t l e d to them. In
contrast, some s t a t e s a l l o w anyone free access to the s t a t e ' s v i t a l
records. Security improvements have been made by OVR in recent years.
For example, bank- note paper i s now used for making o f f i c i a l c e r t i f i e d
copies of v i t a l records. This high q u a l i t y paper i s very d i f f i c u l t to
duplicate. Also, OVR has increased the s e c u r i t y of computerized
documents through the use of passwords which r e s t r i c t employee access to
computer records.
OVR's F a c i l i t y Does Not Adequately Protect
V i t a l Records from Theft or Destruction
The physical s e c u r i t y of the S t a t e ' s v i t a l records and forms i s
inadequate. C u r r e n t l y , OVR's f a c i l i t y i s susceptible t o : 1) i l l e g a l
access and t h e f t , and 2) d e s t r u c t i o n r e s u l t i n g from f i r e and inadequate
climate c o n t r o l .
I l l e g a l access and t h e f t - Physical s e c u r i t y of v i t a l records and
materials i s weak. The records room could e a s i l y be broken i n t o , and the
basement storage area i s poorly secured. S i m i l a r s e c u r i t y weaknesses
contributed to v i t a l records t h e f t s i n two other s t a t e s . However, OVR
can address some of these s e c u r i t y problems at l i t t l e cost.
OVR's records room, which houses a l l b i r t h and death c e r t i f i c a t e s , as
well as the materials needed to produce c e r t i f i e d copies, could be
burglarized r e l a t i v e l y e a s i l y . " I Although the o f f i c e i s
" r e s t r i c t e d , " there are no alarms on the doors to the OVR o f f i c e or to
the records room. The records room also lacks alarms on i t s windows even
though they are large enough to allow entry i n t o the area.
In addition, OVR's basement storage area i s not secured from t h e f t . The
basement, which i s not locked, houses storage areas for several other DHS
d i v i s i o n s , and the departmental copy and mail rooms. OVR also stores
supplies of blank c e r t i f i c a t e s and other valuable m a t e r i a l s , which could
be used to produce fraudulent records, i n the basement storage area.
This area i s surrounded by a fence and padlocked. However, there i s a
f i v e - f o o t clearance between the top of the fence and the c e i l i n g , and the
fence could be climbed e a s i l y . The locked storage area i s unattended,
and a l l DHS employees have access to the basement. There are no video
cameras or alarms t o monitor the area.
The lack of adequate s e c u r i t y has contributed to t h e f t s of v i t a l records
i n at least two s t a t e s . For example, the Delaware v i t a l records o f f i c e
burglarized i n March 1989 lacked a s e c u r i t y system and was not being
adequately monitored by the s t a t e s e c u r i t y p o l i c e . S i m i l a r l y , thieves
broke i n t o the Colorado OVR through a side window during the 1985 Labor
Day weekend. Records, the S t a t e s e a l , a photocopy machine, and cert i f ied
paper were a l l a v a i l a b l e i n the o f f i c e which lacked s e c u r i t y alarms,
video cameras, window breakage detectors, or movement d e t e c t o r s . Since
the incident, a l l have been i n s t a l l e d .
According to the State of Arizona l i b r a r y and archives records management
s p e c i a l i s t and v i t a l records o f f i c e s i n other states we contacted, OVR
can g r e a t l y improve i t s physical s e c u r i t y by taking the f o l l o w i n g steps:
( 1 ) Materials needed t o produce c e r t i f i e d copies include: c e r t i f i e d copy paper t h a t i s
used to produce a photocopy o r computer- generated copy, t h e S t a t e seal which i s
stamped on c e r t i f i e d copies to make them o f f i c i a l , the photocopy machine, and the
computer that produces computer- generated b i r t h c e r t i f i c a t e s .
Alarms can be i n s t a l l e d on the records room entrance, and window
breakage alarms can be i n s t a l led on records room windows.
DOA- Facilities Management researched the costs of the needed
alarms and s a i d t h a t i n s t a l l i n g such alarms at OVR would cost an
estimated $ 1 ,800.
