For example, the district protocol required that a representative from the FWISD oversee the work, but in several circumstances, the audit found that Assistant Superintendent of Maintenance and Operation Eldon Ray and Tommy Ingram, executive director of maintenance and operations, who would have had oversight responsibility, would allow BCI to begin work without oversight by either of them.
Internal Audit Division Director for the FWISD Jim Kram says that, looking back with hindsight, it is clear that one of the reasons the fraud continued for so long was the lack of internal controls.
Furthermore, the investigation found that contrary to FWISD protocol, Ingram was the only person who saw the invoices, and he never asked his employees in the field to compare what work had been done against what had been billed to the district.
According to Lozano, part of the problem was that the FWISD did not have a system of controls in place at the district level that allowed it to analyze purchase orders by school site, by unit, by product delivered, and by unit price.
Whitley Penn made several recommendations to the FWISD to help prevent future fraud.
Kram and his staff are actively involved in informing FWISD employees of the risks associated with fraud and the methods used to prevent it.