CITY OF HARTFORD

INTERDEPARTMENTAL MEMORANDUM
Date:
To:

April 27, 2015

James Rovella, Chief, Hartford Police Department

From:

H. Patrick Campbell, Chief Auditor

Telephone:

860.757.9951

Subject:

Special Review of the Accounts and Operations of the Hartford Police

Department Shooting Range

At your request we performed a special review of the accounts and operations of the Hartford
Police Department (HPD) Shooting Range. The scope of our review concentrated on the
purchase and use of and the accounting for ammunition by the HPD.
Background
The HPD maintains a shooting range which is located at 50 Jennings Road in Hartford, CT. The
shooting range is used primarily for police officer firearm training and certification of purposes.
Each police officer is required to meet and maintain State of Connecticut Department of
Emergency Services and Public Protection Police Officer Standards and Training Council
(POST) firearm certification requirements. This requires each police officer to shoot a
designated number of rounds of ammunition per year and achieve a minimum standard score.
According to HPD management, however, they are bound by a more stringent firearm training
and qualification requirement that exceeds the State of Connecticut standards as a result of an
agreement in the settlement of the Maria Cintron, Et Al vs. Thomas Vaughn, Et Al law suit. A
designated police officer is responsible for all aspects of the management and oversight of the
shooting range. This includes, but is not limited to, purchasing, storing and distributing
ammunition and making arrangements for and overseeing required firearms training. During the
fiscal year ended June 30, 2014 HPD budgeted and paid $115,000 and $115,131 for ammunitions
purchases respectively. Potential issues and concerns initially came to light regarding the
shooting range accounts and operations during an inspection that was initiated by HPD
management in March 2014 after a change in firearms training and qualification requirements.
General
In general, we found that the management oversight of and controls over the shooting range
accounts and operations and its police officer administrator (the shooting range administrator)
were not adequate and needed significant improvement. We noted that policies, procedures and
controls over the purchase and use of and accounting for ammunition by the HPD and other
related key functions of the shooting range were not documented or sufficient to manage or
control the operation of the shooting range. In addition, documentation relating to ammunition

purchases, the related inventory and subsequent distribution for use was not adequate to ensure
that all ammunition was properly accounted for, used for HPD purposes and not misappropriated.
Of particular concern is that this was not detected earlier because the shooting range
administrator was circumventing the budget by purchasing ammunition on account without the
knowledge or consent of HPD management. In addition, it appears that the shooting range
administrator was purchasing more than twice as much ammunition than was necessary or
required to meet police officer firearm training and qualification requirements and operate the
shooting range. HPD management indicated that many of these issues were carried over from
prior HPD administrations.
Review Results
Various tests of the purchase and use of ammunition and reviews of the administration and
oversight of the accounts and operations of the shooting range disclosed the following:
1. Shooting Range Accounts and Operations
a. Policies, procedures and controls over the key operations and functions of the
shooting range were not documented and needed significant improvement.
b. The shooting range administrator did not obtain or maintain documentation to support
the periodic purchases of ammunition. It should also be noted, that the system and
methods used by the vendor to account for purchases on account were antiquated and
insufficient to effectively support these transactions. As a result, other than relying on
representations made by the vendor and shooting range administrator there is no other
way to independently verify the accuracy and propriety of the amount of ammunition
purchased, invoiced and subsequently paid for by the HPD.
c. When the shooting range administrator purchased ammunition from the vendor he did
not request or obtain a receipt detailing the date of the transaction or the items
purchased. In addition, the vendor did not record these transactions in an automated
point of sale system or application. The only documentation created and maintained
by the vendor to support these transactions was a manual notation on a 5 by 8 lined
piece of paper. This document was not reviewed, approved or obtained and
maintained by the shooting range administrator to subsequently verify and approve
the transactions for payment.
d. The shooting range administrator did not account for and maintain records of the
inventory of ammunition purchased, held in storage and distributed to police officers
for firearm training or other purposes. As a result, there is no documentation to
support the receipt and recording of ammunition into inventory after purchases were
made, the removal of ammunition from inventory and assignment to police officers
for firearms training or the ongoing perpetual inventory of ammunition on-hand in
storage.
e. Rather than ordering ammunition and having the vendor deliver it to the HPD, the
shooting range administrator was driving up to the vendors store and warehouse in
Greenfield, MA as frequently as once a week to purchase ammunition. This was both