Video cameras would provide a means for monitoring a c t i v i t y in
and around the records room and basement storage areas at al l
hours of the day. DOA- Faci I i t i e s Management estimated the cost
for the needed cameras at $ 12,000.
DHS requested funds from the L e g i s l a t u r e f o r these devices i n i t s f i s c a l
year 1989 budget request, but the request was not funded.
F i r e and environmental threats - F i r e and poor climate control are also
threats to Arizona's v i t a l records. A records management special i s t from
the State l i b r a r y and archives observed OVR and determined that v i t a l
records are at r i s k of f i r e i n two ways:
a S p r i n k l e r System - The DHS bui l d i n g , where OVR operates, uses a
s p r i n k l e r system to suppress f i r e . In the event of a f i r e , water
from the f i r e suppression system could severely damage v i t a l
records.
a Walls - OVR's records room w a l l s are not f i r e retardant and,
therefore, would not contain a f i r e . As a r e s u l t , a f i r e in an
adjacent area could e a s i l y threaten v i t a l records.
OVR can remedy i t s f i r e suppression problem without undue expense. Halon
systems are already used by several State agencies. For example, the
State l i b r a r y and archives uses halon to protect documents, and the DHS
computer room uses halon to protect equipment. Halon i s a popular
records p r o t e c t i o n system because i t suppresses f i r e without the use of
water. According to DOA- Faci l i t i e s Management, who researched the cost
for OVR, i t would cost approximately $ 12,800 to i n s t a l l a halon system at
OVR. OVR requested funds for a halon system i n i t s 1988- 89 DHS budget
request, but the request was r e j e c t e d .
I n a d d i t i o n , inadequate climate c o n t r o l s could cause i r r e p a r a b l e damage
to the S t a t e ' s records. The d i r e c t o r of the State l i b r a r y and archives,
pursuant to A. R. S. 939- 101, sets s p e c i f i c standards for temperature and
humidity f l u c t u a t i o n i n storage areas for permanent paper records.
However, OVR has no monitors to ensure that the climate i n i t s records
room conforms to these requirements. The records room lacks any special
climate c o n t r o l s . I t i s heated and cooled i n the same manner as the rest
of the DHS b u i l d i n g . For example, because a i r c o n d i t i o n i n g i s turned o f f
on workday evenings and weekends, the indoor temperatures can climb as
high as outside temperatures. Also, the records room has no humidity
c o n t r o l , thus p o t e n t i a l l y allowing paper records to become dry and
b r i t t l e . This i s a considerable danger since records are r o u t i n e l y
handled when making c e r t i f i e d copies.
In order to provide adequate climate control i n the records room, DHS
would need to add cooling and humidifying equipment. The DHS computer
room, which shares a wal I w i t h the OVR records room, has a separate
cooling system s i m i l a r to that needed i n the records room. We asked the
Department of A d m i n i s t r a t i o n - F a c i l i t i e s Management section to determine
the cost of such a system for the records room. They estimate that
adequate temperature and h u m i d i t y c o n t r o l would require the a d d i t i o n of a
separate a i r conditioning system t h a t a d j u s t s the humidity l e v e l . Such a
system would cost approximately $ 40,000.
Controls over V i t a l Records
Are Weak i n Several. Areas
Controls over v i t a l records, m a t e r i a l s , and forms are weak i n some areas
at OVR. OVR lacks a sound inventory control system to ensure that
materials and equipment are not used to create fraudulent documents.
Controls over employee access to records and forms do not prevent
unauthorized use of the documents.
Inventory controls - Loose inventory controls increase the 1 i k e l i hood
of i l l i c i t a c t i v i t y . OVR does not r e g u l a r l y reconcile the number of
c e r t i f i e d records sold w i t h the s e r i a l numbers of the prenumbered
bank- note q u a l i t y paper used to produce the copies. Moreover, OVR does
not reconcile the number of copies sold w i t h the a p p l i c a t i o n s and
payments received for the copies. As a r e s u l t , the blank forms ccn! c! he
diverted for unauthorized purposes without OVR's knowledge. Blank forms
and c e r t i f i e d copies are valuable documents and should be treated the
same as cash and reconciled each day. OVR should reconcile copies sold
with copies produced by recording s e r i a l numbers of c e r t i f i e d copies on
the a p p l i c a t i o n for them. OVR should also take greater care in
monitoring and t r a c k i n g the s e r i a l numbers of the c e r t i f i e d copy paper
used.
