04 Bell Harbor

Internal Audit Report 

Third-Party Management Services Agreement 
for 
Bell Harbor International Conference Center 

January 1, 2010, through December 31, 2011 




Issue Date: April 2, 2013 
Report No. 2013-03

Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 

Table of Contents 

Transmittal Letter ..................................................................................................................... 3 
Executive Summary .................................................................................................................. 4 
Background............................................................................................................................... 6 
Highlights and Accomplishments ........................................................................................... 6 
Audit Scope and Methodology ................................................................................................ 7 
Conclusion ................................................................................................................................ 8 
Schedule of Findings and Recommendations ........................................................................ 9 
1.     Port Management Monitoring Could Be Strengthened ............................................... 9 












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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 
Transmittal Letter 

Audit Committee 
Port of Seattle 
Seattle, Washington 

We have completed a third-party management services agreement audit of Bell Harbor International
Conference Center (BHICC). 
We reviewed information relating to the period January 1, 2010, through December 31, 2011.
We conducted this performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We
believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on
our audit objectives. 
We extend our appreciation to the management and staff of Real Estate Portfolio Management, Columbia
Hospitality Inc., Seaport Finance and Budget, and Accounting and Financial Reporting staff for their
assistance and cooperation during the audit. 


Joyce Kirangi, CPA, CGMA 
Director, Internal Audit 








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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 
Executive Summary 

Audit Scope and Objective The purpose of the audit was to: 
1.  Evaluate and assess whether Port management monitoring controls are working effectively to ensure:
a.  Billings are complete and accurate. 
b.  Expenses are proper and in accordance with the agreement terms and conditions. 
2.  Determine whether Columbia Hospitality, Inc. complied with the terms of the agreement. 
We reviewed information for the period January 1, 2010, through December 31, 2011. 
Background  The Port of Seattle owns and operates the Bell Harbor International Conference Center
(BHICC) as a trade and meeting place for local and international businesses. The BHICC's goals "are to
maintain the highest quality international conference center, which supports the Port mission of fostering
international trade and commerce" 
BHICC derives most of its revenues from a full range of conference services including, but not limited to, -
food and beverage, meeting room rental, and catering for private and social events. The Port is responsible
for all operating costs, including maintenance and labor related to the facility. 
The Port has outsourced the day-to-day operations and management of BHICC to Columbia Hospitality,
Inc. (Columbia Hospitality hereinafter) under a third -party management services agreement.  The
agreement provides a 3% Base Management Fee, based on gross revenue, and an Incentive Management
Fee up to 27.5% of the Net Operating Profit. 
Audit Result Summary  Port management monitored the third-party management agreement to provide
reasonable assurance relating to the achievement of agreement objectives. However, we identified an
opportunity for management to strengthen its monitoring controls to ensure proper support and reasonable 
allocations of labor costs. 
Columbia Hospitality, Inc. materially complied with the terms of the Management Services Agreement.
However, as reported in the finding, we identified instances of noncompliance with allocated payroll
reimbursements and related party billings as follows: 
I.  Unreasonable and Inadequately Supported Columbia Hospitality Employee Cost 
For the audit period 2010 and 2011, the Port paid $387,700 and $399,941, respectively, as
reimbursements for Columbia Hospitality Human Resources and Accounting corporate services.
Columbia Hospitality invoiced the Port based on budgeted figures, as opposed to the actual costs 
incurred. Reimbursement based on the budget is contrary to the terms of the agreement, which
require reimbursement to Columbia Hospitality be based on actual costs incurred. 
Considering the relative size of the Port Facility (BHICC) to the Columbia Hospitality property
portfolio and the size of BHICC workforce, we determined that the percentage of Columbia
Hospitality corporate services cost (i.e., Columbia Hospitality Accounting and Human Resources) 
allocated to the Port is unreasonable. For example, while BHICC employs approximately a
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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 
seventh (100 of 700) of the Columbia Hospitality workforce, it was responsible for 54% of the total
2010 payroll corporate services. 
During the audit period, BHICC payroll expenses included approximately ten positions (excluding
positions reimbursed based on budget), for which the Personnel Action Form (PAF) could have
documented support for the costs allocated to the Port. However, we noted five instances where
the PAF was absent to support the payroll costs charged to the Port. Included in the exceptions
was the position of Director Sponsorship for WTCS, which was charged 80%, or approximately
$110,607, to the Port. 
During the audit period, we identified 24 instances where the Port reimbursed Columbia Hospitality 
for Paid-Time-Off (PTO) that employees had earned from non-Port facilities. Columbia Hospitality 
should not commingle Public Funds with private activities. 
Columbia Hospitality has a dedicated workforce for BHICC Facility in areas such as Sales, Food &
Beverage, and Conference Services. We determined that allocating almost 100% of executive 
positions in Sales and Food & Beverage to the Port is unreasonable, given: 
o  Columbia Hospitality recruited the Sales position as a non-BHICC position, and we noted
no objective evidence to suggest any subsequent changes in the job responsibilities. 
o  The positions provide high-level direction and oversight in their respective areas for all
properties managed by Columbia Hospitality. As such, the benefit extends beyond one
particular property, and the Port should not bear most of the costs. 
We determined that allocations for Executive Chef positions in Food & Beverage weren't fully
supported: 
o  Mileage reimbursement claims by the positions for travel to and from other non-Port
properties  under  Columbia Hospitality  management  demonstrate that the positions
benefited more than BHICC. 
o  Publicly available information in social media and websites - which have become an
additional source of audit evidence - indicates that these positions work at multiple
Columbia Hospitality-managed properties. 
o  The positions received incentive payouts in 2010 and 2011 for having contributed to
accomplishing  performance measures related to non-Port facilities/properties under 
Columbia Hospitality management. The positions could not have been eligible to receive
the incentive payouts unless they worked at those non-Port properties. 

