Forensic Investigation Frequently Asked Questions

Posted 01.09.2026

What is a forensic investigation and why did Clean Water Services (CWS) contract an independent investigator to complete one?

A forensic investigation uses accounting, auditing, and investigative techniques to examine a company’s finances. Morones Analytics, an outside investigator, examined CWS training, travel, and meal expenditures.

The CWS Board of Directors required the investigation under Resolution & Order 25-5. It was focused on analyzing spending trends and determining whether transactions during fiscal years 2022, 2023, 2024, and the first eight months of fiscal year 2025 complied with federal per diem rates and with CWS policies. Spending related to Clean Water Insurance Company, which is a separate legal entity, was outside the scope of the forensic investigation.

The completion of this third-party forensic investigation — which took place over approximately six months — is the final action item of the Resolution & Order issued by the CWS Board in April 2025 to increase transparency and accountability.

The investigator’s final report and a management response by CWS are publicly available.

Why did the investigation cover only four years?

Documentation for almost four fiscal years of travel, training, and food expenditures was extensive — requiring months of work by the third-party investigator to review records to determine compliance. The investigator also did additional sampling for a deeper analysis of certain expenditures. The period of review provided a quality representative view of recent CWS procedures and spending.

What are the results of the investigation?

The independent investigator created a report that is publicly available. A draft report and its conclusions were based on the travel and training policy in place during the period reviewed. The final report includes an assessment of CWS’ responses to the draft. The assessment shows that all the issues identified by the investigator have been addressed, primarily through the implementation of new policies and through changes in procedures and practices. CWS leadership continues to refine policies and is exploring a small number of remaining recommendations. Here is a summary of the investigator’s recommendations and assessments of CWS responses:

Update the travel/training policy to include all employees and the Board of Directors when acting on behalf of Clean Water Services and/or as a CWS public official with a clear approval process.

Investigator’s assessment: CWS has addressed this recommendation by adding clarifying language that the travel/training policy applies to the CEO and Board and by planning updates to establish a clear approval process for the CEO and Board members.
Require travel/training request and reconciliation forms for all travel and training.

Investigator’s assessment: Planned updates to the travel/training policy to require travel/training request and reconciliation forms for all training, including online training, address this recommendation and will improve the completeness of the Travel-Training Report, enabling greater transparency of total travel and training expenses.
All air travel should be reserved and billed directly to CWS through a CWS-approved travel agency.

CWS response: This recommendation remains under consideration. The current travel/training policy indicates that direct billing to CWS through an approved travel agency is the norm. If an employee purchases their own airline ticket, the cost reimbursed is limited to the price of the ticket or the original quoted price obtained from the travel agency, whichever is lower.

Investigator’s assessment: If CWS determines it is not practicable or appropriate to require all air travel to be billed directly through the CWS-approved travel agency, then a quote from the CWS-approved travel agency should be printed and included with the Travel/Training Request and Reconciliation Forms to ensure that reimbursement does not exceed the rate available.
Revise the travel and training policy to require that lodging booked through a conference or seminar sponsor be at the lowest available rate for the event.

Investigator’s assessment: Management’s planned update to the travel/training policy to comply with this recommendation should clarify that this requirement refers to the lowest available rate arranged by the conference or seminar sponsor.
CWS should go back to its prior policy of prohibiting the use of CWS purchasing credit cards for lodging expenses incurred at the time of travel.

CWS response: This recommendation remains under consideration. No executive staff members hold purchasing cards anymore. There may be a need for non-executive staff to check out travel purchasing cards to be able to travel. Expense reconciliation will address any potentially inappropriate expenditures.