OVR also d i s t r i b u t e s b i r t h and death c e r t i f i c a t e s to county r e g i s t r a r s ,
h o s p i t a l s , and funeral homes but does not reconcile the number of
c e r t i f i c a t e s d i s t r i b u t e d w i t h completed c e r t i f i c a t e s returned. The
l i b r a r y and archives records management s p e c i a l i s t suggests that OVR
number the blank c e r t i f i c a t e s , have the users sign the c e r t i f i c a t e s out
i n " blocks," and l a t e r reconcile the completed c e r t i f i c a t e s to the number
d i s t r i b u t e d .
Employee access - Access to both the o r i g i n a l records and to the
materials needed to make c e r t i f i e d copies i s loosely guarded at OVR and
could lead to the fraudulent use of records and OVR m a t e r i a l s . Although
records room employees are most frequently i n the area, a l l employees
have free access to the records room. In f a c t , the s t a f f r e f r i g e r a t o r i s
located i n the records room, so i t i s common to f i n d any of the OVR
employees there. Moreover, employee a c t i v i t y i n the records room i s not
monitored. Weak c o n t r o l s over v i t a l records may have c o n t r i b u t e d t o
several incidents of i l l e g a l a c t i v i t i e s by OVR employees.
0 OVR's records room supervisor was caught a l t e r i n g the content of
v i t a l records and d i s t r i b u t i n g a c e r t i f i e d copy of a record to a
f r i e n d . In January 1987, the supervisor was caught sending a
c e r t i f i e d copy of a b i r t h record to a friend without the proper
request, a u t h o r i z a t i o n , o r fee. In December 1988, she cut two b i r t h
c e r t i f i c a t e s out o f records books, whited out c e r t a i n information,
and had an employee type i n fraudulent information. ( The employee
said that t h i s was not the f i r s t time a s i t u a t i o n such as t h i s had
occurred.). A f t e r the second i n c i d e n t , the supervisor was demoted
and transferred to another DHS u n i t .
0 In October 1986, an OVR information processing s p e c i a l i s t was caught
making a copy of a b i r t h c e r t i f i c a t e for her own use. The employee
q u i t her job a f t e r t h i s incident.
In neither case were c o n t r o l s set up to prevent the i l l e g a l a c t i v i t i e s .
In the f i r s t i n c i d e n t , the employee who was asked to a s s i s t the records
room supervisor reported her to OVR's d i r e c t o r . In the second i n c i d e n t ,
an OVR employee reported the information processing s p e c i a l i s t to the OVR
supervisor a f t e r seeing her produce the document for her own use.
In addition, non- OVR employees have access to the records room.
Representatives from Social S e c u r i t y , the State Board of Funeral
Directors and Embalmers, the American Cancer Society and the DHS B i r t h
Defects Monitoring Program are a l lowed to review speci f i c records and
obtain copies.
Access to the records room should be s t r i c t l y regulated. For example,
the Michigan o f f i c e of v i t a l records uses s t r i c t d i v i s i o n of labor to
control access. Although d u t i e s at Arizona's OVR are normally
segregated, i t i s not unusual for s t a f f to perform tasks outside of t h e i r
assigned f u n c t i o n i n c l u d i n g a l l jobs necessary to produce a c e r t i f i e d
record. According to the Michigan d i r e c t o r , d u t i e s are segregated so
that one person cannot search f o r , copy, and c e r t i f y a record.
Only employees who are s p e c i f i c a l l y assigned to the Michigan records room
are allowed i n that area. Arizona's l i b r a r y and archives records
management s p e c i a l i s t also recommends that only records room s t a f f be
allowed in the records room to make c e r t i f i e d copies. Given the l i m i t e d
space at OVR, working i n the records room appears necessary, but i t i s
reasonable to r e s t r i c t access for those who work outside of the records
room. DHS has i n i t i a t e d both short- and long- term plans to renovate
OVR's f a c i l i t y . These plans should take OVR's s e c u r i t y needs i n t o
consideration.
