State of New York Office of the State Comptroller Division of Management Audit

ROOSEVELT ISLAND OPERATING CORPORATION

OPERATING PRACTICES

REPORT 94-S-59

H. Carl McCall Comptroller State of New York Office of the State Comptroller

Division of Management Audit

Report 94-S-59

Ms. Jean Lerman President Roosevelt Island Operating Corporation 591 Main Street Roosevelt Island, NY 10044

Dear Ms. Lerman:

The following is our report on the Roosevelt Island Operating Corpor-ation's operating practices, primarily as they relate to maximizing revenues and minimizing expenses.

This audit was performed pursuant to the State Comptroller's authority as set forth in Article X, Section 5 of the State Constitution and Chapter 26 of the New York Unconsolidated Laws. Major contributors to this report are listed in Appendix A.

In an effort to reduce the costs of printing, if you wish your name to be deleted from our mailing list or if your address has changed, contact Raymond W. Cecot at (518) 474-3271 or at the Office of the State Comptroller, Alfred E. Smith State Office Building, 13th Floor, Albany, NY 12236. Executive Summary Roosevelt Island Operating Corporation Operating Practices

Scope of Audit Pursuant to Chapter 26 of the New York Unconsolidated Laws, the Roosevelt Island Operating Corporation (RIOC) was organized in 1984 as a public benefit corporation. In 1985, RIOC became responsible for the development, operation, security and maintenance of a planned, mixed-income urban community located on Roosevelt Island (Island), which is situated in the East River between Manhattan and Queens County. To date, 3,241 of the planned 5,000 housing units have been built (2,141 in 1976 and 1,100 in 1989). RIOC officials expect the remaining units to be built and occupied by 1999. RIOC administers all Island services, including grounds' maintenance, and the operation of the aerial tramway (tram), bus services, and the parking facility. RIOC uses outside contractors to manage the tram and the parking facility. For the 1994-95 fiscal year, RIOC had operating revenues totaling $7.5 million and expenditures of $9.2 million. The resulting operating deficit, as well as $6.4 million in capital costs, was funded by State appropriations. As of February 1996, RIOC had a staff of about 81.

Our audit addressed the following questions concerning RIOC's operating practices for the period from April 1, 1991 through March 31, 1995:

! Is RIOC providing Island services efficiently?

! Does RIOC maintain adequate internal controls over revenues and expenses?

Audit Observations We found that, since a New York City subway station opened on the Island in and Conclusions October 1989, ridership on the Island's tram dropped 48 percent. The tram, which once showed an operating surplus, has suffered annual deficits averaging nearly $450,000 for the five fiscal years ending March 31, 1995. RIOC management needs to take actions to reduce tram costs to minimize this deficit. Unless appropriate cost-saving measures are taken, the tram will continue to show large deficits. We believe that RIOC officials should consider the reduction of tram operations. According to RIOC estimates, a reduction to 15 hours per day would result in annual cost savings of $150,000. In addition, although an October 1993 labor arbitration allowed RIOC to eliminate tram console operators, they were still employed as of February 1996. Elimination of these positions would result in annual savings of approximately $269,000. (See pp. 5-7)

RIOC also needs to consider taking over the management of the tram from its contractor. In doing so, additional annual savings totaling as much as $132,500 could result. We also found that RIOC has failed to collect more than $472,000 in tram fare subsidy reimbursements due from New York City's Board of Education from July 1990 through October 1993. RIOC needs to vigorously pursue these revenues and establish a mechanism for collecting these reimbursements regularly. (See pp. 8-9)

RIOC also needs to strengthen internal controls in several areas. We found a serious weakness in the controls over RIOC's practices for negotiating and documenting changes to commercial leases. In some cases, as a result of informal, undocumented agreements, tenants are paying rents that are lower than the agreed to amounts. Controls over the deposit of tram token sales also need to be strengthened. The tram cashier does not deposit all cash receipts. Rather, receipts representing only the number of tram tokens collected daily are deposited. Revenues from the sales of other tokens are retained in the contractor's safe, without an adequate accounting. We found over $13,000 in undeposited cash collections being held by the contractor. RIOC also needs to better document contracts awarded without competition, and awards made to other than the lowest bidder. (See pp. 11-15)

