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INTERNAL AUDIT REPORT
Operational Audit
Public Art Program
January 2024 to December 2025
Issue Date: March 3, 2026
Report No. 2026-02
Public Art Program
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TABLE OF CONTENTS
Executive Summary ................................................................................................................................................. 3
Background ............................................................................................................................................................. 4
Audit Scope and Methodology ............................................................................................................................... 5
Schedule of Observations and Recommendations ................................................................................................ 6
Appendix A: Risk Ratings ......................................................................................................................................... 9
Public Art Program
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Executive Summary
We completed an audit of the Port of Seattle’s (Port) Public Art Program for the period January 2024
through December 2025. The audit was conducted to assess the overall compliance of the Port with the
Port-wide Arts and Cultural Program Policy Directive (Directive), as well as assess the existence and
accuracy of art assets in the airport.
In the late 1960s, the Port became the first public agency to develop and establish a public art collection.
Since then, the collection has grown tremendously to over 420 pieces. The collection represents a
diverse range of styles and artists, as well as a variety of forms.
Our review concluded that Port management’s monitoring, compliance, and internal controls for
inventory management and art-related spending aligned with established policies and procedures.
However, we identified instances of non-compliance with certain sections of the Directive, which
represents an opportunity where internal controls could be enhanced or further developed. This
opportunity is summarized below and discussed in greater detail beginning on page six of this report.
1. (Medium) The Port is not fully compliant with the Policy Directive on Port-Wide Arts and
Cultural Program (Directive). Specific clauses within the Directive are not being followed and/or
implemented.
The exceptions identified from this issue highlight the need for a more proactive approach to manage
and oversee the Public Art program. This will be especially important as the Port embarks on the
Sustainable Aviation Master Plan (SAMP) and scales up capital spending. Developing annual plans,
reevaluating funding requirements and associated complexities, updating guidelines, and integrating
employee changes will be important parts of the Port’s strategies and priorities over time.
Glenn Fernandes, CPA
Director, Internal Audit
Responsible Management Team
Wendy Reiter, Managing Director Aviation
Arif Ghouse, Aviation Chief Operating Officer
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Background
In the late 1960s, Seattle Tacoma International Airport (SEA) was the country’s first public airport to
establish a public art collection. Since then, the Port has continued “acquiring and incorporating high
quality, modern, and contemporary art” into the airport’s various terminals and facilities. The collection
represents a diverse range of styles and artists, with an emphasis on regional and emerging artists.
Additionally, it features a variety of forms, such as glass, photography, sculptures, paintings, and
digital/ new media.
The Policy Directive on Port-Wide Arts and Cultural Program (Directive) was formally adopted in
November 2019 to “establish a Port-wide Arts and Cultural Program, which returns the Port to its
position as a national leader among its peers for art and cultural programming, promotes art and
cultural programming throughout all Port and Port-related facilities, and engages the public with the
Port.” The Directive includes different components, such as formally establishing a Port-Wide Arts and
Culture Board in charge of reviewing art selections and placement, establishes policy regarding the
calculation of the art pool fund, and includes metrics on how the overall program is evaluated.
A multi-step process, taking multiple months to years, occurs for art assets acquired. Once a decision
has been made regarding the scope and budget, a Request for Qualifications (RFQ) is publicized and
any interested artist can submit a proposal. Once all the proposals are received, the selection panel,
usually comprised of 3 or 5 panelists to avoid ties, reviews the proposals and votes. Afterwards, the
chosen artist is contacted by the Central Procurement Office (CPO) for awarding of the contract. Once
the contract is awarded, the collaboration process between the artist and various key teams (Art
Program staff, architects, engineers, designers, Construction Team, etc) begins. When everything is
agreed upon, the design phase starts. After obtaining approval from Engineering, the fabrication and
creation of the art is performed. Lastly, the installation phase occurs when the art piece is actually
placed into its final location. Depending on the piece itself, the art can be mounted and bolted to walls,
hung onto the ceiling away from an average person’s standing reach, built into the airport’s pillars, or
enclosed in glass. These methods reduce the risk of accidental damage, vandalism, and possible
theft.