RECOWENDATIONS
1. DHS should provide adequate, secure f a c i l i t i e s for OVR including:
a. Door and window alarms, and video cameras i n the records room,
b. A f u l l y enclosed basement storage area w i t h i n t r u s i o n alarms
and a video monitor,
c. A f i r e suppression system appropriate for use w i t h paper
records,
d. Temperature and humidity control i n the records room, and
e. Consideration of provisions for OVR's s e c u r i t y needs i n t h e i r
plans for f u t u r e o f f i c e renovation.
2 . OVR should improve controls over the bank- note q u a l i t y paper used
to produce c e r t i f i e d copies of v i t a l records by r e c o n c i l i n g s e r i a l
numbers for c e r t i f i e d copies w i t h the corresponding a p p l i c a t i o n s
and payments, and the prenumbered copy forms.
3. OVR should a l s o r e c o n c i l e the blank forms d i s t r i b u t e d to the local
r e g i s t r a r s , h o s p i t a l s , and mortuaries w i t h the completed
c e r t i f i c a t e s received.
4. OVR should l i m i t nonessential s t a f f ' s access to the records room
area to records room s t a f f only.
5. OVR should more s t r i c t l y segregate o f f i c e duties to avoid enabling
one employee to search, copy, and c e r t i f y a record.
FINDING I1
OVR CAN IMPROVE
OPERATIONAL EFFICIENCY AND CUSTOMER SERVICE
The O f f i c e o f V i t a l Records could improve e f f i c i e n c y and customer
service. By more f u l l y u t i I i z i n g i t s computer system, OVR could:
1) process record requests faster and free s t a f f to perform other d u t i e s ,
and 2) increase customer s a t i s f a c t i o n by improving turnaround time.
Turnaround time f o r m a i l - i n requests could also be improved by
e l i m i n a t i n g OVR's p o l i c y of holding persona! checks for 20 days.
F u l l Benefits o f OVR's In- House Computer
Are Not Being U t i l i z e d
OVR i s not making e f f i c i e n t use of i t s computerized records system.
Although the agency developed an in- house computer to f a c i l i t a t e a more
timely and e f f i c i e n t records storage and r e t r i e v a l system, the computer
i s c u r r e n t l y u n d e r u t i l i z e d .
Computer system developed t o increase e f f i c i e n c y - OVR developed and
p a r t i a l l y implemented an in- house computer system to f a c i l i t a t e e f f i c i e n t
operations and o f f s e t increased workloads. Increased workloads have made
timely and e f f i c i e n t service more d i f f i c u l t for the agency to achieve.
For example, OVR's incoming mail has increased approximately 34 percent,
and the number of c e r t i f i e d records issued has increased approximately 26
percent since f i s c a l year 1985, while s t a f f i n g has remained r e l a t i v e l y
constant. To compensate for increasing demands, OVR developed and
p a r t i a l l y implemented the V i t a l Records System i n January 1989 at a cost
of $ 372,000.'" To fund t h i s system, DHS had to d i v e r t funds from
( 1 ) B i r t h records f o r persons born i n Arizona from 1950 t o the present are on the
system. Data e n t r y forms d i d not require a i l necessary information from the
o r i g i n a l c e r t i f i c a t e t o be included on the computer form when the f i r s t records
( 1973- 1982) were o r i g i n a l l y entered i n t o the system. This prevents OVR from
producing usable copies f o r those years. The data entry forms have since been
changed, and complete records f o r 1973 through 1982 are being entered i n t o the
system as time permits. Death records are not on the system, and plans to complete
the system have s t a l l e d due t o the lack of funding.
i t s automation group's operating budget. The o f f i c e j u s t i f i e d the
expense by asserting that an automated system was necessary to prevent
" i n t o l e r a b l e delays i n accessing v i t a l records, decreasing service
l e v e l s , and ... increased complaints."