Comments of RIOC When they responded to our draft audit report, RIOC officials did not expect Officials to receive any State appropriation in the 1995-96 State budget. They said that their estimated $1.855 million operating deficit would, therefore, have to be eliminated through cost savings/reductions and revenue enhancements. Officials indicated that some recommendations contained in the audit report had been implemented and some others were being considered for implementa- tion to help eliminate the deficit. Subsequently, the enacted 1995-96 budget did include a $1.1 million subsidy for RIOC - about $750,000 less than the estimated deficit. Overall, RIOC officials' responses contained significant detail and evidence of serious consideration of conditions and opportunities to improve its operations. We believe that RIOC officials should continue to strive to implement our recommendations and continue related efforts to eliminate the need for State subsidies. Contents

Introduction Background ...... 1 Audit Scope, Objectives and Methodology ...... 2 Response of RIOC Officials to Audit ...... 3

Aerial Tramway Hours of Service ...... 6 Console Operators ...... 7 Reimbursable Transportation Costs ...... 8 Contractor Services ...... 8

Internal Controls Commercial Leases ...... 11 Revenue Collection ...... 13 Collection of Bus Fares ...... 14 Contracts ...... 15

Appendix A Major Contributors to This Report

Appendix B Comments of RIOC Officials

The comments of Agency Officials are not available in an electronic format. Please contact our Office if you would like us to mail you a copy of the report that contains their comments. Introduction

Background The Roosevelt Island Operating Corporation (RIOC) manages a planned, mixed-income urban community located on the 144-acre Roosevelt Island (Island), which is in the East River between Manhattan and Queens County. Pursuant to Chapter 26 of the New York Consolidated Laws, RIOC was organized in 1984 as a public benefit corporation responsible for the development, operation, security and maintenance of the Island. With oversight by a nine-member board of directors named by the Governor and approved by the New York State Senate, RIOC serves as the provider of many municipal services on the Island. RIOC has a staff of approximately 81. It operates transportation, provides security, performs snow removal, repairs the streets and sidewalks, and maintains the common grounds. RIOC receives revenues from such sources as commercial space leases, parking fees, bus and aerial tramway fares, as well as fees from the housing companies that operate apartments and co-ops on the Island.

These revenues have not been sufficient to support all RIOC operations. Consequently, RIOC receives operating support from the State in the form of an annual appropriation, as well as capital funds. The following table summarizes RIOC's operating revenues and expenses and the resulting deficits for the last four fiscal years:

State Fiscal Year Revenues Expenditures Deficit Appropriation

1991-92 $5,437,000 $7,919,000 $2,482,000 $2,740,000

1992-93 6,984,000 8,421,000 1,437,000 1,346,000

1993-94 7,133,000 8,535,000 1,402,000 1,648,000

1994-95 7,547,000 9,248,000 1,701,000 2,205,000

RIOC officials report that only 3,241 of the Island's planned 5,000 housing units have been built. They believe that the completion of the additional planned units would enable RIOC to generate sufficient revenues to support its operating budget. Assuming RIOC is successful in lining up federal and state funding commitments for this construction, these units are expected to be built and occupied by 1999. Meanwhile, RIOC is operating at a deficit. RIOC officials estimated the need for $1.855 million in operating subsidies from the State for the 1995-96 fiscal year; however, the enacted State budget only included $1.1 million for RIOC. RIOC must absorb the difference through cost savings /reduction and revenue enhancements.

Audit Scope, We audited selected RIOC operating practices from April 1, 1991 through Objectives and March 31, 1994. Additional information was subsequently obtained to update the report through the 1994-95 fiscal year, and in some cases to February Methodology 1996. The primary objective of our economy and efficiency audit was to determine the extent to which RIOC was maximizing operating revenues and minimizing operating expenses. To accomplish this objective, we reviewed procedures and interviewed RIOC personnel and contractor representatives, reviewed RIOC accounting and operating records, and made physical observations.

We conducted our audit in accordance with generally accepted government auditing standards. Such standards require that we plan and perform our audit to adequately assess those RIOC operations which are included in our audit scope. These standards also require that we understand RIOC's internal control structure and its compliance with those laws, rules and regulations that are relevant to RIOC's operations included in our audit scope. An audit includes examining, on a test basis, evidence supporting transactions recorded in the accounting and operating records; and applying such other auditing procedures as we consider necessary in the circumstances. An audit also includes assessing the estimates, judgments, and decisions made by management. We believe that our audit provides a reasonable basis for our findings, conclusions and recommendations.

