Audit of the U.S. AbilityOne Compliance Program

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Date Issued

Thursday, January 26, 2023

Submitting OIG

U.S. AbilityOne Commission OIG

Other Participating OIGs

U.S. AbilityOne Commission OIG

Agencies Reviewed/Investigated

Committee for Purchase From People Who Are Blind or Severely Disabled (AbilityOne Program)

Report Number

2021-02

Report Description

The OIG engaged the independent public accounting firm CliftonLarsenAllen (CLA) to conduct the performance audit and issue its report. The objective of the audit was to determine whether the Compliance Program, as implemented by the Commission and CNAs, is effectively providing reasonable assurance of NPA and CNA compliance with applicable laws, regulations, and policies. The auditors concluded that although the Commission’s policies and procedures governing the Compliance Program comply with applicable laws and regulations, there are opportunities for improvement in four key areas. The report contains 11 recommendations to improve the Commission’s controls over the Compliance Program.

Report Type

Audit

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

Open Recommendations

This report has 6 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use	Additional Details
01	No	$0	$0	OCD-2022-01
In accordance with Policy 51.101, review and update all compliance policies, including determining whether updates are needed to improve clarity, remove inconsistencies, and ensure harmonization with the Cooperative Agreements.
05	No	$0	$0	OCD-2022-05
Develop comprehensive written documentation of the procedures to be performed by Commission staff for reviewing, evaluating, and approving or rejecting compliance transaction packages CNAs submit to PLIMS. The procedures should include roles and responsibilities with an appropriate segregation of duties and documentation requirements in PLIMS. (Finding 1B) For CVR transactions, also incorporate the following: a. OCD staff protocols and requirements for requesting access to detailed supporting documentation provided by the NPAs to the CNAs to independently verify NPA compliance with statutes, regulations, and Commission policies. The protocols should take into consideration identified risks such as NPA past performance, overall trends in compliance deficiencies, external factors such as civil settlements, and the Commission’s plan for conducting compliance visits to NPAs during the FY. (Finding 4A) b. OCD staff documentation requirements in PLIMS including any follow-up with the CNA for discrepancies between the Commission’s results and the CNA’s reported results.
06	No	$0	$0	OCD-2022-06
Develop comprehensive written documentation of the procedures to be performed by Commission OCD staff for reviewing, reconciling, and processing manual compliance reports and transactions submitted by the CNAs and/or NPAs outside of PLIMS (Finding 1B). The procedures should also include the following: a. Roles and responsibilities with an appropriate segregation of duties. b. Follow-up on compliance exceptions reported. c. Reconciliation of manual data to PLIMS. d. Review of quarterly and annual AR&C extracts, including data supporting the NPA’s 75% ODLH requirement. e. Documentation requirements, including the use and frequency of PLIMS reports and summarizing compliance findings and actions, preferably in PLIMS. Evaluate the feasibility of using the NPA Comments and/or NPA Compliance Action screens in PLIMS. f. Maintenance of records.
07	No	$0	$0	OCD-2022-07
Review each CNA’s NPA Oversight Protocol for conducting RRAVs and update to improve comparability of data provided and reported to the Commission as follows: a. Standardize the sampling methodology used by the CNAs and the Commission to test certain key compliance areas during RRAVs such that comparable data is reported to PLIMS for NPA compliance deficiencies. b. Harmonize the CNAs’ RRAV Checklists and the Commission’s Compliance Review Checklist such that the procedures performed are consistent. c. Standardize the methodology for aggregating and reporting summarized results of compliance deficiencies for the FY in the End of Year AR&C Analysis. d. Standardize the documentation the CNAs are required to submit to the Commission for CVR transactions.
09	No	$0	$0	OCD-2022-09
Identify updates needed for CVR transaction data reported in PLIMS as follows: a. Review the information available from each CNA’s proprietary system for CVR transaction packages, determine the current mapping of data fields to PLIMS, and identify whether any updates are needed to improve clarity or correct inconsistencies between CNAs. b. Evaluate whether any new data fields should be added to PLIMS to provide the Commission with additional insights to better inform decision making. c. Determine whether any updates are needed to the eleven (11) individual compliance categories to improve clarity or respond to changes in regulations. d. Prioritize identified updates and establish a timeline for implementation.
11	No	$0	$0	OCD-2022-11
Develop written standard operating procedures for the specific procedures it requires Commission OCD staff to perform when conducting an NPA compliance visit including the documentation requirements and reporting to PLIMS (Finding 4B). The procedures should also include the following related to joint visits with the CNA: a. The rationale and factors to be considered in making the decision to conduct a joint visit with the CNA versus a stand-alone visit to the NPA as well as the scope of the review. b. Develop a protocol for communicating the roles and responsibilities of the Commission and CNA reviewers to the NPA including the scope of the Commission’s review and coordination with the CNA. c. Determine the format of the Commission reviewer’s separate written documentation of procedures he/she performed and results, including findings requiring corrective action by the NPA. This should include timely transmission of this documentation to the CNA for submission with the CNA’s CVR transaction to PLIMS and the process to ensure the CNA tracks and closes-out any required corrective actions. d. Determine whether to implement a formal appeals process that would be available to NPAs to assist in resolving disputes with Commission findings.