The computer system i s u n d e r u t i l i z e d - Despite the agency's investment,
OVR i s not f u l l y u t i l i z i n g the computer system. Currently, the vast
m a j o r i t y of c e r t i f i e d records sold by OVR are s t i l l produced by the older
and slower method of photocopying o r i g i n a l records. Our analysis showed
that the agency issues f i v e times more c e r t i f i e d photocopies than
c e r t i f i e d computer copies. I f i t s computer technology were f u l l y
u t i l i z e d , many more c e r t i f i e d computer copies could be sold. Currently,
54 percent of a l l b i r t h records are on the system and can be used to make
c e r t i f i e d computer copies.
The large number of photocopies issued i s due to the agency's p o l i c y of
providing persons an option of purchasing e i t h e r c e r t i f i e d photocopies or
c e r t i f i e d computer records. Although few people who purchase records are
aware they have an option u n t i l informed by OVR, our audit work indicates
many customers tend to choose photocopies l a r g e l y because of confusion
regarding the legal value of computer records. However, t h i s
concern i s unnecessary because c e r t i f i e d computer copies have the same
legal value as c e r t i f i e d photocopies. In f a c t , more and more State
agencies nationwide are increasing t h e i r reliance on computer technology.
OVR has at times added to the confusion over the legal value of computer
records by misrepresenting the records' worth to the p u b l i c . We observed
OVR counter s t a f f asking customers i f they wanted " the c e r t i f i e d copy or
the computer copy," implying that the computer records were pJ
c e r t i f i e d . We also observed counter s t a f f erroneously t e l l i n g customers
that the Social Security Administration might not accept
computer- generated records.
( ' ) A customer survey showed only 10 percent o f t h e m a i l - i n customers and 16 percent of
the over- the- counter customers were aware t h a t such an o p t i o n existed.
F u l l U t i l i z a t i o n o f Computer Technology
Would Result in Greater E f f i c i e n c y
Complete u t i l i z a t i o n of computer technology would increase agency
e f f i c i e n c y . OVR could: 1) process records faster and free s t a f f to
perform other d u t i e s , and 2) improve customer service by f u l l y u t i l i z i n g
i t s computer technology.'"
More e f f i c i e n t records processing - Ful l e r u t i l i z a t i o n of the V i t a l
Records System would r e s u l t i n faster record processing. Our o f f i c e
performed a l i m i t e d time and motion study to determine the time required
to produce photocopied records versus computer- generated records. We
found c e r t i f i e d photocopies take up to one- third longer to produce than
computer- generated records because s t a f f need time to manually r e t r i e v e
o r i g i n a l records and photocopy them. These a c t i v i t i e s , and the time
required to perform them, are avoided w i t h the computer.
Overall improvements i n processing e f f i c i e n c y may be even greater than
our study indicated. Studies by V i r g i n i a ' s v i t a l records o f f i c e
determined that processing records by computer i s f i v e times faster than
photocopy i ng . ( 2 )
In addition, greater reliance on computer processing would free s t a f f to
address other bottlenecks i n processing. Producing photocopied records
i s a labor intensive a c t i v i t y . Currently, four f u l l - t i m e employees are
assigned to t h i s a c t i v i t y . I f photocopying were s i g n i f i c a n t l y reduced,
some s t a f f involved i n records r e t r i e v a l and photocopying a c t i v i t i e s
could be reassigned to other functions where s t a f f are needed. Record
requests sent by m a i l , for example, t y p i c a l l y remain unopened for three
days because s t a f f are unavailable to begin processing. F u l l u t i l i z a t i o n
of i t s computer c a p a b i l i t y would give OVR greater f l e x i b i l i t y i n
deploying s t a f f to these kinds of a c t i v i t i e s , r e s u l t i n g i n more e f f i c i e n t
processing.
( 1 ) I n addition t o more e f f i c i e n t processing, use o f computer technology would help
protect o r i g i n a l records from wear r e s u l t i n g from photocopying. Current1 y, some
records must be cut out of ledgers, copied, and taped back i n place.
( 2) Vi r g i n i a may obtain greater benef i t s , however, because of a more sophisticated
computer system.
Computer technology and customer service - More e f f i c i e n t record
processing through increased automat ion cou Id improve customer
s a t i s f a c t i o n . In response to a customer survey, a s i g n i f i c a n t number of
people expressed d i s s a t i s f a c t i o n w i t h OVR timeliness i n f u l f i l l i n g record
requests.
