After last week’s missteps in the effort get a joint financial review committee off the ground, town officials are in the process of reconfiguring it, including what its goals are, how it will work, and making sure it’s established per Town Charter rules.
[Editor’s note: the Board of Finance held an early morning special meeting on Wednesday, July 16 to redefine the joint committee’s mission statement and goals, following notice from one Board of Selectmen member that the two boards had approved two different types of committees with scopes, authorities and timelines that did not match. GOOD Morning Wilton will have coverage of that meeting shortly.]
However, the effort to form of a committee to review the town’s financial and operational processes was begun independently by Selectwoman Kim Healy, a Republican, and included collaboration with Board of Finance member Sandy Arkell, a Democrat, and was a first-tier response to issues facing concerns with operations at Town Hall under First Selectman Toni Boucher.
The idea was sparked after Town Hall issued second senior tax credits in January 2025 without required BOS approval, and later the town’s audit flagged a “material weakness”.
Since getting the ball rolling, their work together outside of their respective boards has resulted in the creation of suggested policy documents that advocate segregating the duties of the tax assessor and tax collector, while also outlining internal controls to put in place for a conjoined position.
But whether that initial effort will be used by the joint BOS-BOF Policy Review Committee or even by Town Hall officials seems unlikely.
How it Started
“I reached out to Kim during the budget process when it came to light that there was an elderly tax credit disbursed in a second installment without appropriate authorization and approval,” Arkell said. “Kim was already diving deep into the issue.”
It was by chance that Healy first became aware, in the middle of a Board of Selectmen meeting at the beginning of 2025, that Town Hall had issued a tax credit to seniors without required BOS approval. It started with an offhanded remark made by Selectman Ross Tartell praising the disbursement.
“The meeting was live,” Healy remembered, “so you can hear me say that cannot be possible since we had discussed the process in December and that we were disappointed to have missed the deadline to issue them.”
She said that the mood of the meeting noticeably changed after that moment, with neither Boucher nor Town Administrator Matt Knickerbocker offering any comments, making Healy suspicious that the credits had simply been issued without proper approval.
Conflicting statements later came from Boucher and Knickerbocker about the matter, with Boucher placing blame on the previous administration of First Selectwoman Lynne Vanderslice. Knickerbocker, who also initially cited Vanderslice, ultimately took blame for what he called miscommunication and misunderstanding.
In response, the BOS retroactively approved several different disbursements for installments in 2021, 2023 and 2024.
“I am happy that the payments were given, but we must have accountability for the required approval process,” Healy said, noting that she had to learn from her senior neighbor that the credits were even issued.
“I know there was a lot of reporting on what happened next,” Healy said, with concerns expressed publicly by both the BOS and BOF Chair Matt Raimondi. Selectman Josh Cole publicly asked for an investigation and Healy suggested to the BOS on several occasions that an internal control review should be executed.
“I suggested an internal control review to ensure the tax department and town admin had a written summary documenting the appropriate procedures with proper segregation of duties,” Healy said. “I felt that, at that time, that I would face resistance, so I took it upon myself to get that done.”
Boucher tabled discussion of the matter at multiple meetings, noting it should wait until after budget season.
“So, I researched best practices, asked a CFO from another town for suggestions, and then shared the drafts with Sandy, others and made many edits,” Healy said, with additional feedback obtained from Wilton’s CFO Dawn Norton.
Healy noted that there was no cost to the town involved in her work.
“What I have shared is still a draft and Ross mentioned he has some feedback,” Healy said. “I do not claim it is perfect, especially since I did not review current internal practices, but it has strong controls and segregation of duties that are required of any similar-sized tax departments.”
Despite Healy’s request at the last BOS meeting that the documents be made public in draft form, they were not posted to the town website until well after the meeting, and may also not be the most current version.
[Editor’s note: Healy’s proposed Tax Assessor/Collector Payment Handling Policy and Internal Controls/Segregation of Duties Procedures can be found on the Town’s BOS meeting agenda webpage.]
“I have been told by the first selectman that what I provided will not used,” Healy said, although she hopes her documents will be part of the scope of the consultant hired to review town hall processes.
“I’ll make that recommendation when the committee meets. I did the work I said I would. It’s public information now,” Healy said. “I can’t control what the First Selectman does with it.”
“Internal Controls-Segregation of Duties” Document
“Internal controls are essential in order to reduce the risk of fraud and errors,” the introduction to one document states. “One of the most important controls is segregation of duties. Segregation of duties ensures no single employee has control over all aspects of financial transactions. Ensuring that different employees and/or outside entities handle various tasks within the billing and collections process is critical to minimize the risk of fraud.”
Specifically, the document highlights the distinct responsibilities of tax assessor and tax collector — two roles that in Wilton are currently held by the same individual, Hollie Rapp, Wilton’s manager of assessing and tax collection.
“The two positions involve distinct responsibilities,” it states. “When combined, compensating controls must be implemented to reduce the risk of error, fraud, or misuse of authority.”