II.  Related-Party Transactions 
We observed Columbia Hospitality had not disclosed to the Port some of its related-party
transactions, as required by the agreement. We also observed  other instances where deep 
discounts had been granted to Columbia Hospitality and its affiliates. 



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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 
Background 
The Port of Seattle owns and operates the Bell Harbor International Conference Center (BHICC) as a trade
and meeting place for local and international businesses. The Facility has been in operation since 1995.
The BHICC's goals "are to maintain the highest quality international conference center, which supports
the Port mission of fostering international trade and commerce" 
BHICC derives most of its revenues from a full range of conference services including, but not limited to,
food and beverage, meeting room rental, and catering for private and social events. The Port is responsible
for all operating costs, including maintenance and labor related to the facility. 
The Port has outsourced the day-to-day operations and management of BHICC to Columbia Hospitality,
Inc. (CHI), under a third-party management services agreement. Columbia Hospitality is a hospitality
management and consulting company whose portfolio includes facilities in Washington, California,
Montana, Idaho, as well as global consulting. Columbia Hospitality employs approximately 750 employees
and assigns 110 full and part-time employees to the Port's BHICC operations. 
The management agreement provides a 3% Base Management Fee, based on gross revenue, and an
Incentive Management Fee up to 27.5% of the Net Operating Profit. 
Financial Highlights (in thousands) 
2011    2010 
Revenue 
Food & Beverage                      $2,770   $2,936
Conference and Meeting Room               2,729    1,841 
Audio Visual                             1,358    1,052 
Other                                 1,719    1,593 
Gross Revenue                        $8,576   $7,422 
Expense 
Cost of Sales                            $1,272   $1,133 
Direct Expenses                         2,695    2,647 
Operating Expenses                      1,952    1,787 
Fixed Expenses                          261     234 
Management Fee                      257     222 
Incentive Management Fee                   351     142 
Maritime Event Center net income/(loss)             (2)      (2) 
Operating Expenses                       $6,790   $6,167 
Net Income/(Loss)                         $1,786   $1,255 
Data source: BHICC Profit & Loss Statements. 