unnecessary and costly. We estimated that this cost the City/HPD at least $110 per
trip or more than $3,000 per year.
2. Shooting Range Administrator
a. Based on standard firearm training qualification requirements and discussions with
HPD management it appears that the shooting range administrator purchased
considerably more ammunition than was necessary or required to meet firearm
training and qualification requirements and operate the shooting range. According to
State of Connecticut Department of Emergency Services and Public Protection POST
range qualification requirements, on an annual basis, each police officer must shoot
four courses consisting of 60 rounds of ammunition. According to HPD management,
however, they are bound by a more stringent firearm training and qualification
requirement as a result of an agreement in the settlement of the Maria Cintron, Et Al
vs. Thomas Vaughn, Et Al law suit. According to the settlement The Hartford
Police Department has implemented a change in its firearms training schedule in
order to improve the efficiency of officers in the familiarization and use of firearms.
Each officer shall now qualify every three months, firing a total of one hundred and
twenty rounds from his issued weapon. During the six fiscal years ended December
31, 2014 the HPD purchased an average of about 485,000 rounds of ammunition or
about 970 rounds of ammunition per police officer assuming a force of 500 police
officers. Based on the state training and qualification standards we estimated that the
HPD would be required to use a minimum of 120,000 rounds of ammunition a year.
Based on the Cintron agreement we estimated that the HPD would be required to use
a minimum of 240,000 rounds of ammunition per year. According the HPD
management, however, they were only shooting four 60 round courses per year per
officer for qualification purposes to reduce ammunition costs. It should be noted that
this met the state training and qualification requirements. In addition, during
preliminary discussions with HPD management they estimated that the HPD was
using closer to 180,000 rounds per year or about 360 rounds of ammunition per police
officer as a result of additional training on the new hand guns and certain police
officers not meeting qualification requirements on the first try. Again, it appears that
the shooting range administrator was purchasing more than twice as much
ammunition annually than was necessary or required to meet police officer firearm
training and qualification requirements and operate the shooting range.
b. The HPD has an established annual budget for the purchase of ammunition. For the
fiscal year ended June 30, 2014 the HPDs budget for ammunition was $115,000. As
with other items purchased by departments throughout the City the standard policy
and procedure for ammunition is to purchase and pay for what is needed on an
ongoing basis while staying within budget or requesting revisions to the budget if
deemed necessary. We noted, however, that the shooting range administrator
circumvented the established budget and applicable policies and procedures by
making arrangements with the vendor to purchase ammunition on account and to pay
for it at a later date and in a subsequent fiscal year. This allowed the shooting range
administrator to exceed the annual ammunition budget without the knowledge or
consent of HPD management. When this came to light by HPD management in

