Part I

Executive Summary

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EXECUTIVE SUMMARY

INTRODUCTION

The allocation and utilization of funds intended for extraordinary and

miscellaneous expenses by government agencies are generally governed by
COA Circular No. 85-55A dated September 8, 1985, and Section 25 of the
General Provisions of the General Appropriations Act (GAA) for National
Government Agencies (NGAs), COA Circular No. 2006-001 for Government-
owned and Controlled Corporations (GOCCs), and Section 325(h) of R.A. 7160
for Local Government Units (LGUs).

Extraordinary and miscellaneous expenses as prescribed under these rules and

regulations, shall include, but shall not be limited to expenses incurred for:

• Meetings, seminars and conferences

• Official entertainments
• Public relations
• Educational, athletic and cultural activities
• Subscriptions to professional technical journals and
informative magazines, library books and materials
• Contributions to civic and charitable institutions
• Membership in government associations, national
professional organizations duly accredited by the Professional
Regulations Commission, and in the Integrated Bar of the
Philippines
• Other similar expenses not supported by the regular budget
allocation.

AUDIT OBJECTIVE

The audit was conducted to assess whether the existing systems on the
allocation and utilization of discretionary, extraordinary and miscellaneous
funds were effective in ensuring that the limitations prescribed under existing
rules and regulations were observed and that funds were used for the purposes
intended.

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 EXECUTIVE SUMMARY

EVALUATION CRITERIA

To achieve the audit objective, the team considered the following evaluation
criteria for assessing the agencies’ effectiveness in controlling the allocation
and utilization of discretionary, extraordinary and miscellaneous funds:

• Conformity with the following prescribed limitations:

o LGUs - 2% of Real Property Tax collection in the next

preceding year
o GOCCs - amounts prescribed in their respective
charters or, in its absence, rates provided in the GAA

• Judicious spending of funds focusing on:

o Spending funds for the purposes intended

o Proper documentation of expenses

AUDIT SCOPE AND METHODOLOGY

The audit covered the review and evaluation of appropriations and reported
discretionary, extraordinary and miscellaneous expenses incurred from CYs
2004 to 2006 by selected GOCCs and LGUs in the National Capital Region,
Regions I, III, VII and X. The audit also covered detailed analysis of selected
CY 2006 expenditures charged against these funds and similar expenses
charged against other accounts. The agencies covered in the audit are the
following:

• Bangko Sentral ng Pilipinas (BSP)

• Land Bank of the Philippines (LBP)
• Philippine Ports Authority (PPA)
• Metropolitan Waterworks and Sewerage
System (MWSS)
GOCCs
• Philippine Charity Sweepstakes Office
(PCSO)
• Philippine Amusement and Gaming
Corporation (PAGCOR)

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 EXECUTIVE SUMMARY

National Capital Region

• City Government of Manila

• City Government of Quezon City
• City Government of Makati
• City Government of Valenzuela

Region I

• City Government of Urdaneta

• Provincial Government of Ilocos Norte

Region III
LGUs
• City Government of Olongapo
• Provincial Government of Nueva Ecija

Region VII

• City Government of Cebu

• Provincial Government of Bohol

Region X

• City Government of Cagayan de Oro

• Provincial Government of Misamis
Oriental

During the audit, the team employed the following audit techniques, among
others:

• Reviewed and evaluated extent of compliance with existing rules

and regulations on the allocation and utilization of funds
intended for discretionary, extraordinary and miscellaneous
expenses and analyzed nature of expenses charged thereon;

• Interviewed concerned GOCC and LGU officials and employees

involved in the allocation and utilization of these funds; and

• Assessed the control/monitoring mechanism for the allocation

and utilization of these funds.

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 EXECUTIVE SUMMARY

AUDIT CONCLUSION

Overall, the audit concluded that the existing systems on the allocation and
utilization of funds intended for extraordinary and miscellaneous expenses by
selected GOCCs and LGUs were not effective in ensuring that the limitations
prescribed under existing rules and regulations were observed and that funds
were used for the purposes intended.