Highlights and Accomplishments 
During the course of the audit, we observed the following highlights and best practices: 
Columbia Hospitality submits a detailed annual budget for the Port's approval. The budget includes
monthly budgeted amounts by detailed categories of expense types and the details of assumptions
used in preparing the budgeted expenses. 

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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 
On a monthly basis, representatives from the Port's Real Estate and Seaport Finance & Budget
departments meet with Columbia Hospitality management to review BHICC reports and activities, 
which include the following items: 
o  Analyses of operating performance forecast for two quarters. 
o  A summary financial statement line item review including an explanation for the variances. 
o  A review of a monthly disbursement list (i.e., vendors and payroll), from which a sample of
checks is randomly selected for Port management review in detail  improvement since the last
review. 
o  A review of sales and marketing activity reports. 
Through its hospitality business, Columbia Hospitality creates jobs in the Puget Sound region. This
is in line with the Port's strategy for creating additional jobs in the region.

Audit Scope and Methodology 
We reviewed information for the period January 1, 2010, through December 31, 2011. We utilized a riskbased
audit approach in planning and testing. We gathered information through research, interviews,
observations, analytical reviews, and obtained a complete understanding of the Bell Harbor International
Conference Center (BHICC) management agreement. We assessed significant risks and identified controls
to mitigate those risks. We evaluated whether the controls were functioning as intended. 
We applied additional detailed audit procedures to areas with the highest likelihood of significant negative
impact as follows: 
1.  To evaluate and assess whether Port management monitoring controls are working effectively to
ensure compliance with the agreement terms: 
We reviewed the monthly disclosure on related-party transactions for the audit period. 
We analyzed payroll reimbursement requests for three months in 2010 and 2011. 
We reviewed controls related to a prior audit issue concerning employee costs. 
We reviewed the Port's management analysis of Columbia Hospitality Inc.'s financial information,
which is used to verify the accuracy of its management fees. 
We re-performed the management control over vendor disbursements. We traced one month in
2010 and 2011 from the reimbursements to the original records, and verified the validity of
randomly selected disbursement checks. 
We analyzed monthly and quarterly expenses for significant budget variances, which normally
trigger additional management follow-up. 
2.  To determine whether Columbia Hospitality complied with the terms of the agreement: 
We validated BHICC's accounting information, including financial statements. 
We analyzed asset accounts and tested risk-based samples of related bad debt, prepaid expenses,
and accruals. 
We analyzed the financial statements by line-item for significant outliers. 
We analyzed the Banquet Event Order for completeness and appropriateness. We tested a riskbased
sample of 69, which included 53 of 282 events related to Columbia Hospitality and its

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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 
affiliates. Banquet Event Order is a document that itemizes event room, equipment, food &
beverage, and labor. 
We tested risk-based samples of the detailed payroll records and identified some staff 
compensations that were likely unrelated to BHICC. 
We traced January 2010 payroll reimbursements to the source documents for reasonableness. 
We reviewed promotional hosting expenses for appropriateness. 
We analyzed and tested risk-based samples of contractual payments for procurement compliance. 
We tested risk-based samples of inter-company expenses for reasonableness and appropriateness. 
We reconciled insurance requirements to the coverage reflected in the certificate of insurance in
force for the audit period. 

Conclusion 
Port management monitored the third-party management agreement to provide reasonable assurance
relating to the achievement of agreement objectives. However, we identified an opportunity for
management to strengthen its monitoring controls to ensure proper support and reasonable allocations of
labor costs. 
Columbia Hospitality, Inc. materially complied with the terms of the Management Services Agreement.
However, as reported in the finding, we identified instances of noncompliance with allocated payroll 
reimbursements, and related-party billings. 