We conducted a survey of 238 customers which showed t h a t , o v e r a l l , 26
percent of the over- the- counter customers surveyed were unhappy w i t h the
agency's timeliness i n f u l f i l l i n g record requests. Analyzing these
r e s u l t s , we found that the degree of d i s s a t i s f a c t i o n rose as people
waited more than a half- hour to complete t h e i r business. Further, we
found that surveyed customers who purchased c e r t i f i e d photocopies tended
to wait longer than those purchasing c e r t i f i e d computer records.
. Increased use of ' automation could also speed processing for m a i l - i n
requests. A survey of 145 m a i l - i n customers showed almost 33 percent
were displeased wi? h the timeliness of OVR's m a i l - i n service. A review
of OVR f i l e s showed processing time for m a i l - i n requests averaged over 15
days. Greater reliance on the computer could reduce t h i s
processing time. As noted previously, m a i l - i n requests t y p i c a l l y are not
opened for three or more days because s t a f f are not a v a i l a b l e to begin
processing. More frequent use of the computer would free s t a f f to
address t h i s and ather processing delays.
Customer Service Could Be Improved
I f OVR Changed I t s Check- Handling Procedure
Turnaround time, and consequently customer s a t i s f a c t i o n for m a i l - i n
requests, could be f u r t h e r improved i f OVR changed i t s check- handling
procedure. Under the current procedure, any m a i l - i n request accompanied
by a personal check ( and lacking a copy of a check guarantee card) i s
held for 20 days by OVR to allow time for the check to clear the bank.
( ' 1 OVR's turnaround time f o r mai 1- i n requests has improved substantial1 y since January
1989, when i t was f o u r weeks. However, t h e c u r r e n t two- week turnaround time i s
s t i l l considered marginal. According t o an o f f i c i a l of the National Center f o r
Health S t a t i s t i c s ( NCHS), a turnaround time of greater than two weeks i s considered
substandard.
This has a s i g n i f i c a n t impact on turnaround. While average turnaround
for mai I - i n requests i s 15 days overal I , turnaround time for requests in
which customers pay by check i s 36 days - including the 20- day delay.
In order to process a check, i t must clear the bank, be processed by the
State Treasurer's o f f i c e , and, i f there i s a problem, be returned to
OVR. This process can take up to 20 days. The Assistant S t a t e R e g i s t r a r
maintains that the 20- day check- holding p o l i c y has s u b s t a n t i a l l y reduced
the number of checks returned f o r n o n s u f f i c i e n t funds ( NSF). However,
figures are not avai lable from OVR on the percentage of NSF checks.
OVR should track the amount of checks returned NSF i n order to b e t t e r
i d e n t i f y the size of the problem. I f they f i n d that the number j u s t i f i e s
the 20- day checkhold, they should consider adopting the procedure
employed by Arizona's Motor Vehicle D i v i s i o n ( MVD). MVD processes a l l
check payments immediately. I f a check i s returned, MVD arranges for the
appropriate bank to hold the bad check u n t i l money s u f f i c i e n t to cover
the fee i s deposited i n t o the account. A t that time, the bank issues MVD
a c a s h i e r ' s check for the amount owed, plus any penalty fee assessed by
the agency. This procedure, i f adopted by OVR, would eliminate delays
resu l t i ng from checkho l ds.
A s t a t u t o r y amendment w i l l be necessary for OVR to implement t h i s
procedure. A. R. S. 528- 1599.38 allows MVD to i n i t i a t e the action
described above. DHS w i l l need to ask the Legislature to provide OVR
w i t h simi l a r a u t h o r i t y .
RECOWENDAT I ONS
1. OVR should i n s t r u c t i t s s t a f f on the legal value of computer records
and r o u t i n e l y issue these records i n cases where the data from the
o r i g i n a l record i s contained on i t s automated records system. OVR
could continue to issue photocopied records to persons s p e c i f i c a l l y
requesting them.
2. OVR should track processed checks to determine the percentage of
checks returned NSF.
3. I f OVR f i n d s t h a t the number of checks returned NSF warrants a
checkhold, OVR should consider using MVD's procedure. I f t h i s i s
needed, OVR should request the appropriate l e g i s l a t i o n .