The extraordinary and miscellaneous expenses annual rates of the officials of

selected GOCCs, as approved by their governing boards, ranged from P72,000
to P5.0 million. These rates far exceeded the GAA-prescribed annual rates for
each official of P68,000 to P230,000 by P9,000 to P12.83 million, as shown
below:

Board-approved Rates Annual

Official Rates Excess
Monthly Yearly per
GAA
LBP
BOD
Chairman P 45,000 P 540,000 P230,000 P 310,000
Vice Chairman and LBP
President 35,000 420,000 230,000 190,000
Members 30,000 360,000 230,000 130,000
Senior Executive / Executive
Vice President 30,000 360,000 115,000 245,000
Senior Vice President 25,000 300,000 85,000 215,000
First Vice President 22,500 270,000 80,000 190,000
Vice President 20,000 240,000 68,000 172,000
BSP
Monetary Board
Chairman/Governor 150,000 1,800,000 230,000 1,570,000
Cabinet Representative 60,000 720,000 230,000 490,000
Private Sector - Members 70,000 840,000 230,000 610,000
Deputy Governors 30,000 360,000 115,000 245,000
MWSS
BOT 18,000 216,000 230,000 202,000
Administrator 40,000 480,000 115,000 365,000
Deputy Administrator 18,000 216,000 80,000 136,000
Department Manager 6,000 72,000 63,000 9,000
Chief Regulator 18,000 216,000 80,000 136,000
PPA
General Manager 5,000,000 115,000 4,885,000
AGM-Operations 100,000 80,000 20,000
AGM-Finance and Admin 100,000 80,000 20,000
PCSO
BOD Chairman 5,000,000 85,000 4,915,000
BOD Vice-Chairman/General
Manager 5,000,000 85,000 4,915,000

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 EXECUTIVE SUMMARY

Board-approved Rates Annual

Official Rates Excess
Monthly Yearly per
GAA
BOD Members P 200,000 P 2,400,000 P 85,000 P 2,315,000
PAGCOR
Senior Managing Head 180,000 - 12,906,635 80,000 100,000 - 12,826,635
Managing Head 612,000 - 1,420,000 80,000 532,000 - 1,340,000
Senior Branch Manager 291,000 - 2,782,950 80,000 211,000 - 2,702,950
Branch Manager 233,360 - 3,690,082 80,000 153,360 - 3,610,082

PCSO, PAGCOR and PPA allocated funds for this purpose based on prior
year’s actual expenses plus provision for price increases.

In addition to the excessive rates approved by the MWSS Board for MWSS
officials, a lump sum amount of P2.6 million was still set aside for this purpose
and 12 Division Managers, with Salary Grade below 26, were allocated
P24,000 each annually. This is not in conformity with the provisions in the
GAA that only positions equivalent to Salary Grade 26 and above are entitled to
such expenses.

In view of excessive rate approved for each official, total allocations of these
GOCCs exceeded their total computed allowable allocation by P5.245 million
to P41.671 million. While the respective allocations of LBP, BSP, PAGCOR,
and PPA were not fully expended, their reported expenses still exceeded their
limitation. On the other hand, expenditures of MWSS and PCSO even exceeded
their BOD-approved allocations. Total expenses then exceeded the limitation by
P1.899 million and P198.621 million, as tabulated below:

GAA Board Difference

Allowable Approved Reported Excess Excess
CY Expenditures
Budget Budget Allocations Expenditures
(a) (b) (c) (d=b-a) (e=c-a)
LBP
2006 P 10,641,000 P 17,684,000 P 12,540,925.00 P 7,043,000 P 1,899,925.00
BSP
2006 1,955,000 7,200,000 6,134,729.19 5,245,000 4,179,729.19
PAGCOR
2006 3,700,000 33,127,033 24,407,361.04 29,427,033 20,707,361.04
MWSS
MWSS-CO and BOT
2004 1,752,000 3,932,000 2,701,334.63 2,180,000 949,334.63
2005 1,752,000 3,932,000 81,805,729.93 2,180,000 80,053,729.93
2006 1,752,000 3,932,000 21,058,161.63 2,180,000 19,306,161.63
Sub-total 5,256,000 11,796,000 105,565,226.19 6,540,000 100,309,226.19
MWSS-RO
2004 1,035,000 3,851,324 4,001,239.10 2,816,324 2,966,239.10
2005 1,035,000 1,800,000 4,652,818.19 765,000 3,617,818.19
2006 972,000 2,927,500 11,064,799.00 1,955,500 10,092,799.00
Sub-total 3,042,000 8,578,824 19,718,856.29 5,536,824 16,676,856.29
Total 8,298,000 20,374,824 125,284,082.48 12,076,824 116,986,082.48