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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 

Schedule of Findings and Recommendations 
1.  Port Management Monitoring Could Be Strengthened 
Port management has sufficient knowledge of the Bell Harbor International Conference Center (BHICC)
operations. Management has implemented monitoring processes to ensure compliance with agreedupon
terms and conditions. Following a review by Internal Audit in 2009, management made further
improvements in monitoring procedures, especially over vendor disbursements. However, we observed
that management monitoring over areas of high risk (e.g., payroll cost allocation and reimbursements) 
were not effectively focused to ensure compliance. We identified additional opportunities to improve
monitoring controls as follows: 
a.  Unreasonable Employee Cost Allocated To The Port 
The Management Service Agreement, as amended, with Columbia Hospitality, under Section 4, 
states that the Port is responsible for all operating costs including the cost to compensate Columbia
Hospitality employees who work at the Port Facility (BHICC). 
Columbia Hospitality operates in multiple states and overseas regions. In Washington alone,
Columbia Hospitality manages 15 properties, including two properties for the Port of Seattle  Bell
Harbor International Conference Center and the World Trade Center Seattle. Columbia Hospitality 
website states (Retrieved from: http://www.columbiahospitality.com/about.php, Last Accessed:
2/11/2013): 
"The company has steadily grown its portfolio, employing more than 1,200 team members
at properties in Washington, Oregon, Idaho, Montana, and California In addition to
expanding our management portfolio, Columbia has consulted on over 80 hospitality
projects worldwide." 
Company-wide, Columbia Hospitality  employs over 750+ employees.  Some are corporate
employees who provide central services (e.g., Human Resources Dept.) to all properties under
Columbia Hospitality management. Columbia Hospitality assigns the rest of its employees to
specific facilities (e.g., Bell Harbor), where they provide services to the assigned (home) property. 
BHICC payroll expense between direct and allocated charges for the audit period are as follows: 
Bell Harbor International Conference Center Payroll Expenses 
For the audit period Jan. 1, 2010  Dec. 31, 2011(rounded to thousands) 
Payroll Source                                2010      2011 
Direct - based on automate time tracking system            $1,800     $1,830 
Allocated - indirectly charged                           1,400      1,400 
Total                                            $3,200      $3,230 
Data Sources: Bell Harbor International Conference Center Trial Balance and Ceridian Payroll Register. 
Data Note:* Includes salaries and wages only. 
Through a timekeeping system, Columbia Hospitality tracks the time (labor) spent directly on each
facility and charges the facility accordingly. The time tracking system seems to work effectively.
However, we determined that the additional payroll costs indirectly charged the Port through an
allocation methodology are not adequately supported and reasonable as follows:

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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 
i.   Port Reimbursed Columbia Hospitality Based on Budget 
The Port reimbursed Columbia Hospitality for its corporate Accounting and Human Resources 
services attributable to BHICC based on the budgeted figures as opposed to the actual costs 
incurred by Columbia Hospitality. 
Annually, Columbia Hospitality submits a budget to the Port for BHICC operations. Port
management approves the budget as early as three months prior to the operating year. The 
approved budget establishes revenue and expense expectations, and serves as a guiding
document during the year. The budget provides a basis for variance analysis to identify cause
and impact of significant budget departures, which enables management to make informed
decisions. 
The budget is an important monitoring tool, but it does not reflect the actual cost of operations. 
A payment based on the budget is not a reimbursement of the actual cost incurred, but rather a
reimbursement of expectations that could be significantly different from reality. Further, to the
extent that the budget exceeds actual costs, reimbursement based on budget is a Gift of Public
Funds, as the Port cannot demonstrate what it received in return. Thus, the validity of
reimbursements based on budget estimates is questionable, and the practice is contrary to the
terms of the agreement, which require the Port to reimburse Columbia Hospitality based on
actual costs. For the period 2010 and 2011, the Port reimbursed Columbia Hospitality $387,700
and $399,941, respectively, based on budgeted figures, not actual costs. We learned that this
practice of reimbursing Columbia Hospitality based on the budget has been the practice for a
number of years. 
When we compare the Port approved budget (for two of the Columbia Hospitality departments),
to the actual reimbursements for demonstration purposes, the calculation results in a potential
over reimbursement of approximately $58,000 for the calendar year 2010 (See Attachment A
on page 14 of this report). This demonstrates the possible shortcomings of budget-based 
reimbursement. 
ii.    Unreasonable Cost Allocations to the Port Facility (BHICC) 
As stated above, the Port reimbursedColumbia Hospitality for its corporate Accounting and
Human Resources costs for the calendar year 2010 as follows: 
Columbia  Hospitality      Total Columbia    Port Payroll     % of BHICC Payroll to
Department            Hospitality Payroll    Reimbursement    Columbia Hospitality's
Expenses*       for BHICC            Total Payroll 
Accounting                    $349,459            $167,157               48% 
Human Resources               362,236           219,543             61% 
Total                          $711,695            $386,700                54% 
Data Source: Columbia Hospitality Budget, Worksheets, and general ledger. 
Data Note: * Includes salaries and wages only. 
Considering the relative size of BHICC to the Columbia Hospitality property portfolio and the
size of BHICC workforce, the percentage of Columbia Hospitality corporate services costs
allocated to BHICC is unreasonable. For example, while BHICC employs approximately a
seventh (100 of 700) of the Columbia Hospitality workforce, it was responsible for 54% of the
total 2010 corporate services payroll cost for the two departments. Even in consideration of
the BHICC's unique personnel needs and seasonal ups  and downs in workloads, the
allocation seems disproportional and unreasonable.
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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 

ColumbiaHospitality has hired a dedicated workforce for BHICC Facility in areas such as 
Sales, Food & Beverage, and Conference Services.  During the audit period, the Port
reimbursed 100% of BHICC actual compensation for employees (approximately 18 positions)
in the above groups. 
In analyzing Port reimbursements to Columbia Hospitality and the supporting documents, we
determined that the Port reimbursed almost 100% of the following Columbia Hospitality 
corporate positions:
Corporate Position                        2010           2011 
Vice President of Sales                        87%             88% 
Director of Operations - Food & Beverage           83%            100% 
Data Source: Bell Harbor International Conference Center General Ledger and Payroll Record 
Our review of the Offer of Employment Letter for the above positions indicated that Columbia
Hospitality recruited and hired the VP of Sales as its employee (not dedicated to any of its
managed properties). Accordingly, the Port should not have been responsible for the almost
entire compensation for the VP of Sales. When asked, Columbia Hospitality could not provide
objective evidence for any changes in job responsibilities that would have supported the
allocation to the Port. 
As noted before, Columbia Hospitality operates in multiple states and overseas regions. 
These positions provide high-level direction and oversight in their respective areas for all
properties managed by Columbia Hospitality. As evidenced by mileage reimbursement claims, 
the benefit of the positions extends beyond one particular property. While BHICC received
certain benefit from the positions, their dedication to BHICC services could not have been to
the extent observed in reimbursements. Thus, for the Port to have reimbursed substantially all 
of the positions' compensation is unsupported and unreasonable. 
Positions Dedicated To BHICC May Not Be Fully Benefiting BHICC. 
Columbia Hospitality has an incentive program to promote employee performance. When
employees achieve certain defined performance measures, Columbia Hospitality awards them
additional incentive pay. As the program is property- or facility-specific (e.g., gross receipts at
BHICC), the incentive would not be available unless the employee contributed (i.e., working at
the property) to the success of meeting that performance measure. 
We observed that the Executive Sous Chef and the Executive Chef positions in Food &
Beverage  received incentive  payouts  in 2010  and 2011,  from other non-Port
facilities/properties that Columbia Hospitality manages. Considering how Columbia Hospitality 
formulates the incentive program, the above positions could not have been eligible to receive
the incentive payouts unless they worked at those non-Port properties. 
We also noted mileage reimbursement claims by the positions for travel to and from other
non-Port facilities managed by Columbia Hospitality. Such mileage reimbursement claims
demonstrate that the positions benefit more than BHICC. In addition, the review of publicly
available information in social media and websites - which have become an additional source
of audit evidence - indicates that these positions work at multiple Columbia Hospitalitymanaged
properties. Thus, fully allocating the chefs' compensation cost mostly to the Port
Facility - Bell Harbor Conference Center  is unreasonable. 
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Internal Audit Report 
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January 1, 2010, through December 31, 2011 