FINDING I l l
OVR SHOULD ENLARGE ITS WAITING AREA
TO IMPROVE SERVICE TO THE PUBLIC
OVR's customer w a i t i n g area i s not adequate to serve the p u b l i c . The
w a i t i n g area i s not designed to accommodate the number of people using i t
each day, and t h i s leads t o customer d i s s a t i s f a c t i o n . DHS' c u r r e n t p l a n
for improving the f a c i l i t y should be modified to provide enlargement of
the w a i t i n g area.
Current Lobby S i t u a t i o n
I s Inadequate
OVR's w a i t i n g area i s too small to serve the needs of the p u b l i c . OVR has
been located at the Department of Health Services b u i l d i n g since 1974. A t
that time, OVR's level of service was approximately one- fourth of i t s
present l e v e l . A space management s p e c i a l i s t estimates that up to four
times more people use the w a i t i n g area each day than the a l l o c a t e d space
comfortably a l l o w s . The poor w a i t i n g area s i t u a t i o n r e s u l t s i n i n f e r i o r
service to the pub1 i c .
OVR does not have an adequate w a i t i n g area to serve i t s p u b l i c . Over 200
people are served at OVR's counter each day. Accompanied by f r i e n d s or
family members, the t o t a l number who enter the w a i t i n g area averages 400
people a day. In the middle of the day, we observed between 30 and 50
people i n the lobby area a t one time. A t one p o i n t , we counted 56
people. Since the w a i t i n g room i s only 12 feet by 22 f e e t , t h i s s i t u a t i o n
r e s u l t s i n cramped space, lack of adequate table space on which customers
can f i l l out a p p l i c a t i o n s , and poor flow of customers i n and out of the
area. During busy times, some persons wait outside the b u i l d i n g ( o f t e n i n
the heat) for up to an hour.
A Department o f A d m i n i s t r a t i o n space management s p e c i a l i s t determined that
OVR's customer w a i t i n g area i s too small t o serve i t s customers and that
i t should be enlarged. The space management s p e c i a l i s t analyzed the
dimensions of the w a i t i n g area and concluded that the maximum number of
people there at one time should not exceed 15. He also noted that the
setup of the room i s confusing and does not s u i t the needs of the
customers. The s p e c i a l i s t s a i d t h a t the area should be at least twice i t s
current s i z e and recommends that OVR enlarge i t i n two d i r e c t i o n s . He
recommends moving back the counter wall and the area's r e a r w a l l .
According to the survey we conducted of OVR customers, the public i s not
s a t i s f i e d with the present w a i t i n g area. Forty- two percent of those
surveyed f e l t that the lobby was e i t h e r poor or very poor, and many
provided additional comments on the lobby size and crowded conditions they
experienced.
OVR Shou l d I nc l ude Lobby Expans i on
i n I t s Plans to Enlarge the O f f i c e
DHS i s planning to modify i t s b u i l d i n g to provide more space for OVR.
However, DHS' current plan for f a c i l i t y improvements includes no
provisions for w a i t i n g area expansion. The plan, which has been approved
and given p a r t i a l funding by the L e g i s l a t u r e , involves moving the d i v i s i o n
that i s presently adjacent to OVR u p s t a i r s and expanding OVR's space.
However, the plan includes only increases in o f f i c e space, not an
expansion of the w a i t i n g area.
DHS should adjust i t s plan to a l low more room for the lobby area. Because
the DHS plan has yet to be f u l l y financed and construction plans are not
f i n a l , OVR should rearrange the expansion design to include increases in
the waiting area space. Modifications should include more area for
customers to f i l l out a p p l i c a t i o n s , and an organized area i n which people
can both wait to be served and wait to pick up c e r t i f i e d copies. DHS i s
also developing future plans f o r a d d i t i o n a l faci l i t ies and should consider
OVR lobby requirements when designing those f a c i l i t i e s .
RECOWENDAT I ONS
1. DHS should modify i t s current plans for expanding OVR's faci l i t ies to
include lobby enlargement.
AREAS FOR FURTHER AUDIT WORK
During the course of our audit we i d e n t i f i e d two p o t e n t i a l issues that we
were unable to pursue because of time c o n s t r a i n t s .
e Should OVR use m i c r o f i l m to supplement i t s computer system?
