2021-02 - Recommendation 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.