Audit of the U.S. AbilityOne Compliance Program

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.

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.

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.

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.

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.