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City of Baltimore Department of Finance -- accounts receivable and billing controls

Baltimore City Audit: $82.7M in Invoices Cancelled, No Sign-Off

Summary

A biennial performance audit from Baltimore's Department of Audits found the city's Department of Finance cancelled 2,774 invoices worth $82.7 million during fiscal 2023-24 -- about two-thirds of a sampled batch already approved before cancellation -- in a system that requires no sign-off or documented reason to cancel a bill. The same audit found receivables aged past Maryland's three-year collection deadline grew from $6.0 million to $8.5 million in 18 months, with no formal write-off policy to clear them from the books.

By Frontinus · July 20, 2026

Baltimore's Department of Finance cancelled 2,774 invoices worth $82.7 million during fiscal 2023 and 2024, according to a biennial performance audit the city's Department of Audits released March 30, 2026. Auditors sampled 60 of those cancellations and found 40 -- about two-thirds -- had already cleared supervisory approval before someone cancelled them. Baltimore's billing system, Workday, requires no approval and no documented reason to cancel an invoice that's already been signed off on, even one issued by staff outside the billing office.

A cancel button with no lock on it

The invoices in question cover loans, leases, utility-marking fees, payments-in-lieu-of-taxes and other bills the city's Bureau of Accounting and Payroll Services issues on behalf of other agencies. In some of the sampled cases, the cancellation was performed by personnel outside the billing function entirely -- staff from the Department of Real Estate and the Department of Housing and Community Development cancelling invoices that originated with the Finance department's own billing team. Auditors were explicit that they found no evidence any of this reflected fraud, but wrote that the gap itself is the risk: an employee with system access could cancel a valid, already-approved invoice and erase the receivable without anyone required to sign off, document why, or review it afterward.

Invoices cancelled, FY23-24
$82.7M
2,774 invoices; about two-thirds already approved before cancellation, which Workday allows with no sign-off
Receivables aged past the collection deadline
$8.5M
up from $6.0M 18 months earlier -- now 37% of all outstanding AR in scope, with no write-off policy to clear it
Balances with no escalation path
$2.74M
Miscellaneous Billing System accounts get only automated notices -- no manual review or Law Department referral
Two-thirds of cancelled invoices had already been approved
Sample testing of the 2,774 invoices (totaling $82.7 million) cancelled during the audit period
Already approved when cancelled
40
Not yet approved when cancelled
20
Source: City of Baltimore Department of Audits, Biennial Performance Audit on Department of Finance, March 30, 2026
View data as table
DOA sampled 60 of the 2,774 invoices cancelled during the audit period and found 40 -- about 67% -- had already cleared supervisory approval before being cancelled, some by staff outside the billing function. The audit found no evidence of fraud, but noted Workday's cancellation function has no approval requirement or documentation trail, which it flagged as a control gap that could mask improper revenue reductions.
Already approved when cancelled40of a random sample of 60 -- Workday requires no approval or documented reason to cancel an already-approved invoice
Not yet approved when cancelled20the remaining sampled invoices, cancelled before reaching approval

Averaged across the full population, each cancelled invoice was worth about $29,800 -- a mid-size municipal bill, not a rounding error, cancelled with no paper trail Workday requires the city to keep.

Money that ages past the point the city can sue for it

A separate finding traces what happens to bills the city never collects at all. Maryland law gives the city three years to bring a civil collection action on most debts before they become legally unenforceable. As of June 30, 2024, about $6.0 million -- 14% of the in-scope outstanding receivables -- was already older than that, some dating to 2010. By December 31, 2025, that had grown to $8.5 million, 37% of the outstanding total -- a roughly 42% increase in 18 months. Baltimore has no formal write-off policy, so instead of being cleared from the books once collection becomes legally foreclosed, these balances simply stay recorded as receivable, overstating what the city can actually expect to bring in.

Uncollectible-age receivables grew 42% in 18 months
Baltimore Department of Finance receivables outstanding more than three years (past Maryland's collection statute of limitations)
June 30, 2024
6
December 31, 2025
8.5
Source: City of Baltimore Department of Audits, Biennial Performance Audit on Department of Finance, March 30, 2026
View data as table
The dollar value of receivables aged past Maryland's three-year civil-collection statute of limitations grew from about $6.0 million (14% of outstanding AR in scope) as of June 30, 2024 to about $8.5 million (37%) by December 31, 2025 -- both figures the audit's own totals, 18 months apart. Baltimore has no formal write-off policy, so these balances stay on the books indefinitely rather than being cleared once collection becomes legally foreclosed.
June 30, 2024614% of in-scope outstanding receivables; includes invoices dating to 2010
December 31, 20258.537% of in-scope outstanding receivables -- both the dollar total and its share of all outstanding AR grew

Notices that came late, referrals that came later

The audit also tested whether the city's own collection process ran on time. Of 60 delinquent accounts sampled, 13 -- about 22% -- never got the required final bill and legal notice at all, and most of the rest went out more than 120 days late. Of the accounts that did get referred to the city's Law Department for possible legal action, half were referred only after the debt had already aged past 910 days -- about two and a half years, closing in on the three-year cutoff for suing at all. Auditors attributed much of the delay to staffing: for most of the audit period, one employee alone handled customer research, notice issuance, dispute resolution, and Law Department referrals for the whole collections unit; the city has since added two more.