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 EXECUTIVE SUMMARY

GAA Board Difference

Allowable Approved Reported Excess Excess
CY Expenditures
Budget Budget Allocations Expenditures
(a) (b) (c) (d=b-a) (e=c-a)
PPA
2004 P 115,000 P 5,200,000 P 4,286,681.00 P 5,085,000 P 4,171,681.00
2005 115,000 5,200,000 899,451.00 5,085,000 784,451.00
2006 275,000 5,200,000 3,686,346.00 4,925,000 3,411,346.00
Total 505,000 15,600,000 8,872,478.00 15,095,000 8,367,478.00
PCSO
2004 2,047,000 20,000,000 10,355,681.00 17,953,000 8,308,681.00
2005 2,047,000 20,000,000 7,101,806.00 17,953,000 5,054,806.00
2006 2,047,000 7,812,000 187,304,603.47 5,765,000 185,257,603.47
Total 6,141,000 47,812,000 204,762,090.47 41,671,000 198,621,090.47
Grand Total P31,240,000 P141,797,857 P382,001,666.18 P110,557,857 P350,761,666.18

Under COA Circular No. 2006-001 dated January 3, 2006, if the ceiling for
extraordinary and miscellaneous expenses were not provided in the GOCC’s
charters, the amounts fixed in the GAA shall be considered as the ceiling. In the
case of the six (6) GOCCs, the GAA provisions apply as the ceiling for these
expenses was not provided in their charters. Thus, in general, upon review by
the DBM of their budgets, GOCCs were instructed to limit disbursements for
this purpose within the rates prescribed in the GAA. In the case of GOCCs
covered in the audit, such instruction was not adhered to.

Likewise, of the twelve (12) LGUs covered in the audit, 9 LGUs did not
consider the limitation for discretionary expenses prescribed under Section
325(h) of RA 7160 of 2% of the Real Property Tax collection in the next
preceding year. Thus, from CY 2004 to 2006, the Sanggunian-approved
appropriations of the 9 LGUs for extraordinary and miscellaneous expenses far
exceeded the prescribed limitations by 1.52% to 3,091.56%, as tabulated below:

Discretionary Amount of
Fund Actual Allocation Excess %
CY Limitation Expense Account Amount Allocation
City Government of Manila
Extraordinary Expenses (883) P 22,938,070.00
Miscellaneous Expenses (883) 6,800,000.00
2006 P12,165,745.16 Sub-total 29,738,070.00 P17,572,324.84 144.44
Extraordinary Expenses (883) 23,467,019.00
Miscellaneous Expenses (884) 6,800,000.00
2005 12,777,936.94 Sub-total 30,267,019.00 17,489,082.06 136.87
Discretionary Expenses (881) 12,370,083.00
Extraordinary Expenses (883) 14,800,000.00
Miscellaneous Expenses (884) 800,000.00
2004 12,370,083.33 Sub-total 27,970,083.00 15,599,999.67 126.11
37,313,765.43 Total 87,975,172.00 50,661,406.57 135.77
City Government of Quezon
Extraordinary Expenses 12,000,000.00
2004 Miscellaneous Expenses 6,231,052.63
16,277,327.09 Total 18,231,052.63 1,953,725.54 12.00
City Government of Makati
2005 25,556,583.65 Extraordinary and 33,430,822.00 7,874,238.35 30.81
2004 22,980,315.65 Miscellaneous Expenses 23,330,000.00 349,684.35 1.52

