To: NAU Office of Internal Audit
From: Malene Comes, Between Trust and Trauma
Subject: Internal Audit Questions: Wurgler Endowed Chair Shelter Project
A response is expected by August 20, 2026. The response can be emailed to: betweentrustandtrauma@proton.me. If a response is received, Between Trust and Trauma will publish it in full, alongside any follow-up questions or commentary. If no response is received by that date, that absence will also be noted publicly.
I am writing to request a formal internal audit and financial verification review regarding the new “on-site behavioral health program” launched August 3rd at the Huntington Drive shelter — a collaborative project between Flagstaff Shelter Services, The Guidance Center (TGC), and NAU’s James Wurgler MD Endowed Chair.
Following the same question-based approach I sent to the NAU Ethics & Institutional Review Board, I need your office to look into the financial and corporate dimensions of this partnership and answer these questions formally.
1. Where Is the Money Going?
What university or foundation funds from the Wurgler Endowed Chair are being used to underwrite this program — and in what amounts? Are NAU funds being used to pay the wages or operational costs of frontline personnel who are actually employed by a private entity like TGC?
Endowed chair financial transparency is not optional when public university resources are involved. The community has a right to know exactly what NAU money is funding here, and exactly who is being paid with it.
2. What Happens If the Partner Goes Under?
Public tax documents show that The Guidance Center is carrying a significant operating deficit — losing millions in direct service revenue compared to both pre-COVID baselines and their 2022 highs, while continuing to pay substantial executive salaries.
Did NAU’s risk team conduct a formal financial stability evaluation of TGC before signing onto this project? What specific safeguards protect NAU’s research data, equipment, and staff if TGC faces formal corporate restructuring or bankruptcy? What happens to the behavioral health data collected from unhoused shelter residents if TGC collapses mid-program?
3. How Are the Conflicts of Interest Being Managed?
This is the central question your office needs to answer.
TGC operates inside an interlocking behavioral health monopoly in Arizona — NARBHA controls the majority of regional Arizona behavioral health funding, and NARBHA is simultaneously the sole funder of the James Wurgler Chair payments at NAU. That is a documented financial conflict of interest at the structural center of this program, and it has received no public scrutiny.
How does your office evaluate the NARBHA funding transparency of a project where the funder and the primary clinical beneficiary maintain this kind of interlocking relationship? What safeguards exist to demonstrate that this is a legitimate academic study — rather than a coercive psychiatric recruitment and patient funneling mechanism designed to scoop up unhoused individuals and feed TGC’s billable beds?
The unhoused population research funding flowing through this program deserves the same scrutiny your office would apply to any other partnership where a donor simultaneously controls the clinical outcome.
4. Is NAU Auditing the Partner’s Compliance Failures?
This section requires your immediate attention.
TGC currently holds an active formal warning letter from the federal Office for Civil Rights for unauthorized medical chart modifications — editing records to bury patient complaints. There are also active complaints lodged with the Arizona Attorney General and active state licensing board investigations involving TGC’s frontline nursing staff; with another staff member already having received an official Letter of Concern from her licensing board.
NAU federal grant eligibility is directly at risk here. Continuing a formal research footprint with an organization carrying active federal civil rights violations and state regulatory investigations is not a neutral administrative decision — it is a compliance liability that your office needs to evaluate and document before this program goes any further.
Are you aware of these compliance failures? Has your office reviewed their potential impact on NAU’s standing with federal funders?
5. What Are the Data Risks If This Goes Federal?
This question connects the financial audit directly to university research compliance standards.
The current national administration has explicitly committed to removing unhoused and mentally ill people from public spaces under Executive Order 14321. The database being built through this program — tracking names, locations, and behavioral health data of unhoused shelter residents — carries real federal subpoena risk. If NAU funds helped build that database and it ends up accessed by federal agencies pursuing that agenda, that is both a financial liability and a research ethics violation.
Your office needs to verify that enforceable — not aspirational — data firewalls exist before that risk becomes NAU’s problem.
We need verification that university funds are being managed with absolute transparency — and that NAU is not using university research compliance standards as a rubber stamp for a broken behavioral health monopoly propped up by a captive regional funder.
I look forward to your formal response.
Malene Comes malene.comes@gmail.com