We use a risk-based approach when selecting activities to be audited. This approach focuses our audit efforts on those operations that have been identified through a preliminary survey as having the greatest probability for needing improvement. Consequently, by design, finite audit resources are used to identify where and how improvements can be made. Thus, little audit effort is devoted to reviewing operations that may be relatively efficient or effective. As a result, our audit reports are prepared on an "exception basis." This report, therefore, highlights those areas needing improvement and does not address activities that may be functioning properly.

2 Response of RIOC A draft copy of this report was provided to RIOC officials for their review and Officials to Audit comment. Their comments have been considered in preparing this report and are included as Appendix B.

Within 90 days after final release of this report, as required by Section 170 of the Executive Law, the President of RIOC shall report to the Governor, the State Comptroller, and the leaders of the Legislature and fiscal committees, advising what steps were taken to implement the recommendations contained herein, and where recommendations were not implemented, the reasons therefore.

3 4 Aerial Tramway

One area that we have identified where RIOC can substantially reduce its expenses, minimizing the expenditure of State appropriated funds, is the operation of the aerial tramway (tram). When first developed, the Island was accessible only via a bridge from Queens. In May 1976, a tram was opened from 59th Street in Manhattan to Roosevelt Island. A subway station was opened on the Island in October 1989. Since the opening of the subway station, tram ridership has dropped by nearly one-half (48 percent). The tram, which once operated at a surplus, has operated at an average annual deficit of $449,000 during the five-year period ended March 31, 1995, as summarized below:

Operating Net Surplus Fiscal Year Revenues Expenses (Deficit)

1989-90 $2,010,579 $1,904,162 $106,417

1990-91 1,614,455 1,855,796 (241,341)

1991-92 1,522,886 1,859,227 (336,341)

1992-93 1,507,169 2,017,200 (510,031)

1993-94* 1,009,948 1,521,408 (511,460)

1994-95 1,405,687 2,052,066 (646,379)

* The tram was shut down from October 1993 to February 1994 to repair mechanical problems. This contributed to the significant drop in operating revenues and expenses for the 1993-94 fiscal year.

RIOC management has taken some actions to minimize the deficit. It has eliminated the operation of the token booth on the Island side of the tram and has begun to receive subsidies from New York City for the discounted fares it provides to senior citizens. Other RIOC-planned actions are aimed at increasing revenues through long-term measures. However, we believe that RIOC could make additional adjustments to reduce its operating costs: RIOC can reduce the number of hours the tram operates; eliminate unnecessary positions; and collect monies due from the New York City Board of Education to compensate for the free transportation provided to students. RIOC should

5 also consider taking over the operation of the tram from the contractor to save the management fee.

Hours of Service The tram is operated by a contractor whose costs, plus a management fee, are reimbursed by RIOC. The contractor employs 28 staff to operate the tram. Despite the tram's declining ridership and revenues, RIOC has continued to operate the tram at the same level of service as in the past. The tram operates seven days per week - Sunday through Thursday, 6 a.m. to 2 a.m., and Friday and Saturday, 6 a.m. to 3:30 a.m. - a total of 143 hours per week, utilizing three shifts of workers.

RIOC officials have not taken any action to reduce the hours of tram service because they believe it would adversely affect the quality of life on the Island and could cause a reduction in the number of residents. They state that the tram is relied upon by students, senior citizens and the disabled; and that it provides an essential alternative to the subway, particularly late at night. Such factors should be considered; however, RIOC officials have not conducted any formal studies to determine tram ridership during the late night and early morning hours to determine how many residents would be affected.

We believe that, although the tram is a municipal service and is not expected to make a profit, a transit system should evaluate the cost/benefits of its various routes and cease operations of routes that fail to meet minimum ridership thresholds. In 1991, the tram contractor estimated that $270,000 would be saved annually by reducing the hours of operations to eliminate the need for one shift of workers. RIOC officials believe less would be saved and estimate that only $150,000 per annum could be saved if tram operations were reduced by 25 hours a week to 15 hours per day (7 a.m. to 10 p.m.) from Sunday to Thursday. Friday and Saturday hours would remain as they are. In either case, the reduction of service hours would result in a significant cost savings and should be considered by RIOC officials.

