Watchdog CPAs Aim to Add Systems of Control Over State Elections

Americans vote at the Olbrich Botanical Gardens polling place in Madison, Wis., on Nov. 8, 2022. (Jim Vondruska/Getty Images)

A small, loose-knit group of certified public accountants (CPA) hopes to convince states to apply the same methods that accountants use to assure integrity in business to bolster voter confidence in elections.

“What we want to do is make sure that eligible voters can find it very easy to vote, and people who are not eligible to vote can’t,“ retired Marine Reserve Col. Frank Ryan told The Epoch Times. ”Then, we want to make sure that every vote that is cast is counted.”

Ryan, a CPA, is a retired state representative in the Pennsylvania House. He left the seat in December, specifically to work on election security, believing he could have a bigger effect on public policy outside the legislature than from within.

It isn’t the first time that he’s been involved in election security. In 2005, when Iraq held its first free election in years to choose an entirely new National Assembly, Ryan facilitated the country’s election. That year, Iraqi voters stuck their fingers in dye so no one could vote twice.

More Than Math

Frank Ryan in Baghdad, Iraq, in 2005. (Courtesy of Frank Ryan)

While many think of CPAs as the arithmetic wizards who handle tax returns, Art Werner of the Philadelphia firm Werner-Rocca Seminars, which trains CPAs, says they do more than math. The CPA code of ethics and the work they do make CPAs the perfect profession to add oversight to elections.

They also set up systems to show how to avoid fraud and can forensically determine if there’s been fraud or mismanagement.

“The main function of a CPA is to do two things: one, to tell people what happened in the past,“ Werner told The Epoch Times. ”To do so, they design systems that can be reviewed in a manner that can guarantee that they are impartial and can guarantee that the results are proper, which allows, for example, banks to have confidence in financial statements that a CPA prepares.”

For example, when banks loan money, they rely on the CPA reports, balance sheets, and income statements prepared by CPAs to determine the health of a company.

“The CPA can design internal systems well beyond this financial structure that do the same thing. Can they design a system of internal controls so that people could redeem trust in elections? The answer is, a CPA can easily do that,” he said.

Adding CPA systems to elections in every state would increase much-needed trust, Werner said.

“Even if every state right now has a system that is working, if the people of the United States have a suspicion that there’s a problem, it lends to the fact that people will then walk away and say that we have an unfair election,” he said. “Maybe the CPA, by their involvement, can establish a system that will say [that] we have set up something that guarantees that it’s fair.

“Even if it turns out the results are the same, people will trust it.”

Inaccurate Voter Records

The Pennsylvania Auditor General’s damning 2019 performance audit of the Statewide Uniform Registry Electors (SURE) system, which is administered by the Department of State, caught Ryan’s attention when it was released.

“We identified tens of thousands of potential duplicate and inaccurate voter records, as well as voter records for nearly three thousand potentially deceased voters that had not been removed from SURE,” the audit stated. “We found that voter record information was inaccurate due to weaknesses in the voter registration application process and the maintenance of voter records in SURE.

“Specifically, voter registration applications remain in pending status for long periods of time—indefinitely in some cases, and although list maintenance activities are performed by counties, insufficient analysis and monitoring has resulted in inaccurate data in the voter records.”

Ryan said he was shocked by the report, which was written by a Democrat auditor general, Eugene DePasquale, to a Democrat-led administration.

“We are very discouraged by management’s response to our draft findings,” the report reads. “We were quite surprised that the DOS' [Department of State’s] response indicates that it strongly disagrees with many of our findings and mischaracterizes information that was provided, or not provided to us in many instances, during the course of our audit.

“With its attempt to refute our findings, DOS does not seem to understand that a primary objective of our audit was to assess the accuracy of records maintained in the SURE system. Our audit procedures disclosed internal control weaknesses related to input and maintenance of voter records, and our data analysis revealed examples of potential inaccuracies, all of which should be properly investigated by forwarding the information to the counties for further review,” it stated.

“We are concerned that DOS, and therefore the counties, will not utilize the information provided to them in the audit because it is assuming that the data in the SURE system is accurate. Our data analysis strongly suggests otherwise.”

The DOS requested the audit, DePasquale wrote, but didn’t seem to grasp the auditor couldn’t properly satisfy the objectives of the audit in accordance with generally accepted government auditing standards without obtaining evidence, which the DOS refused to provide. Robert Torres was the acting secretary of DOS at the time.

Ryan was still a state representative when the 2020 election report was released.

“They said there were approximately 200,000 voters we couldn’t identify,” he said. “I called up a number of CPA firms after the 2020 election to say, ‘Look, I believe that there are irregularities and inconsistencies. Would you be willing to do a forensic audit?’

“Every CPA firm I approached said absolutely not, it’s too politically charged, and we would lose customers over this. I truly understand that.”

His CPA friends asked him why he was getting involved, and he sent them the 2019 auditor’s report.

“They all called me back, all of them, and said, this is negligent on the part of a CPA—it’s called subordination of judgment—for us not to track these issues down,” Ryan said. “I can’t tell who won the [2020] election. The systems are that problematic.”

Not About 2020

Ryan had a group of CPAs who were concerned about election integrity. They tried to look into it and soon saw that questioning elections after the results are in is politically charged.

“My objection was not the 2020 election. It was about the system of internal controls about the election,” he said. “We found that very quickly became overtaken by the perception that we were trying to dispute the election results, which I did, but that wasn’t the basis of the dispute.

“The basis of the dispute was the auditor general’s report, which basically said that there were major flaws in the system of elections. ... Who is better qualified to design systems of controls than the CPA who’s responsible for designing controls in corporations?”

That’s why Ryan and a few other CPAs are writing draft legislation that would encourage states to add a layer of CPA-style system controls to whatever voting system they already have in place in their state.

Under their plan, the Department of State would own the voting process, the auditor general would be responsible for auditing the process, and a “bureau of election audits,” a new agency, would investigate any questions that come up after the election.

In Luzerne County, Pennsylvania, they ran out of ballots in a recent election. A bureau of election audits would investigate how that happened, figure out how to prevent it from happening again, and assess the likelihood that it affected the election results.

Ultimately, the plan is to design a system of controls upfront, before the election, to make sure there are sound, established key performance metrics, which is what a system of internal controls mandates, Ryan said.

When it’s ready, Ryan plans to present the plan to Pennsylvania legislators; there are also CPAs in New Jersey and Maryland ready to promote it. In time, he intends to find an advocacy group to pick up the plan and get it put it place in states across the nation.