The Numbers
What the City's own documents show, and don't say out loud
An approval is a finding about a specific set of facts. Between December 2023 and today, the largest of those facts grew from $800 million to a stated $10 billion. This page counts what the City assigned to watch it — and closes on the question that follows.
Start with coverageEvery figure below is arithmetic performed on numbers the City of El Paso already publishes — in its Annual Audit Plans, quarterly plan updates, and budget book. Nothing here required a records request. It required reading the inputs the City provides and computing the result the City doesn't.
186 scored. Eight examined.
The department scores 186 auditable areas every year. It has capacity for 8 engagements.
That's roughly 4% annual coverage. At that rate, cycling through the full audit universe once takes about 23 years — longer than most municipal careers.
96% of the scored universe goes unexamined every year. A risk score of 41 and a risk score of 20 produce the same outcome — nothing — for almost everyone.
Thirty of fifty, untouched
60% — 30 of 50 tracked areas — received zero audit or follow-up work in five years. 22 received no engagement of any kind. The top 5 departments captured 54% of all recorded activity.
Where nothing meets the top of the risk list
These areas received no audit engagement of any kind in five years, ranked by the City's own risk score:
The table behind FIG. 03
| Risk score | Area |
|---|---|
| 41 | Animal Services |
| 41 | Housing / Community & Human Development |
| 40 | Purchasing & Strategic Sourcing |
| 40 | Grant Administration |
| 39 | Code Enforcement |
| 38 | Real Estate Division |
| 38 | Information Security Assurance |
| 33 | Risk Management |
| 28 | Office of Emergency Management |
| 28 | 911/311 Communications |
Housing and Grant Administration — the two highest-scored areas on this list — administer federal funds, the category of city operations carrying the most external compliance exposure.
Economic development got 1.8%
The department completed 114 engagements between FY2021 and FY2025: 32 audits, 18 follow-ups, 64 recurring projects.
Economic & International Development received 2 of 114 — 1.8% of all activity. The Tax Office received 21 — 10.5 times as many — and every one was a recurring project, not an audit.
A function spending 1.8% of its capacity on economic development cannot be crowding out the other 98.2%. It is barely audited, like almost everything else the City runs.
Half the year is spent before a risk decision is made
The FY2025–26 plan budgets 12,782 audit hours:
The table behind FIG. 05
| Category | Hours | Share |
|---|---|---|
| Recurring administrative work | 4,160 | 32.5% |
| Contingency | 1,762 | 13.8% |
| Named engagements | 6,860 | 53.7% |
Nearly half the department's year is committed before a single risk-based decision gets made. Inside the recurring block, one line stands out:
The table behind the recurring block
| Hours | Share | Line |
|---|---|---|
| 2,000 | 15.6% | Financial Oversight and Audit Committee support |
| 500 | 3.9% | Cyber Audits (administration) |
| 400 | 3.1% | Hotel Occupancy Tax audits |
| 400 | 3.1% | Tax Office Refund Review |
| 300 | 2.3% | City Employee Hotline |
| 200 | 1.6% | Franchise Fee audits |
| 200 | 1.6% | TX Sales Tax Discovery |
| 160 | 1.3% | Citywide Sales Tax Analysis |
Supporting the oversight committee consumes more audit capacity than any single engagement in the plan — roughly one full-time position's worth of hours, and eight times the 250 hours budgeted for the one engagement that carried a discretionary condition.
The re-underwriting test
Re-underwriting is what a lender does when the facts behind a loan change materially: the analysis is redone and the terms are re-approved against current conditions, rather than the original decision carrying forward on inertia. An approval is a finding about a specific set of facts. When the facts move far enough, the finding no longer describes the thing being governed.
The table behind FIG. 06
| Measure | Dec 2023 | Aug 2026 | Indexed |
|---|---|---|---|
| Stated investment | $800M | $10B | 1,250 |
| Authorized audit positions | 10 | 8 filled, 2 vacant | 80 |
Between December 2023 and today, the City's largest economic-development agreement grew from an initial $800 million to a stated $10 billion. Over the same period, Internal Audit Department staffing was flat at 10 authorized positions, then dropped to 8 filled with 2 vacancies — including the Chief Internal Auditor seat itself, vacant for roughly seven months.
The risk grew by an order of magnitude. The capacity to verify it did not move.
The plan budgets 250 hours to a single 380 follow-up — the one engagement in it carrying a discretionary condition, and one-eighth of the hours spent supporting the oversight committee. That is the entire published commitment to re-examining the largest agreement the City has ever signed.
What a re-underwrite would ask- On today's stated scale, would the original public-purpose finding be made again — and on the same terms?
- Which assumptions behind the original vote have already moved on the public record? The ledger lists twenty-four of them, five clusters, one contradicted outright.
- Who is assigned to answer the first two questions, and in which published document does that assignment appear?