One example shows what a missed bill can cost. A taxpayer under a payment-in-lieu-of-taxes agreement went unbilled from July 2011 until the agreement was reissued in May 2025 -- 28 missed semiannual billings the audit estimates cost the city roughly $700,000, without even adjusting for the annual increases the agreement called for. Separately, the audit found the city doesn't record loan receivables at their full value when a loan agreement starts; instead it books each scheduled payment as a fresh bill, which understates what's actually owed and can overstate revenue when principal repayments get counted as income.

The department agrees -- with a 16-month runway

The Department of Finance agreed with all six of the audit's recommendations in its formal response, dated April 20, 2026. Its plan includes writing formal collection and write-off policies, requiring documented approval before an already-approved invoice can be cancelled, and automating parts of the notice process through the city's TaxSmart modernization initiative -- but the department's own timeline stretches the final milestones out to August 2027, more than a year after the audit's release.

  • Baltimore's Department of Finance cancelled 2,774 invoices worth $82.7 million during the fiscal 2023-24 audit period; a sample test found about two-thirds had already been approved before cancellation, in a system that requires no sign-off or documented reason to cancel a bill.
  • Receivables aged past Maryland's three-year collection statute of limitations grew from about $6.0 million (14% of outstanding AR) in June 2024 to $8.5 million (37%) by December 2025 -- roughly a 42% increase in 18 months -- with no formal write-off policy to clear them from the books.
  • Collection follow-up was inconsistent: 22% of a sampled batch of delinquent accounts never received a required legal notice at all, and half of the accounts referred to the Law Department were referred only after nearing the three-year deadline to sue.
  • One payments-in-lieu-of-taxes account went unbilled for nearly 14 years (2011-2025), an estimated $700,000 in missed revenue -- and the city separately doesn't record loans as full receivables at the time they're issued, which can understate what's owed and overstate revenue.
  • The Department of Finance agreed with all of the audit's recommendations, but its own corrective-action plan runs through August 2027 -- more than 16 months after the audit's release.

The audit is explicit that it found no evidence of fraud in the invoice-cancellation control gap -- the finding is about the absence of an approval and documentation requirement, not a confirmed instance of misused funds. Its scope covered eight specific invoice categories (Loans, Leases, Miss Utility, PILOTs, Conduits, PACE Loans, Special Benefit Tax Incremental Funding, and Water/Wastewater Industrial Surcharge) within the Department of Finance for fiscal years 2024 and 2023; it did not cover billing handled outside DOF or collection efforts performed directly by the Law Department. Dollar figures for aged receivables and MBSS balances are the audit's own point-in-time totals, unaudited as of the dates given (October and November 2025, and December 31, 2025 for the year-over-year comparison). All figures and quotations in this piece come from the City of Baltimore Department of Audits' Biennial Performance Audit on Department of Finance, published March 30, 2026 and accessed directly from the city's own hosting domain.

Sources(2) ▾
  • City of Baltimore, Department of Audits (Office of the City Auditor / Comptroller), Biennial Performance Audit on Department of Finance -- Evaluation of Controls over Recording Accounts Receivable and Monitoring of Receipts (FYs Ended June 30, 2024 and 2023) (2026-03-30)The City Auditor's biennial performance audit of the Department of Finance's controls over recording accounts receivable and monitoring collections, covering FY2024 and FY2023. Evidences the aged-receivables findings, the $82.7 million in cancelled invoices, the MBSS follow-up gap, the FBLN/referral-timeliness testing results, the single-PILOT non-billing example, and the Department of Finance's management response and corrective-action plan (Appendix I). Published directly on the City of Baltimore's own asset-hosting domain and linked as the canonical report from the Comptroller's official audit-reports page. s3.amazonaws.com · original document
  • City of Baltimore, Office of the Comptroller, Audit Reports -- Office of the City Auditor (2026-07-20)The Comptroller's official audit-reports index page, confirming this report's title, release date, and the canonical link to the PDF above -- used to verify the primary document is the issuer's own official copy rather than a third-party mirror. baltimorecity.gov · original document
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