City of Chattanooga

Human Resources Department

Beverly L. Moultrie, Chief HR Officer Andy Berke, Mayor

December 10, 2020

Anne Wilkins
Audit Committee Chair

Re: Response in Opposition to the Office of Internal Audit Findings dated

September 25, 2020

Dear Ms. Wilkins:

In accordance with your request, please accept this letter as my Response in Opposition
to the Office of Internal Audit Findings Dated September 25, 2020 (“Audit”). 1 As stated in my
Notice of Appeal, the Audit findings are based on a clearly erroneous assessment of the facts,
evidence, and an incomplete recitation of the relevant events. This Response is intended to
provide a more detailed, but concise statement of the facts and relevant events that precipitated
and preceded the personnel decisions at issue in this matter.

As the Chief Human Resource Officer, I proposed a reorganization of the Human

Resources Department after a 2018 needs assessment was conducted. The needs
assessment confirmed my belief that changes were necessary within my department to provide
for a more efficient delivery of human resource services to the City of Chattanooga. Following
the needs assessment, and a critical point which the Audit fails to acknowledge, I had
numerous discussions and meetings with the Chief Operations Officer and other city officials
regarding the reorganization of the Human Resources Department. For example, the
reorganization changes were discussed and reviewed during monthly budget meetings with
the Deputy Chief Operations Officer, the Chief Financial Officer and the budget team. Finally,
the reorganization was approved through the budgeting process (BFO) and reaffirmed in the
current FY Budget. The reorganization was approved to occur in two (2) phases. The changes
in question were a part of phase 2.

1
This response also relies on the responses set forth in the February 26, 2020 email communication from
Beverly L. Moultrie, Chief Human Resources Officer to Stan Sewell, City Auditor.
Anne Wilkins
December 10, 2020
Page 2
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Following the comprehensive and detailed discussions with leadership which transpired
over several months, I certainly without any equivocation believed that the reorganization of
the Human Resources Department had been approved.

Based on these approvals, in my opinion the submission of JAQ forms “ex post facto”
was not necessary and would have been superfluous. Importantly, prior to the implementation
of the personnel changes at issue a comprehensive assessment and evaluation of existing
positions was completed in 2018, which included job descriptions and salary.

With these approvals in mind, I then followed the applicable policy by executing the
PARF forms to initiate the reorganization of the Human Resources Department. At no time
after I executed the PARF forms, until the Audit, was I aware that the remaining authorized
signatures on the PARF forms had not been obtained. At all relevant times, I believed that
based on the prior approvals referenced herein, that the PARF forms had also been promptly
executed as this matter was a fait accompli.

Because I firmly believed that the reorganization had been approved and the PARF
forms executed, I authorized the Human Resources Department to process the payrate
changes. I would not have authorized these changes if I had not concluded, that all necessary
approvals had been obtained. I am now aware that my conclusion with regard to the execution
of the PARF forms by the other signatories was erroneous, although at the relevant time I
believed otherwise.

With regard to the Audit comment about a delay in providing PARF forms, I affirm that
this is correct. However, the delay was not intentional, but rather was caused by an emergency
leave I took for a personal family matter, closely followed by the onset of the Coronavirus
pandemic and the rolling disruptions to normal work hours. In the midst of these things, my
commitment to provide the forms merely fell off of my radar.

My desire to better serve the administration and the citizens of Chattanooga led to my
aggressive approach in implementing the reorganization which I believed had been approved.
However, in hindsight, my actions should have been tempered by a more deliberate approach
to making personnel changes within City of Chattanooga government. I clearly understand that
the policies and procedures which govern our collective actions are important to achieve an
effective organization. In this regard, the Audit has provided me with a teachable moment and
a learning tool. I certainly appreciate the hard work that went into the Audit, and in the future,
my actions as the Chief Human Resources Officer, will be guided by its critique of this matter
and the findings.

Sincerely,

Beverly Moultrie
Chief Human Resource Officer