See below for a summary of this process, including the major milestones:
Source: Public Art Program
Public Art Program
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Audit Scope and Methodology
We conducted this performance audit in accordance with Generally Accepted Government Auditing
Standards and The Institute of Internal Auditors’ Global Internal Audit Standards. These standards
require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit objectives. We believe the
evidence obtained meets this requirement and supports our audit objectives.
We used a risk-based, judgmental approach to select items for testing. As a result, the findings reflect
only the items tested and should not be interpreted as representative of, or extrapolated to, the entire
population.
The period audited was January 2024, through December 2025 and included the following procedures:
Inquiries and Process Walkthroughs
• Conducted inquiries and walkthroughs with key employees in the Art Program department, to
obtain and gain an understanding of:
o The overall history of the Art Program
o Day-to-day duties and responsibilities of Port staff related to the Art Program
o Acquisition process of art, from beginning to end (This includes the different phases as
mentioned above)
Document Review
• Obtained and reviewed key documents, such as:
o Policy Directive on Port-Wide Arts and Cultural Program (Directive)
o 2009 POS Art Program Policy and Guidelines (Guidelines)
o Public Art Program 2024 Annual Report
o 2024 Annual Workplan
o Agenda and Minutes from Commission Meetings in 2024 and 2025
o Agenda and Minutes from Art Board Meetings in 2024 and 2025
o Full Listing of Art Collection
Validation and Testing
• Inventory of Art Assets:
o Observed 15 art pieces at SEA and traced them to the Full Art Collection Listing
o Selected 15 art pieces from the Full Art Collection Listing and validated their existence
by physical observation at SEA
o Performed a site visit of the storage room to observe how art pieces are stored and kept
when not on display
• Art Pool Funding and Spending:
o Obtained supporting documentation (i.e. Excel spreadsheets and PeopleSoft
screenshots) to understand and analyze how the Art Pool fund was calculated
o Obtained and reviewed a list of all art pool-related spending for the years 2024 and 2025
o For the three largest projects, Internal Audit (IA) selected three expenses for each
project and obtained copies of invoices to review verify reasonableness and amounts
spent
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Schedule of Observations and Recommendations
The Port is not fully compliant with the Policy Directive on Port-Wide Arts and Cultural Program
(Directive). Specific clauses within the Directive are not being followed and/or implemented.
IA selected significant clauses within the Directive to ascertain compliance. We noted the following
exceptions:
A. Section 4A: The “Executive Director (ED) or their Delegate shall develop annual workplans which
outline yearly goals for the Port-Wide Arts and Cultural Program, including art activities, cultural
programming activities, and budget estimates.”
- IA requested copies for both 2024 and 2025. For the year 2025, no annual workplan was
developed. Meanwhile, for the year 2024, a very simplistic 2024 Annual Workplan was created,
containing only two columns: “Ideas” and “Source”, without budget estimates.
B. Section 5F: “Changes in capital construction project budgets shall include a proportional change
to the project’s one-percent allocation for art.”
- IA requested supporting documentation and calculations as evidence that this is being
performed. Per our discussions with management, this is not being followed and is consistently
a contentious subject between the Art and Construction teams. Construction is insistent on
following an informal rule that was developed through emails in late 2021 by members of Senior
Management that are no longer at the Port. However, no formal amendments or policy changes
were officially submitted and approved.
C. Section 6J: “By September 30, 2020, update the Port-Wide Art and Cultural Program Guidelines
to include direction from this policy.”
- IA requested and obtained a copy of the program guidelines to confirm its existence. We noted
that the most recent approved version dates back to Q4 of 2009, which is now over 16 years old.
A current working draft is in progress and according to the Art Program department, was
presented multiple times to the Art Board now but has yet to be formally approved.
Recommendations:
1.) Formalize a process regarding the establishment of a detailed annual workplan in order to aid
the overall direction and operations of the Art Program department, as well as present the Art
Board with a clear vision for the year. This will promote further clarity and transparency as to how
the Art Pool fund is utilized each year.
