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.
Another internal problem was that instead of being an independent body, the FWISD's audit division reported to the superintendent, not directly to the board of education.
Whitley Penn made several recommendations to the FWISD to help prevent future fraud.
They also suggested that the district conduct training sessions for current or potential district vendors that detail the FWISD's regulations for contractors.
Kram and his staff are actively involved in informing FWISD employees of the risks associated with fraud and the methods used to prevent it.
These reviews would strengthen the FWISD's ability to detect fraud early and prevent it in the future.