6 Recommendation

1. Consider reducing the hours of tram operation.

(RIOC officials indicated that they were considering reducing tram operating hours due to the expected loss of their State operating subsidy for 1995-96. However, they also stated that should their revenue base increase, they would reverse this decision. Although the $1.1 million State appropriation has increased RIOC's revenue base, we believe RIOC officials should still consider reducing tram service hours. At a minimum, RIOC officials should conduct a formal study to determine the effect of such a reduction. As of February 1996, RIOC officials have not taken action to reduce the hours of tram service.)

Console Operators A second cost savings adjustment that RIOC could have already made involves the elimination of the tram console operators. Since it began operation, the tram has had a console operator on duty at all times while the tram is in operation. In October 1993, RIOC won an arbitration decision over the union whose members operate the tram to eliminate these positions. It was established that the console operator's duties could be performed by the staff operating the tram. However, as of February 1996, RIOC had not eliminated these positions, incurring unnecessary salary costs. RIOC officials stated that eliminating these positions would save about $269,000 per annum. (In response to our draft report, RIOC officials indicated that $124,000 of the $269,000 in savings would be reinvested in the tram operation.)

We asked RIOC officials why this cost savings measure was not put into effect immediately when the favorable decision was received from the arbitrator. They stated that it was decided to keep the function staffed until the Island residents were convinced that the operators were not needed and to insure the remaining tram staff were trained to perform the console operator's duties. They planned to introduce the change after a maintenance shutdown scheduled for the summer of 1994. RIOC's management expected the change to be completed in October 1994, one year after the favorable ruling was received. That has not occurred. It is not in the State's best financial interests that these funds be expended unnecessarily.

7 Recommendation

2. Eliminate the console operator positions.

(RIOC officials agreed with the recommendation, citing a variety of reasons for the delay.)

Reimbursable In June 1990, the New York City Board of Estimate resolved that RIOC is to Transportation be reimbursed for discounted tram transportation provided to senior and disabled citizens and for free transportation provided to students. RIOC Costs officials reported that their attempts to collect these subsidies from New York City had gone unheeded until February 1994 when reimbursement of fare subsidies for senior citizens and disabled tram passengers was approved by the City's Office of Management and Budget. The first check for $230,816 for prior period reimbursement was received in June 1994.

According to RIOC officials, monies due to RIOC for student fare subsidies, which have accrued to $472,000 for the period through October 1993, have been more difficult to collect; but they have pursued discussions with the Board of Education on this matter. Collection of both of these subsidies on a regular basis would generate approximately $213,000 annually in tram revenues and should be pursued vigorously.

Recommendation

3. Collect overdue revenue reimbursements for discounted tram transportation provided to students, and establish a system for obtaining these reimbursements, as well as reimbursements for senior and disabled citizens, on a regular basis.

(RIOC officials report that reimbursements for senior and disabled citizens are now received quarterly. Efforts to collect overdue student reimbursements have been unsuccessful.)

Contractor Services RIOC reimburses the tram contractor for all direct costs associated with tram operations, plus a 10 percent management fee. The management fee for the 1993-94 fiscal year totaled $132,500. For this fee, the contractor is responsible for the management, administration, operation and supervision of the tram. During the course of our audit field work, we discussed with RIOC officials their taking over the operation of the tram from the outside contractor, saving as much as $132,500 annually in management fees. RIOC officials

8 agreed to consider assuming direct responsibility for operating the tram. However, they did not agree that the entire $132,500 in annual management fees could be saved because they believed additional staff and consultants with specialized engineering background would have to be employed to provide RIOC with the on-going expertise necessary to properly and safely operate the tram.

Recommendation

4. Consider taking over the operation of the tram from the contractor.

(RIOC officials have determined that it would not be prudent to assume direct control over the tram operation. Instead, they indicated they are seeking an alternative where a larger agency, such as the Metropolitan Transit Authority, would assume jurisdiction over the tram.)

9 10 Internal Controls

The Internal Control Act of 1987 requires every State agency and public authority to establish and maintain a system of internal controls and a program of internal control review. A comprehensive system of internal controls is necessary for management to foster effective and efficient use of resources and to ensure the integrity of accounting and recordkeeping systems. A program for internal control review also provides management with a mechanism to identify internal control weaknesses and plan the actions needed to correct those weaknesses.

Our audit found areas where RIOC's internal controls need to be strengthened, including: negotiation and documentation of changes to commercial leases; cash collections; and the bidding of contracts.