2.) With approval from Senior Management, collaborate with key members from the Construction
team to revisit and potentially revise the calculation method of each eligible project’s proportional
change to the one-percent allocation for art based on changes in actual budgets. This will
ascertain alignment and compliance with the Directive. If changes need to be made regarding
the overall methodology of calculating the allocation for art, develop a formal amendment and
obtain formal approval from all necessary departments.
1) Rating: Medium
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3.) Finalize and present the current draft of the updated Guidelines to the Art Board for final approval
and implementation. This will ensure compliance with the Directive, as well as ensure that the
Port’s documentation is up to date and relevant.
Management Response/Action Plan:
Management appreciates Internal Audit’s review of the Public Art Program and the collaborative
approach taken throughout the audit. We agree that this is an appropriate time to strengthen
governance documentation and long-term planning for the program as it continues to evolve.
We also want to clarify that the issues identified are not the result of unmanaged spending, missing
assets, or breakdowns in financial control. The audit confirmed that inventory controls and monitoring
of art-related spending are functioning appropriately. The observations instead relate to documentation
completeness, policy interpretation, and the need to modernize program frameworks to reflect current
capital delivery practices.
Management’s response and action plan are outlined below.
1. Annual Workplan
Management agrees that a more structured and formal annual workplan will improve transparency,
prioritization, and program oversight, and will provide clearer direction to the Port-Wide Arts and
Culture Board in carrying out its advisory role.
Action:
➢ Beginning with the 2027 planning cycle, the Port will implement a standardized annual workplan
template that includes program goals, project priorities, and associated budget estimates.
➢ A 2026 interim workplan will be completed in Q2 2026 using the new format and presented to the
Art Board to establish expectations and institutionalize the process.
Target completion: Q2 2026 (interim), Q4 2026 (fully institutionalized process)
2. 1% Allocation Methodology
Management acknowledges Internal Audit’s interpretation of the Directive language. However, the
current funding methodology was implemented following executive-level direction from Port Senior
Management to stabilize long-range art funding using a multi-year CIP projection model. The intent
was to create predictability, align with capital planning cycles, and avoid volatility caused by year-to-
year construction budget fluctuations.
This approach was adopted as a governance decision and applied consistently. The issue therefore
represents a need for policy clarification and formal alignment rather than a breakdown in internal
controls.
Action:
➢ Management will convene a cross-functional working group including representatives from
Aviation, Maritime, Economic Development, Finance & Budget, Capital Development, and the
Public Art Program to review the allocation methodology considering the Directive language.
➢ The working group will engage the Art Board for advisory input as part of its review.
Public Art Program
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➢ If the review determines that current practice should continue, management will bring forward a
formal amendment to the Directive for Commission consideration.
➢ Alternatively, if alignment with the existing Directive language is required, implementation
processes will be modified accordingly to ensure compliance.
Target completion: Q4 2026
3. Program Guidelines Update
The new Public Art Policy & Guidelines have been finalized and were shared with the Board in
September 2025.
➢ Management will upload the document to the Port’s website to ensure public visibility. Michelle
Hart confirmed that Commission approval is not required, noting that after reviewing the Board
Charter, there is no requirement for subsequent Commission adoption of the Board’s Public Art
Policy and Guidelines. A copy will be saved in the Governance archive for reference, and any
future updates should be forwarded to Governance to keep the archived version current.
Target completion: Q2 2026
DUE DATE: Various
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Appendix A: Risk Ratings
Observations identified during the audit are assigned a risk rating, as outlined in the table below. Only
one of the criteria needs to be met for an observation to be rated High, Medium, or Low. Low rated
observations will be evaluated and may or may not be reflected in the final report.
Rating
Financial/
Operational
Impact
Compliance
Public
Commission/
Management
High
Significant
Non-compliance
with Laws, Port
Policies,
Contracts
High probability
for external audit
issues and / or
negative public
perception
Requires
immediate
attention
Medium
Moderate
Partial
compliance with
Laws, Port
Policies
Contracts
Moderate
probability for
external audit
issues and / or
negative public
perception
Requires
attention
Low
Minimal
Mostly complies
with Laws, Port
Policies,
Contracts
Low probability
for external audit
issues and/or
negative public
perception
Does not
require
immediate
attention