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an independent personnel system for the District, was examined because we were concerned with its handling of detailing.

D.C. Law 2-139 provides for detailing of employees to other governmental entities and to institutions of higher education. It does not provide for detailing between District agencies. Existing law, as set forth in the District Personnel Manual specifically establishes policy and procedure for detailing between District agencies, including establishment of time limits for details; when details are allowed; required documentation; and approval requirements. We believe that these regulations are consistent with the policy of the new personnel law and may continue to be in force, regulations covering details outside the District are contained in the Federal Personnel Manual, which will no longer apply to

the District.

We found that present regulations governing details of employees as established in the existing DPM are not being followed, resulting in a circumvention of the merit personnel system. Merit principles of classification and evaluation were violated. Budgetary principles have been violated because long-term detailing of employees has resulted in de facto reprogrammings not in accord with budget justifications.

Specifically, we found that interagency details exceeded allowable time limits without required approvals from the D. C. Personnel Office or the Civil Service Commission. Interagency details were not properly documented. Required data was not placed in employee's personnel files. While agencies are required to submit quarterly reports on details that will extend beyond 120 days, the D. C. Personnel Office has not required preparation of such reports. Two agencies filled positions from which employees had been detailed. One agency, by providing a detailed employee was actually paying the training costs for an employee of

another agency. It is impossible to determine the true cost of the operation of the Mayor's office and the offices of the various Assistant City Administrators because of the number of employees detailed to them from other agencies without proper documentation.

The Auditor found that current regulations regarding detailing have not been treated seriously, and their intent is not being fulfilled. It follows that the new personnel act may be similarly misused in the area of detailing. The Auditor recommended that no detailing actions be undertaken pursuant to the new Act until regulations have been adopted; that the Personnel Office certify compliance with law and regulations of all details exceeding 30 days and audit agency detailing practices; and that procedures be adopted to relate detailing actions to the budget control process.

PROCUREMENT OF AN AUTOMATED ELECTION SYSTEM

September 14, 1979

NOTE: At the time this report was completed, this Office had not been given access to information in the possession of the Board of Elections and Ethics, although such access is required by P.L. 93-198. Subsequent to transmission of the report, the Board agreed to make its records available, and answered most of the points raised in the report. A final report will follow at a later date.

As a part of our general procedure in examining procurement practices, and based upon a request from a private concern, we examined the District contract with Diamond International Corporation for an automated election system.

We reviewed the records of the Department of General Services and the District Accounting Office, which processed payment. As explained in the NOTE above, we could not examine records of the Board of Elections and Ethics.

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We found that the equipment was procured without competition; that DGS accepted a negotiated contract for $648,000 without review or analysis; that used equipment was accepted in partial performance of the contract, although all new equipment was specified; that receipt for equipment did not take place when specified so that the contract was paid without all provisions being filled. In a government notorious for its failure to pay bills in a timely manner, this contract, whose execution allowed payment without penalty up to 30 days after delivery, was paid 6 days after acceptance of the contract. By paying 24 days in advance, the District lost approximately $5,000 in interest. What makes this transaction even more extraordinary is that a separate contract for printing ballots executed with the same contractor under the same payment terms was made 72 days late.

The Auditor concluded that sufficient facts exist to indicate that required procurement procedures were violated. * The Departmert of General Services clearly does not have sufficient staff to review negotiated contracts, and sufficient controls were not utilized to insure that the District takes advantage of favorable payment terms. Enough information was not made available to the Auditor to allow him to conclude whether or not a sole-source procurement was proper, and whether or not a proper reduction was made based on acceptance of previously used equipment.

The Auditor recommended that the Mayor and Council establish a unit to supervise negotiated procurements; that the Financial Management System be reviewed to insure that it still control premature payment of contracts; and that the needs and capabilities of the election process and system be presented by the Board of Elections and Ethics with its FY 1981 budget submission.

A later report by the United States General Accounting Office agreed with this conclusion.

LETTER REPORTS

REGULATION OF EMERGENCY MEDICAL TRANSFORTATION February 12, 1979

This was the second report regarding emergency medical (ambulance) transportation. Our first study found that current regulations were not being enforced.

This study found that the District licensed only four of ten private companies which advertised themselves in the "ambulance" section of the Yellow Pages. We found that, contrary to law, non-District ambulances operating in the District, publicly owned ambulances, and District based ambulances were not being inspected twice a year. Most so-called "ambulances" do not carry life support equipment, nor are their personnel trained in such practices.

The major problem appears to be failure of the District to have a regulatory policy taking into account currert medical transport practices. The District has no authority to regulate the medical transportation industry; this is done by the Washington Metropolitan Area Transit Commission. Regulations requiring standards for training of Emergency Medical Technicians are not fully implemented.

The Auditor concluded that a regulatory program relevant to today's industry should be adopted by the Mayor and Council. The Fire Department should be given responsibility for training, certification, inspection and licensing of ambulances and personnel, thus providing better enforcement and integration of private services with the District.

COMPARISON OF DISTRICT AND FEDERAL INCOME TAXES FOR VARIOUS INCOME
LEVELS AND FAMILY STATUS

February 23, 1979

This study was instituted to assist the Council Committee on Finance and Revenue in their consideration of tax reform proposals. This study focused on the differences between taxes levied by the District and Federal Governments on married couples, and families with two children.

The Federal Government does not tax married couples unless their incomes exceed $5,200; families with two children are taxed when their income exceeds $7,500. The District, by comparison, taxes a married couple earning more than $1,700 and a family with two children with an income of $3,350 or more. A District married couple with two children earning $7,000 will receive a rebate from the Federal Government of $100, but will pay to the District $105 in income tax. Single individuals pay taxes to the District at an income of $850, but will not pay the Federal Government any taxes until income is approximately $4,000. CONSIDERATION OF THE MAYOR'S PROPOSED "REAL PROPERTY TAX CLASSIFICATIONS FOR TAX YEAR 1980 ACT."

April 30, 1979

This letter report was prepared to assist the Committee on Finance and Revenue in their consideration of the Mayor's tax proposal.

The Auditor was of the opinion that while the general theme of the proposal was tax reduction, in fact the proposed classifications would result in a tax rate increase for renter occupied homes. This would result from the reclassification of renter-occupied homes from the current residential class to a new commercial class with a higher tax rate. The resulting increase in revenues would result from assessment increases and the rate increase caused by the reclassification action. The bill also would raise tax rates for apartments and commercial properties.

Rates on owner-occupied single family homes would decrease, but revenues would be expected to increase because of increased assessments by including rental-occupied single family homes with business and commercial properties and apartments would benefit owners of apartments and commercial properties.