Commercial Leases RIOC rents commercial space on the Island to a number of businesses, such as restaurants, a shoe repair and a dry cleaning establishment. Rents are set on a per square foot basis with provisions that the base rents will rise when additional buildings are opened and occupied on the Island, thus increasing the number of potential customers for the business. According to RIOC's financial statements for the year ended March 31, 1994, commercial tenants owed RIOC a total of $284,320. We reviewed the billing for all 21 commercial tenants who were in arrears during the period April 1, 1991 through February 28, 1994 and found that the billing invoices for 7 of the 21 did not agree with the terms of their signed leases. Four tenants had been underbilled a total of $39,929, and the other three had been overbilled a total of $8,948. (RIOC officials explained that 4 of the 7 billing errors were due to calculation errors which have since been corrected. For two others, RIOC indicated that the billings were correct; however, the leases had not been amended to show the proper charge. For the seventh tenant, RIOC cited a court-ordered stipulation as the basis for the billing amount. Our review of this stipulation, however, found no basis for changing the agreed-to rent.)

Upon further review, we found a serious weakness in the internal controls over RIOC's practices for negotiating and documenting changes to commercial leases. According to RIOC officials, several tenants have had difficulty sustaining their operations on the Island, consequently, they have sought to reduce their rent. When a tenant requests a reduction of the monthly rent, RIOC's Counsel might negotiate with the owner and authorize a reduction of the rent. However, there are no records of the negotiations and there are no formal written procedures for a review of the tenant's financial status before the rents are reduced. For example, a gift shop on the Island had a valid lease that required a monthly rent of about $5,000. However, this tenant was paying RIOC only about $3,300 per month, $1,700 lower than the agreed-to rent.

11 When we checked with RIOC officials on this reduction in rent, we were informed that RIOC's Counsel had made an informal agreement to reduce the rent after the tenant claimed a financial hardship.

RIOC officials were unable to demonstrate to us how they evaluated the tenant's financial condition before authorizing this reduction. Further, we could find no evidence that the reduction in rent was authorized by the RIOC Board of Directors, as required. In another case a reduction in the monthly rent of nearly $500 was implemented without the benefit of supporting documentation. We were told that both these and other such reductions were verbally approved by the RIOC President; however, RIOC could not demonstrate that a thorough investigation of the tenant's ability to pay was performed.

During our examination of the commercial leases, we also observed that RIOC's recordkeeping for rents due RIOC was weak. To properly present RIOC's financial condition, records of accounts receivable should be accurate. As of December 31, 1993, RIOC's records indicated that total accounts receivable amounted to $457,350. After we questioned some of the accounts receivable balances, a RIOC official stated that the balances were incorrect and needed to be updated. They made adjustments to the balances and reported that accounts receivable was $345,293 as of January 31, 1994. The certified statements, as of March 31, 1994, reported accounts receivable for commercial tenants as $284,320. Based on these facts and the RIOC billing problems described earlier, it appears that RIOC's recordkeeping is not kept timely and that accounts receivable have been reported inaccurately. If RIOC hopes to successfully pursue these accounts receivable, it is paramount that accurate records be maintained.

12 Recommendations

5. Develop procedures for the review of a tenant's financial status when a request is made for a rent reduction.

6. Ensure that all changes in commercial lease terms are document- ed, formalized and approved by RIOC's Board of Directors.

7. Ensure that the amounts billed to commercial tenants adhere to the terms of the signed leases, or valid approved rent reduction amendments.

8. Correct balances of commercial tenants' accounts receivable and pursue collection of valid outstanding balances.

(RIOC officials stated they lack sufficient staff to adequately monitor commercial operations. They also reported that many of the errors we identified have been corrected and documentation has been included in the files. Lastly, they indicated that the accounts receivable records are now accurate.)

Revenue Collection In a good system of internal control, revenues are deposited promptly. Each deposit should include all monies collected since the previous deposit and in the same form as originally received. An employee of the tram contractor is responsible for collecting the cash from the token sellers and depositing it into RIOC's bank account. We found that the contractor's employee collects all the cash, but does not deposit it into the bank account. Instead, the employee only deposits cash equal to the amount of tokens used by riders during that day. According to RIOC accounting personnel, this is done to facilitate the recording of revenue earned.