iii.    Columbia Hospitality Standard Operating Procedures  requires a Personnel Action Form (PAF) 
when designating a home facility or title, which serves as a basis for subsequent cost
allocations: 
PAFs are used for new hires, rehires, terminations, wage changes, time-offs, etc. 
The PAF "must list the property the team member is currently working at or being hired
or transferred to work at the top of the PAF". 
During the audit period, BHICC payroll expenses included approximately ten  positions 
(excluding positions reimbursed based on budget), for which the PAF could serve as support 
for the allocated costs. However, we noted five instances where the PAF was absent as
support for the payroll costs charged to the Port. Included in the exceptions was the position of
Director of Sponsorship for WTCS, which was charged 80%, or approximately $110,607, to
BHICC. 
iv.   Columbia Hospitality designates a home facility for each employee. The designation is used to 
accrue and subsequently compensate Paid-Time-Off (PTO). The method does not consider the
actual distribution of working hours; that is,  the home facility where the benefit is wholly
accrued/paid may not be the facility where the employee works all of his/her time. In cases 
where the employee worked at multiple facilities, Columbia Hospitality should have, but did not,
assign PTO to facilities where the benefit  was earned.  BHICC PTO compensation was 
approximately $176,000 and $220,000 in 2010 and in 2011, respectively. 
During the audit, we identified 24 instances where BHICC compensated for PTO hours accrued
under non-Port facilities. Columbia Hospitality should not commingle Public Funds with private
activities. 
b.  Related-Party Transactions 
Section R of the Management Agreement states: 
"Columbia Hospitality [Columbia Hospitality Inc.] shall not grant discounts (emphasis
added) for any use of the Facility on the basis of any contractual or business affiliations
the user may have with or any entity connected to Columbia Hospitality..." 
In addition, Port management requires disclosure of related-party transactions as part of the 
monthly meeting information. 
We observed the following instances of nondisclosure and noncompliance: 
i.   There was no disclosure of any related-party transactions during the 24-month audit period.
However, our testing noted 282 Banquet Event Orders (related to Columbia Hospitality and its
affiliates. 
ii.    We examined 53 of the 282 related transactions and determined: 
A total of 20 events had not been billed, as of December 31, 2012. 


