2006-01-AU Audit of the County of Hawai‘i's Recycling and Diversion Grants Program

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CHAPTER 2 GENERAL FINDINGS • The department does not have performance or benchmarks in place which would readily allow for an effective and efficient internal review process. • The department lacks formal policies and procedures for ongoing measurement of waste stream flows, including accurate and verifiable data collection and reporting methods. • The department does not conduct regular management meetings as a mechanism to facilitate timely review and communication of program status and current issues. • The department lacks formal policies and procedures in the areas of program planning and management, file and document management, and intra- and inter - departmental reporting and communication. • The department did not include sufficient provisions in its program guidelines to ensure adequate monitoring of County and contractor compliance with governmental laws, rules, regulations and requirements for permit application, approval, and renewal. • The department has failed to timely respond to regulatory agency warning letters and notices of violation, and has been unable to implement and operate its recycling and diversion programs in accordance with contractual and governmental permit timelines. As a result, the County is at risk for possible permit revocation and /or financial penalties. • The Miloli`i transfer station continues to be operated without necessary permits. In a communication to DEM dated March 7, 2005, DOH advised that this is in violation of HRS 342H -30 (b) and HAR §11-58.1-04, and the County may be subject to enforcement actions and penalties of up to $10,000 per day per violation. • The department personnel and contractors are not fully acquainted with program guidelines and permit requirements. • In the absence of reporting procedures, program and budget responsible personnel do not receive the operational and financial information necessary for effective and proactive management. • The department lacks formal policies and procedures for contract procurement and oversight. • The department may have circumvented and violated procurement laws in its issuance of grants. • The department did not include sufficient controls and protections in its procurement and contract documents to reduce the risk of contractor abuse and/or fraud and County exposure to violations of governmental regulations. The department does not sufficiently train incoming supervisory and management personnel in the areas identified above which has resulted in reliance on poorly formulated program guidelines, procurement and contract documents, and operational procedures. o The department has not ensured that personnel responsible for program design and contracting have sufficient knowledge and experience to ensure that adequate controls and protections are included in procurement and contract documents to reduce risk of contractor abuse and/or fraud and County exposure to acceptable levels. The department does not sufficiently prioritize the need for program and contractor evaluation to attain its internal control objectives: 10