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 EXECUTIVE SUMMARY

Discretionary Amount of
Fund Actual Allocation Excess %
CY Limitation Expense Account Amount Allocation
P48,536,899.30 Total P 56,760,822.00 P 8,223,922.70 16.94
City Government of Valenzuela
2006 2,676,907.61 2,824,255.00 147,347.39 5.50
2005 2,536,143.13 Other MOOE-Discretionary 2,729,629.00 193,485.87 7.63
2004 2,393,843.62 Expenses 2,656,613.00 262,769.38 10.98
7,606,894.36 Total 8,210,497.00 603,602.64 7.94
Provincial Government of Ilocos Norte
2005 162,146.39 Extraordinary Expenses 217,487.70 55,341.31 34.13
162,146.39 Total 217,487.70 55,341.31 34.13
City Government of Urdaneta
Discretionary Fund (969-1) 114,558.00
Extraordinary Expenses (969-2) 200,000.00
2006 114,658.27 Sub-total 314,558.00 199,899.73 174.34
Discretionary Fund (969-1) 100,000.00
Extraordinary Expenses (969-2) 200,000.00
2005 107,412.39 Sub-total 300,000.00 192,587.61 179.30
222,070.66 Total 614,558.00 392,487.34 176.74
Provincial Government of Nueva Ecija
2006 157,758.81 Extraordinary Expenses (883) 1,300,000.00 1,142,241.19 724.04
Extraordinary Expenses (883) 500,000.00
Discretionary Fund (969-1) 230,500.00
2005 166,855.60 Sub-total 730,500.00 563,644.40 337.80
Extraordinary Expenses (883) 500,000.00
Discretionary Fund (969-1) 311,632.00
2004 222,424.04 Sub-total 811,632.00 589,207.96 264.90
547,038.45 Total 2,842,132.00 2,295,093.55 419.51
City Government of Olongapo
Extraordinary Expenses (883) 705,600.00
Miscellaneous Expenses (884) 2,543,000.00
2006 523,817.46 Sub-total 3,248,600.00 2,724,782.54 520.18
Extraordinary Expenses (883) 4,440,800.00
Miscellaneous Expenses (884) 3,234,000.00
2005 480,526.30 Sub-total 7,674,800.00 7,194,273.70 1,497.17
Extraordinary Expenses (883) 13,816,600.00
Miscellaneous Expenses (884) 4,755,800.00
2004 581,922.86 Sub-total 18,572,400.00 17,990,477.14 3,091.56
1,586,266.62 Total 29,495,800.00 27,909,533.38 1,759.45
Provincial Government of Bohol
2004 170,829.16 Extraordinary Expenses (883) 200,000.00 29,170.84 17.08
170,829.16 Total 200,000.00 29,170.84 17.08
P112,423,237.46 Grand Total P204,547,521.33 P92,124,283.87 81.94

The allocations exceeded the prescribed limitations in view of the practice of

other LGUs to provide separate budgets for discretionary, extraordinary and
miscellaneous expenses. This practice is not in conformity with DBM Legal
Opinion No. L-B-2001-10, which clarified that no amount, other than the 2%
allocated for discretionary fund, should be set aside for extraordinary and
miscellaneous expenses as both have the same purpose.

In its review of the LGUs’ budgets, the DBM has also disapproved the
excessive allocations of some of these LGUs. Despite such disapproval, the
LGUs still adopted their annual budgets.

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 EXECUTIVE SUMMARY

Of the nine (9) LGUs with allocations in excess of the prescribed limitations,
six (6) did not also observe the limitation in spending such appropriations.
Thus, the reported expenditures of the six (6) LGUs exceeded the prescribed
limitation by P1.395 million to P62.667 million. Of the six (6), five (5) even
expended in excess of Sanggunian-approved appropriations. In the case of the
Provincial Government of Misamis Oriental, while total expenditures were
within the prescribed limitation, the expenditures in CY 2004 exceeded the
Sanggunian- approved appropriation.

Allocations and expenditures of the 12 selected LGUs are tabulated below:

Excess
Expenditures Over
Appropriations Sanggunian-
CY
Sanggunian- Reported Allowable Approved
Allowable Approved Expenses Allocation Allocation Appropriation
(a) (b) (c) (b-a) (c-a) (c-b)
Manila
2006 P 12,165,745.16 P 29,738,070.00 P23,158,843.10 P17,572,324.84 P10,993,097.94 P -
2005 12,777,936.94 30,267,019.00 21,609,749.71 17,489,082.06 8,831,812.77 -
2004 12,370,083.33 27,970,083.00 17,786,195.91 15,599,999.66 5,416,112.57 -
Sub-total 37,313,765.43 87,975,172.00 62,554,788.72 50,661,406.55 25,241,023.29 -
Quezon City
2006 18,946,217.15 18,000,000.00 17,394,078.81 - - -
2005 19,633,632.58 18,000,000.00 13,621,492.36 - - -
2004 16,277,327.09 18,231,052.63 14,816,127.22 1,953,725.54 - -
Sub-total 54,857,176.82 54,231,052.63 45,831,698.39 1,953,725.54 - -
Makati City
2006 27,108,007.55 22,930,000.00 11,948,425.74 - -
2005 25,556,583.65 33,430,822.00 7,729,018.70 7,874,238.35 - -
2004 22,980,315.65 23,330,000.00 19,253,232.59 349,684.35 - -
Sub-total 75,644,906.86 79,690,822.00 38,930,677.03 223,922.70 - -
Valenzuela City
2006 2,676,907.61 2,824,255.00 2,910,499.98 147,347.39 233,592.37 86,244.98
2005 2,536,143.13 2,729,629.00 3,613,811.72 193,485.87 1,077,668.59 884,182.72
2004 2,393,843.62 2,656,613.00 2,477,899.53 262,769.38 84,055.91 -
Sub-total 7,606,894.36 8,210,497.00 9,002,211.23 603,602.64 1,395,316.87 970,427.70
Ilocos Norte
2006 191,326.25 191,326.25 30,857,925.65 - 30,666,599.40 30,666,599.40
2005 162,146.39 217,487.70 14,726,142.21 55,341.31 14,563,995.82 14,508,654.51
2004 188,785.25 188,785.25 17,625,151.40 - 17,436,366.15 17,436,366.15
Sub-total 542,257.89 597,599.20 63,209,219.26 55,341.31 62,666,961.37 62,611,620.06
Urdaneta City
2006 114,658.27 314,558.00 287,399.69 199,899.73 172,741.42 -
2005 107,412.39 300,000.00 307,129.85 192,587.61 199,717.46 7,129.85
2004 101,319.58 69,120.00 69,086.17 - - -
Sub-total 323,390.24 683,678.00 663,615.71 392,487.34 372,458.88 7,129.85
Nueva Ecija
2006 157,758.81 1,300,000.00 749,414.10 1,142,241.19 591,655.29 -
2005 166,855.60 730,500.00 981,700.00 563,644.40 814,844.40 251,200.00
2004 222,424.04 811,632.00 684,770.00 589,207.96 462,345.96 -
Sub-total 547,038.45 2,842,132.00 2,415,884.10 2,295,093.55 1,868,845.65 251,200.00
Olongapo City
2006 523,817.46 248,600.00 5,066,703.99 2,724,782.54 4,542,886.53 1,818,103.99
2005 480,526.30 7,674,800.00 8,699,087.05 7,194,273.70 8,218,560.75 1,024,287.05
2004 581,922.86 18,572,400.00 6,542,398.99 17,990,477.14 5,960,476.13 -
Sub-total 1,586,266.62 29,495,800.00 20,308,190.03 27,909,533.38 18,721,923.41 2,842,391.04
Bohol
2006 233,942.19 200,000.00 63,000.00 - - -

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 EXECUTIVE SUMMARY

Excess
Expenditures Over
Appropriations Sanggunian-
CY
Sanggunian- Reported Allowable Approved
Allowable Approved Expenses Allocation Allocation Appropriation
(a) (b) (c) (b-a) (c-a) (c-b)
2005 176,329.99 175,000.00 97,264.25 - - -
2004 170,829.16 200,000.00 72,000.00 29,170.84 - -
Sub-total 581,101.34 575,000.00 232,264.25 29,170.84 - -
Cebu City
2006 3,524,195.00 3,524,195 2,999,130.33 - - -
2005 4,011,905.00 4,011,905 3,418,023.03 - - -
2004 3,594,042.00 3,594,042 3,555,216.83 - - -
Sub-total 11,130,142.00 11,130,142 9,972,370.19 - - -
Misamis Oriental
2006 578,689.58 578,689.00 577,358.31 - - -
2005 662,300.52 662,300.00 394,760.00 - - -
2004 526,091.41 526,091.00 707,124.00 - - 181,033.00
Sub-total 1,767,081.51 1,767,080.00 1,679,242.31 - - 181,033.00
Cagayan de Oro City
2006 2,305,441.52 1,870,000.00 1,831,699.40 - - -
2005 3,068,628.88 1,700,000.00 1,652,200.00 - - -
2004 1,246,244.51 1,246,000.00 1,245,717.00 - - -
Sub-total 6,620,314.91 4,816,000.00 4,729,616.40 - - -
Grand
Total P198,520,336.63 P282,014,974.83 P259,529,777.62 P84,124,283.85 P110,266,529.47 P66,863,801.65

GOCCs and LGUs were also charging other extraordinary and miscellaneous
expenses to other accounts and are using funds for extraordinary and
miscellaneous expenses for expenditures which are specifically prohibited to be
charged thereon.