This is not a sound control procedure. The current practice allows substantial amounts of cash to be stored in a safe instead of in a bank account. As part of our audit, we performed a count of the cash on hand at the contractor's office and found that there was $13,352 in undeposited cash collections on hand from the sale of tokens. We had no way of verifying how much should have been on hand. This unnecessary storage of cash is compounded by a lack of accountability.

Employees who are responsible for revenue collection should also be bonded. Although the employee of the tram operator is bonded for the collection of tram revenues, RIOC has given this person the additional duties of collecting and depositing RIOC bus and parking revenues, for which she is not bonded. RIOC officials stated that the employee is bonded for all revenue collections,

13 but we found that all of the functions she performs are not specifically included in the contractor's insurance bond. As a result, RIOC is not insured against the loss of these revenues.

Recommendations

9. Account for and deposit all tram token sale receipts daily.

10. Ensure that the tram employee who collects revenues is properly bonded for the collection of bus and parking revenues.

(RIOC officials reported that more stringent controls over collections have been implemented. Large cash balances will no longer accumulate. They also stated that RIOC Counsel has determined that the tram employee is adequately bonded.)

Collection of Bus RIOC operates a bus system with a fare of ten cents to transport residents and Fares staff around the Island, generally between the tram station, subway station, the apartment buildings and the two New York City hospitals located on the Island. RIOC also provides other limited bus services such as transporting residents to Manhattan for shopping at a one-way exact fare of $1.40. In addition, while the tram was shut down for repairs from December 1993 to February 1994, RIOC operated some commuter buses between the Island and Manhattan.

During the period the tram was not operational, we found that when the bus passengers to Manhattan did not have exact change, the drivers accepted bills, made change and retained the collections on their person. In a good system of internal controls for bus fare collection, the passenger deposits the exact fare. The driver should not collect or handle money. As a result of this breach in controls, there was no way to determine whether all the fares collected by the drivers were remitted to RIOC. RIOC officials modified this procedure after we notified them of our concerns. Although the regular buses to Manhattan were discontinued in February 1994 after repairs to the tram were completed, RIOC still runs a special weekend bus to Manhattan for shoppers. RIOC officials informed us that they would institute the same control for fare collections on this route.

14 Recommendation

11. Ensure that bus passengers are required to use exact change and that all bus receipts are handled properly.

(RIOC officials indicated that they have implemented this recommendation.)

Contracts From April 1, 1991 through January 31, 1994, RIOC had 103 active non- construction contracts with total expenditures of $7.9 million. According to RIOC's procurement contract procedures, contracts over $4,999 must be awarded on a competitive basis. RIOC's procedures permit the waiving of the competitive process in certain situations (e.g., emergency, sole source, etc.)

We determined that 38 of the 103 contracts were awarded on a non-competi- tive basis; however, there was no justification for the award for 9 of the 38 contracts. Further, we believe the nine contracts, for such items and services as maintenance of radio equipment; AVAC filter repair; public relations work; and preventive maintenance of the heating, ventilation and air-conditioning system, should have been put out to bid. The value of these nine contracts ranged from $8,000 to $32,000, with a total of about $159,000 reportedly paid through January 31, 1994.

We also examined documentation for a judgmental sample of ten contracts, each valued at more than $20,000, that were awarded on a competitive basis and found that 5 of the 10 were not awarded to the lowest bidder. RIOC officials did not adequately document the selection of one of the five contract awards made to other than the low bidder. Without adequate documentation, we cannot be assured that RIOC had a valid reason for not obtaining the lowest available price. Pursuant to the Public Authorities Law, RIOC must prepare an annual report of procurement contracts for submission to RIOC's Board of Directors. We found that RIOC does not have complete records regarding its contracts. RIOC did not provide us with an accurate report of active contracts for our audit period. By reviewing RIOC's payment records, we were able to identify an additional 18 contracts which were not on the lists of active contracts provided by RIOC staff.

15 Recommendations

12. Adhere to RIOC bidding procedures and properly document awards made on a non-competitive basis, as well as to bidders who did not submit the lowest bid.

13. Ensure that procurement contract records are complete and accurate.

(RIOC officials cited staff shortages and administrative changes as reasons for the lack of adequate documentation for some purchasing decisions. They stated that the recommendations have been implemented.)

16 Major Contributors to This Report

David DeStefano Frank Houston Seymour Peltin Steve Sossei Tom Trypuc Keith Murphy Harry Maher Mary Simckowitz

Appendix A