Although OVR has computerized approximately 54 percent of i t s b i r t h
records, many paper records w i l l be i n use for the foreseeable f u t u r e .
OVR plans to computerize a l l of i t s v i t a l records when funds are
a v a i l a b l e . However, because of the cost involved, m i c r o f i l m technology
may be a more cost e f f e c t i v e a l t e r n a t i v e i n some cases, p a r t i c u l a r l y for
death records which are accessed much less frequently than b i r t h records.
OVR attempted to use m i c r o f i lm technology i n the e a r l y 1970s but was not
s a t i s f i e d w i t h the r e s u l t s . Further audit work i s needed to: 1) i d e n t i f y
microf i Im systems c u r r e n t l y avai Iable, 2 ) evaluate OVR's previous
experience w i t h m i c r o f i l m , and 3) determine whether m i c r o f i l m o f f e r s an
e f f e c t i v e a l t e r n a t i v e t o complete computerization of Arizona's v i t a l
records.
a Does OVR need a d d i t i o n a l p o s i t i o n s to work w i t h local v i t a l records
administrators, h o s p i t a l s , and mortuaries?
OVR c u r r e n t l y r e l i e s extensively on local r e g i s t r a r s , h o s p i t a l s , and
mortuaries to i n i t i a t e paperwork needed to create b i r t h and death
c e r t i f i c a t e s . However, OVR has no s t a f f s p e c i f i c a l l y a v a i l a b l e to deal
with the various l o c a l p a r t i c i p a n t s . A l l t r a i n i n g and assistance i s
provided by the Assistant State R e g i s t r a r . Other states such as Texas and
Michigan have s t a f f assigned f u l l - t i m e t o f i e l d representative p o s i t i o n s .
According to the Assistant S t a t e R e g i s t r a r , f i e l d representatives are
needed to reduce e r r o r rates and t r a i n local s t a f f . They could also be
used to strengthen s e c u r i t y at the local l e v e l . Further audit work i s
needed to determine: 1) the local e r r o r rate, 2) the local r e g i s t r a r s '
knowledge of the proper procedures involved w i t h processing v i t a l records,
and whether they are adequately t r a i n e d , and 3) whether a d d i t i o n a l OVR
s t a f f would be needed to address these p o t e n t i a l problems.
ARIZONA DEPARTMENT OF HEALTH SERVICES
Office of the Director
ROSE MOFFORD. (; OVERNOR
TED WILLIAMS. DIRECTOR September 20, 1989
Mr. Douglas R. Norton
Auditor General
2700 N. Central, Suite 700
Phoenix, AZ 85004
Dear Mr. Norton:
This is in response to your revised draft audit report for the Office of Vital Records.
In review I find that most of our areas of concern have been addressed; however, the
following still requires attention:
1. In our first response we advised you that on page 10 the employee case history, as
stated, was reversed. It has not been corrected. The event described as occurring in
January 1987, actually occurred in December 1988, and the event described as
occurring in December 1988, actually occurred in January 1987. *
2. On page 11, reference is still made to " several government officials from outside of
OVR as well as a representative from a nonprofit organization were authorized to
review records and obtain copies." I believe this statement is misleading and suggest
it be stated t h a t requests for access from Social Security, t h e S t a t e Board of Funeral
Directors and Embalmers, the American Cancer Society, and the DHS Birth Defects
Monitoring Program were approved, and they are allowed, under supervision, to
review specific records and receive copies for same. *
3. The fifth recommendation on page 12 still implies that duties within the office aren't
segregated; however, as we discussed, these duties are separate and distinct. Cross
training ( which is necessary in any office) would give various employees the
knowledge and, therefore, the ability to search, copy and certify a record.
In conclusion, thank you once again for the opportunity to provide comments on the Vital
Records audit report.
Sincerely,
Ted Williams
Director
TW: Jl * Auditor's Note: Text has been corrected as suggested.
The Department of Health Services is An Equal Opportunity Affirmative Action Employer.
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State Health Building 1740 West Adams Street Phoenix, Arizona 85007