October 2014 the shooting range administrator had accumulated an outstanding and
unpaid balance with the vendor totaling more than $186,000.
c. As part of the process for approving invoices from the ammunition vendor the HPD
Finance Unit would submit them to the shooting range administrator to verify the
accuracy of the items purchased and related charges. Although these invoices were
approved for payment by the shooting range administrator there was no basis for
doing so other than the reliance on his memory. Due to the lack of available
documentation from the point of sale/purchase, there was no other way for the
shooting range administrator to verify the accuracy and propriety of the invoices most
of which were submitted to the HPD by the vendor, in aggregate, months after the
actual purchases were made.
d. The shooting range administrator also purchased significant amounts of 45 caliber and
9 millimeter ammunition for firearms that are no longer or seldom used by HPD. In
2012, HPD purchased all new 40 caliber hand guns. As a result of this, the primary
ammunition used by HPD for hand guns changed from 45 caliber rounds to 40 caliber
rounds. HPD management also indicated that they continue to use a limited amount
of 9 millimeter ammunition for sub machine gun training. Even though this change in
ammunition requirements occurred in 2012 the shooting range administrator
continued to purchase significant amounts of 45 caliber and 9 millimeter ammunition
up to and including October 2014. During the ten months ended October 31, 2014 the
shooting range supervisor purchased 94,500 rounds of 45 caliber and 9 millimeter
ammunition at a cost of more than $33,200.
e. The shooting range administrator acknowledged purchasing the 45 caliber and 9
millimeter rounds of ammunition for the purpose of trading it with other State and
municipal police forces for 40 caliber ammunition. According to the shooting range
administrator, this was necessary because it was difficult obtaining 40 caliber
ammunition due to shortages. The shooting range administrator noted that
ammunition trades were made with East Hartford, Windsor Locks and the State
Police.
f. The shooting range administrator did not account for the distribution of ammunition
to police officers for training or other purposes. As a result there is no record of how
much ammunition was actually being assigned and used by HPD. In addition, there is
no way to reconcile ammunition that was purchased to what was assigned and used.
g. It is not clear when or if there were actual shortages of 40 caliber ammunition,
however as previously noted the shooting range administrator was purchasing 45
caliber ammunition on a regular basis through October 2014. It would seem unusual
that a national ammunition supplier could not and/or would not be able to meet the
needs of the HPD for 40 caliber ammunition.
h. The shooting range administrator did not maintain any records to account for the
dates, times, amounts of ammunition or entities involved in these trades. As a result,
these trades cannot be readily confirmed and the shooting range administrator cannot
provide any documentation to support that the value of the ammunition traded to
other agencies is equal to or less than the value of the ammunition received in return.

i. Ammunition shell casings can either be sold to be used for reloading or for scrap
value. In either case, the HPD should have been selling and receiving revenue from
the disposition of these shell casings generated from ongoing training activities.
There was no accounting for the disposition of used brass/copper ammunition casings
by the shooting range administrator. According to HPD management this was
brought to their attention and addressed in May 2014.
3. Ammunition Vendor
a. The ammunition vendor did not maintain adequate records to support sales of
ammunition to the HPD. The vendor was not using an automated point of sales
system to account for ammunition purchases made by the HPD. Instead, the vendor
used notations made on sheets of a 5 by 8 note pad to account for and support HPD
ammunition purchases made by the shooting range administrator. In addition, there is
no indication on these documents of an acknowledgment or approval of the amounts
noted by the shooting range administrator.
b. The vendor was not billing the HPD in a timely manner for ongoing purchases of
ammunition made by the shooting range administrator. The vendor did not bill the
HPD for 49 ammunition purchases totaling more than $186,000 made by the shooting
range administrator from January 2014 to October 2014 until an inquiry was made by
HPD management. In addition, the vendor did not provide the HPD with periodic
statements detailing purchases and payments made and any unpaid outstanding
balances. Consequently, there was no way for HPD management to be aware that the
shooting range administrator was circumventing the budget process and related
policies and procedures by purchasing ammunition on account or that he had accrued
an outstanding unpaid balance with the vendor of more than $186,000.
HPD management indicated that they immediately put stop gap measures in place to address
these issues as soon as they were brought to light. In addition, HPD management informed us
that they are in the process of developing and documenting policies, procedures and controls over
the key functions and operations of the shooting range including but not limited to the purchase
and use of and accounting for ammunition by the HPD and for the management and oversight of
the shooting range administrator. These policies, procedures and controls should address all of
the issues noted above. We recommend that HPD management provide copies of the policies
and procedures they develop and document to the Internal Audit Department for review and
feedback as deemed appropriate. HPD management also informed us that they will be further
reviewing and following up on these matters separately with the shooting range administrator
including determining what disciplinary and/or other actions to be taken.

copy: City Council Members

Internal Audit Commission Members
A. Cloud, City Treasurer
D. Hill, Chief Operating Officer
A. Ilg, Acting Chief of Staff, Mayors Office
P. Segarra, Mayor