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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 
The Port compensates Columbia Hospitality fully for the services provided with the agreedupon
management fees. Additional benefits of utilizing the Facility for non-BHICC purposes
do not appear to be the intent of the agreement. 
Columbia Hospitality could not provide objective evidence (e.g., agenda distributed to 
meeting participants) to demonstrate that the 20 events were BHICC business related
meetings. Thus, we consider these events non-BHICC uses, and they are billable revenues 
to the Port conference center as follows. 
Event
Years           Amount 
Count 
2010           1      $600 
2011          19     13,390 
Total           20     $13,990 
Data Source: Bell Harbor International Conference Center Banquet Event Order and price listing 
For nine related-party transactions, we identified an average discount of 47%, ranging
individually from 1% to 63%. Normally, BHICC grants a 10% discount to its preferred
customers. The discount is the difference between the Banquet Event Order (BEO) and the
payment. BEO is a document that itemizes negotiated, not retail, price for event room,
equipment, food & beverage, and labor. BEO is, in essence, an invoice for the customer, to
which a discount could apply. 
Recommendation 
We recommend Port management: 
Ensure Columbia Hospitality is reimbursed for actual compensation expenses (as opposed to
budgeted figures) as required by the agreement terms. 
Obtain a better understanding of the methodology or criteria used by Columbia Hospitality to
allocate its corporate employee costs to the Port Facility. 
o  Re-evaluate the reasonableness of the allocation methodology. 
o  Assess whether the costs reimbursed by the Port exceeded the actual payroll costs
incurred for the audit period. 
o  Ensure that Public Funds are not commingled with private activities. 
Establish written operating and monitoring procedures to ensure that management addresses
the areas of high risks adequately, including identification of related party transactions. 
Clarify in the management agreement: 
o  Who, if any, should receive discounts or be charged at cost for their events held at Bell
Harbor International Conference Center. 
o  That discounts, including no-charge uses, are equitably granted for the use of BHICC
because it is a Public Facility. 


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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 
Management Response 
We appreciate the time and energy that the auditor has given to this audit. The management agreement
that covered the period of this audit has expired. After a lengthy selection process, CHI was chosen to
continue the management of the Port's waterfront Conference and Event Centers. The terms of the new
agreement should provide some management efficiencies and should streamline the monitoring and
accounting functions in the future. 
We generally agree with the factual findings and recommendations of this audit with the following
comments: 
Port and CHI Management have met several times and are working on a more compliant approach
to staff allocation expenses that will not significantly increase the operating costs of the facility. 
Management will expand review and understanding of the methodology of the allocation of CHI
corporate costs with the next budget cycle. 
Management will look at the approach to monthly monitoring of the agreement to identify and focus
on areas of high risk. 
Regarding "discounts"  in the hospitality industry there are often posted "rack rates" but the actual
rates and fees charged are affected by the size, timing, and complexity of the specific event. Port
and CHI Management are working on revising the event booking guidelines and negotiated
package guidelines to ensure that the reasoning and purpose of reduced rates are more clearly
documented. 











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Internal Audit Report 
Bell Harbor International Conference Center 
January 1, 2010, through December 31, 2011 

Attachment A 
Calendar Year 2010 Allocation of Columbia Hospitality Corporate Employee Costs Based on
Budget 
Actual                   Actual
Earnings               Reimbursement
Allocation    from                  Amount to
% from the  Columbia    Auditor's      Columbia
Approved  Hospitality    Calculated     Hospitality      (Over)/ 
Annual    Payroll   Agreed-Upon    Based on      Under 
Budget    Records*   Reimbursement     Budget 
Corporate Accounting           (a)        (b)      (c) = (a) x (b)        (d)          (c) - (d) 
CFO                  50%   $104,401      $52,201      $62,400    $(10,200) 
ASSISTANT CONTROLLER      100%    83,135       83,135       72,384     10,751 
AR Clerk                   100%     25,611         25,611         33,228      (7,617) 
$213,146       $160,946       $168,012     $(7,066) 
Corporate Human Resources 
DIRECTOR OF T&D MGR       50%    $80,686      $40,343      $41,004      (661) 
VP HR                  50%     75,921       37,960        57,996     (20,036) 
HR GENERALIST           100%     66,725       66,725       59,892      6,833 
RECRUITER              50%     2,679        1,340       24,000    (22,660) 
HR/PAYROLL SPECIALIST       50%     40,782       20,391       21,048      (657) 
HR ADMIN.                50%      3,924        1,962        15,600     (13,638) 
$270,717       $168,721       $ 219,540     $(50,819) 
Potential Over Reimbursement     ($ 57,885)
* Actual earnings include salaries/wages only for consistent comparison purposes with budget. We have excluded other
compensations such as vacation, bonus, incentive pay, etc. from the above calculation because these are negotiated as
separate line items in the budget. 








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