As Wilton currently chooses to combine the roles, the document suggests some best practices for mitigating risk, including the use of a lockbox service. “In 2019, Wilton implemented a lockbox,” it states. “In 2024, the lockbox was terminated and payments instead were processed within the tax department, thereby eliminating a key compensating control and increasing the risk of fraud or misuse of authority.”
“The lockbox should be reinstated as soon as possible,” it states.
“The first step should be to open a lockbox for all tax payments,” Healy said.
“The town policy statement that I was provided, and was told is current, says that we currently have a lockbox but we know that is not the case,” she said.
Healy said that both Boucher and Knickerbocker said that they would prefer the roles of assessor and collector be separated, but the matter has not come before the BOS at any time over the past four years for discussion.
“I also know that we can securely continue with the roles being joined if the town puts appropriate policies [and] controls in place,” Healy said.
Material Weakness
Arkell’s work in this process began after an independent auditor found a “material weakness” in Wilton’s Finance Department at the beginning of this year.
“An auditor’s report of Material Weakness is not necessarily isolated to matters of accounting. Often, it can be an indication of potential opportunities to improve operational processes or tighten procedures and policies to mitigate risk and strengthen controls,” Arkell said, noting that the issue of the senior tax credit is one example.
Healy praised Arkell’s work in this process.
“Sandy and I connected when the BOF started talking about the material weakness and how they could address it,” Healy said. “I have been attending their meetings and we chatted after one and met up a week or so later to discuss.”
“I asked her then if she would review the policy and segregation of duties and she agreed,” Healy said. “She was a great resource and extremely helpful with her comments and edits.”
“We continued meeting, being of similar backgrounds, to address the concerns of the BOF and the audit report, specifically the material weakness,” she said. “We documented what would be in an RFP and the significance (of) getting the work independently done.”
Arkell noted Healy’s background as both a CPA and former auditor have helped lead her analysis of this situation.
“I’m grateful to Kim for her passion and sincere commitment to improving the process,” Arkell said, noting that she was “extremely collaborative and receptive” to Arkell’s feedback and interest in the matter.
Process Review Committee
On July 7, Boucher presented the BOS with a plan to form a Process Review Committee, but omitted Healy from joining and instead recommended herself and Tartell.
While Healy expressed her surprise and displeasure at having been left off the committee after all her work and attention to the matter, she was voted down 4-1 in favor of Boucher’s recommendation, with Cole and former Selectman Bas Nabulsi shifting their initial backing of Healy to grant support to Boucher.
“I will ask the newly created committee that is developing the RFP for the process review to include a requirement to review the documents, revise as necessary, and ask for implementation,” Healy said, following word from Boucher that the documents she worked on will not be used.
“At a minimum, we owe the public assurance that we have addressed the error and put controls in place that should prevent it from happening again,” Healy said.
Arkell, meanwhile, was appointed to the committee by the BOF, along with Raimondi.
“As I discussed in our meeting on July 8, I don’t view the scope of work as an audit or a formal investigation,” Arkell said. “The work is better characterized as an independent review conducted by a third party who can issue a report outlining areas of opportunity.”
“The idea is to quickly get to prioritized root causes or pain points that may be contributing to these recent observations,” she said.
Other financial issues that have recently raised questions in town include certain matters relating to the Department of Public Works, including more than $1 million in surplus bonded money sitting in an account, as well as handling of finances in relation to some building projects; and the Parks and Recreation Department, with contract approvals sought before documents have been completed.
“I’m pleased to see our first selectwoman openly embracing this recommendation in a bipartisan manner,” Arkell said, “partnering with our Board of Finance, and demonstrating her commitment to remedy these matters.”
“Ultimately, it is her responsibility to execute the required corrective actions,” said Arkell, a former public auditor with an extensive background in accounting and financial controls.
Raimondi Weighs In
Because the documents haven’t been discussed publicly, Raimondi said he didn’t have anything to add in their regard, but offered praise for the work of Arkell and Healy.
“I appreciate the work Sandy and Kim have done to shine a light on the processes within the tax department and identify opportunities to strengthen internal controls,” Raimondi said.
“Kim’s advocacy during the BOS meetings helped elevate the discussion and bring important issues to the forefront,” he said. “Additionally, Sandy has brought a sharp financial lens to the audit findings and continues to ask the right questions at the BOF meetings about how we can strengthen our systems going forward.”
“I’m encouraged that both the BOS and BOF are committed to working together on that effort,” Raimondi said. “I look forward to the discussion when the report comes before the (BOF).”
While she was left off the committee, Healy continues to try and offer her input toward improving procedures.
“I would like to see a more thorough response from the town, especially regarding the segregation of duties,” she said. “We also need to ensure that the accounts are now being reconciled monthly as noted as required in the audit report.”
Earlier this month, Norton told the BOF that monthly reconciliations would be done going forward, attributing her department’s previous failure to conduct them to the accounting software that was being used.
While she is not scheduled to officially take part in the new committee, Healy’s wish is that their work will add to her efforts.
“Obviously I hope that everything we have done to date will be included in the discussions,” Healy said.