Investigator’s assessment: The recall of purchasing cards from all executive employees will likely significantly improve compliance with the travel/training policy and the meals and refreshment policy, as it will allow greater monitoring because all travel, training, and meal expenses will require approval under the relevant CWS policy and review under the reimbursement and reconciliation processes. If CWS determines it is practicable and appropriate to allow non-executive staff to check out travel purchasing cards, then limiting their use to lodging charges, without any extras, will reduce the need to address inappropriate charges through the travel/training reconciliation process.
CWS should revise the meals policy to define a “business meal” and clarify if employees dining together while traveling for CWS business qualifies as a business meal.

Investigator’s assessment: Management’s plan to revise the travel/training policy to remove “business meals” as an exception and allow reimbursement only at the per diem rate addresses this recommendation.
CWS should clarify if mileage to and from the airport should be reduced for the employee’s daily commute mileage.

Investigator’s assessment: Management’s plan to update the travel/training policy addresses this recommendation and will ensure consistent reimbursement for all employees.
The reconciliation process should ensure that all training, travel, and meal expenses are recorded in the Travel-Training Report, so CWS has greater transparency of such expenses.

Investigator’s assessment: Management’s intention to update the travel/training policy to require all employees attending training, including online training, and/or traveling on behalf of CWS to submit a travel/training request form addresses this recommendation and will improve the transparency of training expenses.
CWS should require an authorization for food purchase form consistent with the form required by Clackamas Water Environment Services.

Investigator’s assessment: Management has addressed this recommendation by intending to update the meals and refreshment policy to require completion of the authorization for food purchase form prior to purchasing food for an event. The planned update to the policy to better define key terms will enhance clarity and promote consistent application of the meals and refreshment policy.

Why are administrative associates/assistants named in the report?

The names of administrative associates appeared in the records examined because they made purchases on behalf of CWS executives and other employees as part of their job duties.

Why were records related to former executives specifically examined?

The third-party investigator examined records pertaining to travel, training, and food spending for the CWS Board and all CWS employees, including anyone serving on leadership team during the period investigated. CWS Board members requested further analysis of specific expenditures. All issues raised around executive spending have been addressed through the return of purchasing cards and other policy changes.

While not part of the scope of the investigation, spending on computers for the former CEO was flagged when the investigator reviewed a sample of purchasing card activity to test compliance with the travel/training policy. As a result of this disclosure and at the Board’s direction, the CEO/GM is now on the same computer replacement schedule as all employees.

Is it still possible for the kind of spending identified on pages 15-17 of the report for business meals and retirement events to occur?

No. As indicated in recommendation #6 above, CWS is updating the travel/training policy to remove “business meals” as an exception and allow reimbursement only at the per diem rate. For retirement celebrations, purchases are limited to light snacks (cake, fruit, cookies, soda, water); CWS will update the meals/refreshments policy to reflect this current practice.

Where is travel to Hawaii in the report?

Hawaii travel was paid for by the Clean Water Insurance Company, not by Clean Water Services, and was therefore outside the scope of the forensic investigation. However, the Board of Clean Water Insurance Company, LLC, has adopted a new travel and reimbursement policy in response to a request on behalf of the CWS Board of Directors and consistent with Resolution & Order 25-5. Additionally, the CWS Board issued Resolution & Order 25-22 in November 2025, directing re-domestication of the captive insurance company from Hawaii to Arizona. This followed a third-party review that determined that Arizona is currently the most favored domicile.

Why do CWS employees and Board members travel to conferences and other training and networking opportunities?

Ensuring our leaders and staff understand and are equipped to address the emerging issues for our industry and organization is critical in the face of the increasingly complex operation of a wastewater and stormwater utility, especially in the uniquely challenging Tualatin River Watershed. CWS policy prioritizes training and travel that is directly related to delivery of services, aligned with the utility’s core mission, required to maintain job qualifications and certifications, or that supports succession planning for the workforce of the future.

The return on investment for travel and training is significant. Knowledge and connections gained across the water sector have spurred innovation that reduces costs, leads to more effective treatment processes, ensures we can meet increasingly stringent environmental regulations, and helps our region adapt to a rapidly changing climate. Learn more about CWS’ connection with the global water sector.