
7
Internal Audit Report
World Trade Center West Building Agreement No. 655
Audit Period January 1, 2007 – December 31, 2008
Summary of Findings and Recommendations
I. Inadequate Monitoring Related to the Third-party Employee Compensation
Costs Paid by the Port
A system of monitoring is necessary to provide management with reasonable assurance of
compliance with agree-upon terms and conditions. Such a system should be based on an
analysis of risks related to the agreement and an identification of key controls that may mitigate
identified risks. Management then determines what controls to monitor and how the controls will
be monitored.
We concluded that the contractor, Wright Runstad & Company, was in compliance with the
terms of the agreement, but observed that the Port management monitoring system of the third-
party employee compensation needs improvement.
As part of the management services agreement, Port management has advanced some working
capital (funds) to Wright Runstand for the payment of the World Trade Center West Building’s
day-to-day expenses. The Port pays for all costs related to the Facility, including costs related to
compensation, benefits, and payroll taxes for the Wright Runstad employees working at the
Facility. Wright Runstad uses the Port working capital (funds) to disburse these payments.
For the Wright Runstad employees working at the Facility, we observed that the Port paid their
benefits based on a certain percentage or estimate. The auditor tested the benefit estimate and
determined it was reasonable, but found no evidence where Port management had reviewed,
questioned, or was aware how employee benefits were calculated.
The auditor also found evidence that Port funds were used to pay for Wright Runstad employee
bonuses, although there was no evidence of a bonus program. Washington State Constitution
does not allow public entities to use public funds to make additional compensation for services
already rendered and compensated.
We acknowledge that Property management group does conduct monthly reviews of WTC-W
expenses, but the review does not seem to address meaningful risks related to this agreement.
Recommendation
• Port management should implement an appropriate level of monitoring and review to
ensure that it is aware of what it pays at the World Trade Center West Facility related to
the third-party employee compensation costs.