Propriety of extraordinary and miscellaneous expenses in the aggregate amount

of P19.863 million could not also be assessed as these were either not supported
with documents or the supporting documents did not indicate the purpose for
which the expenses were incurred. In the case of GOCCs, in a number of
instances, meetings/conferences of the same officials were almost daily and
simultaneously even during Saturdays and Sundays as P4.918 million were
spent on these days.

MANAGEMENTS’ COMMENTS

The results of the audit were forwarded to the concerned agencies for
comments. In a number of cases, these were also discussed with the concerned
officials in an exit conference conducted on various dates. The agency officials
submitted explanations on the deficiencies noted, which were incorporated in
the report, where appropriate.

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 EXECUTIVE SUMMARY

In the case of GOCCs, except for MWSS, the concerned officials claimed that
their respective Board of Directors are authorized under their respective
Charters to approve their budgets, which include allowances for extraordinary
and miscellaneous expenses. They further claimed that considering that their
offices do not get appropriations from the national government and are
performing highly unusual business, they are not covered by COA Circular No.
2006-001 and the ceilings provided for under the GAA for these expenses.
MWSS, on the other hand, informed the team that policies to adopt the team’s
recommendations are being discussed.

They also claimed that charges of miscellaneous expenses against other

accounts are proper as these represents business development expenses and the
like, and that by the nature of their function, there is no need to indicate the
purpose of expenses.

On the other hand, LGUs claimed that appropriations for Discretionary

Expenses and Extraordinary and Miscellaneous Expenses were set separately as
these serve different purposes. On expenditures charged to other accounts, they
further claimed that appropriations are provided for representation expenses and
the like, as prescribed under the NGAS Chart of Accounts.

TEAM’S REJOINDER

The team acknowledged that the governing boards of the GOCCs are
empowered to approve budgets. However, such authority is not without any
limitation and subject to existing rules and regulations, which in this case is the
COA Circular No. 2006-001. The limitation was also imposed by the DBM. In
its approval of the budgets of GOCCs, among the conditions imposed were for
discretionary and miscellaneous expenses to be limited within the rates
prescribed in the GAA and that such budgets are subject, among others, to
auditing rules and regulations.

The need to document expenses is anchored on the basic principle that

government funds shall be spent solely for public purposes. Thus, it is
imperative that the purpose for which such expenses were incurred be
disclosed. Otherwise, there would be no basis for evaluating the propriety and
legality of such expenses.

On the other hand, the issue on discretionary expenses, and extraordinary and
miscellaneous expenses of the LGUs as being one and the same was already
resolved under DBM Legal Opinion No. L-B-2001-10 issued on February 19,

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 EXECUTIVE SUMMARY

2001. For this reason, extraordinary and miscellaneous expenses cannot be

provided appropriations distinct and separate from discretionary fund as these
have the same purpose.

The team also recognized that similar expense accounts including

Representation Expenses and Other Maintenance and Operating Expenses
accounts are prescribed in the NGAS Chart of Accounts and therefore,
allocations for these accounts could be provided by the agency. However, as
disclosed in the report, even expenditures of the Chief Executive, which should
have been charged to the allocation for Extraordinary and Miscellaneous
Expenses, were being charged therein.

AUDIT RECOMMENDATIONS

Considering that extraordinary and miscellaneous expenses are recurring

expenses, the team recommended measures under Part V of the report to
address these deficiencies. In general, the team recommended that the
limitations prescribed under Section 25 of the General Provisions of the GAA
and Section 325(h) of RA 7160 should be strictly observed. It is also
recommended that charging of miscellaneous expenses against other accounts
be stopped, only claims fully documented be processed, funds be spent only for
the purposes intended for and concerned officials be required to submit
documents to assess the propriety of previous charges in an aggregate amount
of P19.863 million.

The Resident Auditors were also advised to take appropriate actions on

excessive allocations and expenditures in excess of the prescribed limitations;
charging of extraordinary and miscellaneous expenses to other accounts,
prohibited expenses charged against extraordinary and miscellaneous expenses
accounts; disbursements which were not properly documented and justified; and
expenditures which were paid twice.

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