Concerns

From Corrective Action Plan AZ

Consider Deleting this Page after a thorugh review.

18.0 Concern: Lack of Public Access to a Citizen Complaint Process

In my search of the Maricopa County Website, I could not identify a County process to submit my questions about lessons learned from the County’s investigation of election anomalies.

I think it’s odd that the County places a research burden on the citizen (me) to find the appropriate process to submit a concern.

18.1. Concern: Less than Adequate Responsiveness

Finding no process, I began to make calls, submit emails, [and make presentations to the Maricopa County Board of supervisors]. Once again the

[Note the exception, Jen]

18.2. Concern: Hot Potato Mentality

One PRR was submitted to the County, which was

18.3. Concern: Misleading Assertion of No Statutory Obligation

The June 27, 2025, the closeout comments of PRR 2025-64 appeared to disregard the A.R.S. The Maricopa County Recorder’s Office closed this PRR by stating “records had been released and asserting no statutory obligation to respond.”

Contrary to the MCRO’s claim, the following statutes appeared applicable to my original PRR.

  • A.R.S. § 39-121 provides that public records in the custody of any officer shall be open to inspection.
  • A.R.S. § 39-121.01(D) requires a prompt, good-faith search reasonably calculated to locate responsive records.
  • A.R.S. § 39-121.01(E) requires citation of legal authority if access is denied in whole or in part.

19.0 Governance: Unresolved Issues

As a benchmark for governance concerns, we utilized the Standards for Internal Control in the Federal Government (a.k.a., the Green Book), which was published by the United States Government Accountability Office in May 2025 in accordance with the Federal Managers’ Financial Integrity Act of 1982 (FMFIA). We assume Arizona Counties are under no obligation to follow federal governance guidance. That said, the Green book states,

“The Green Book may also be adopted by federal entities outside the executive branch and by nonfederal entities, such as state, local, and quasi-governmental entities and nonprofit organizations, as a framework for an internal control system. Management of an entity determines, based on applicable laws and regulations, how to appropriately adapt the standards presented in the Green Book as a framework for the entity.”

Use of the Green Book serves as benchmark for good governance, even if there is presumed to be no County obligation to follow its guidance.

Governance Concerns were identified by observation of Maricopa responses to my inquiries as well as the review of documents provided to me in response to PRR [???].

Documentation provided to Jamie Weinhauer Martin by Maricopa County consisted of the following:

    • Runbeck

    • Dominion

The content of these documents was too lengthy to include in this letter. However, the documents are available as court records for Arizona Superior Court in Maricopa County, regarding Case CV 2035-063720, if additional review is desired.

19.1. Concern: Inadequate Documentation

The Green Book, Overview, Section 2 -Establishing an Effective Internal Control System explains Documentation Requirements. For some Green Book Attributes, documentation is a requirement; its not optional.

While the Green Book is a performance benchmark, Arizona Statutes are obligations that must be fulfilled. The following statutes specify documentation requirements:

  • A.R.S. § 39-121 provides that public records in the custody of any officer shall be open to inspection.
  • A.R.S. § 39-121.01(D) requires a prompt, good-faith search reasonably calculated to locate responsive records.
  • A.R.S. § 39-121.01(E) requires citation of legal authority if access is denied in whole or in part.

Contrary to >>>>>>>>

19.2. Concern: Inconsistent Adherence to Standards of Conduct

Green Book, Principle 1 -Demonstrate Commitment to Integrity and Ethical Values, Adherence to Standards of Conduct how leaders and employees should adhere to standards of conduct. Item 1.08 states, “Management establishes processes to evaluate performance against the entity’s expected standards of conduct and address any deviations in a timely manner.”

19.3. Concern: Lack of Corrective Action Plans

The Green Book, Principle 17 - Evaluate Issues and Remediate Deficiencies, requires controls for 1) reporting of issues, 2) evaluation of issues and 3) corrective actions.

Contrary to Green Book expectations, there is no evidence to suggest Maricopa County took action to report, evaluate and correct any of the election anomalies that was reported in national news following the 2020, 2022, and 2024 elections.

19.4. Concern: Potential Financial Improprieties

No CAP as required by contract

No documentation justifying Amendment changes

No change approval documentation

List specific issues

19.5. Issue: Missing Disaster Recovery Policy

No clear enforceable Disaster Recovery Policy in the Runbeck contract used during a 2020 pandemic election.  Although we can not change that, we can ensure its properly documented and monitored going forward so that type of contract documentation failure does not happen again.    Implementing formal Corrective Action Plans with ongoing monitoring would mitigate risk proactively vs. reactively.