2009-01-AU Follow-up Review of the 2006 Audit of the Department of Environmental Management's Recycling and Diversion Grants Program

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RECOMMENDATIONS - ADF - GLASS CONTAINER RECOVERY PROGRAM RECOMMENDATIONS — REPORT STATUS REFERENCE ADF - GLASS CONTAINER RECOVERY PROGRAM 1. We recommend that the County obtain a legal opinion as to whether the ADF and Diversion Grant programs are, in fact, exempt from the State procurement IMPLEMENTED p. 20 code under HRS §103D- 102(b)(2)(A). 2. We recommend that the County amend its Code to clearly establish its authority to audit any entity with which it contracts, regardless of whether the procurement PENDING p. 20 is subject to or exempted from State and County procurement code provisions. 3. We recommend that the County incorporate into all contracts exempted from State and County procurement codes, excerpts from the "General Terms and Conditions" of said codes which afford the County better protections and IMPLEMENTED pp. 20 - 21 remedies against collusion, abuse, and fraud without subverting the flexibility intended by the exemptions. 4. We recommend that DEM revise Grant Guidelines and subsequent monitoring IN pp. 21 - 23 practices to ensure accuracy of contractor claims and to reduce the risk of PROGRESS errors, abuse and /or fraud. 5. We recommend that DEM review its ADF program for glass source streams that are not currently being measured, and implement corrective actions to provide PENDING p. 24 greater accountability without causing undue hardship to contractors or County personnel in their application. 6. We recommend that DEM determine whether additional positions will be required to meet timelines for procurement and contract issuance and to IN p.24 conduct necessary oversight and monitoring of contractor performance under PROGRESS procurement and contract agreements. 7. We recommend that DEM research utilizing the project accounting module of the County's FRESH accounting system to assist in more efficient financial PENDING pp. 24 - 25 monitoring and reporting. 8. We recommend that DEM develop a formal policy and procedure for p.25 authorization, documentation, and systematic recordation of changes to its IMPLEMENTED contracts and budgets. 9. We recommend that DEM establish a formal policy and procedure whereby IN financial status reports at contract and program levels are regularly and timely PROGRESS p. 25 provided to and monitored by a designated budget responsible manager within the department. 10. We recommend that DEM obtain specific written clarification from DOH as to IMPLEMENTED p. 25 whether its "glasscrete" projects will satisfy all or portions of the "glassphalt" paving requirement under HRS §342G- 86(a)(2).