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The Department does not implement sufficient internal controls to permit regular <br />assessment of the effectiveness and efficiency of its recycling and diversion programs, and <br />to reasonably ensure that a specific program meets its objectives. The Department has not <br />implemented sufficient internal controls to ensure that unintended actions do not occur as a <br />result of failure to meet permit and grant application; renewal, and reporting deadlines; that <br />data reported to and by the Department is consistent, timely, valid, reliable, and <br />disseminated to the proper agencies and personnel; and that program procurements and <br />operations are in compliance with applicable laws, regulations, and provisions of contract <br />and grant agreements. <br />Recommendations <br />The auditors recommend that the Mayor and County Council, in consultation with DEM, <br />develop a plan and schedule for revising the County's Updated ISWW. The revision <br />should include a method for input by all stakeholders and a commitment by all <br />stakeholders to implement and adhere to the revised plan irrespective of changes in elected <br />officials. An accompanying detailed "working plan" also needs to be developed to drive <br />and guide implementation of the revised ISWMP, by outlining specific tasks to be <br />completed, a schedule for their completion, and assignment of stakeholders responsible for <br />each task. The County should also consider codifying this revised long -term solid waste <br />management plan in the form of an ordinance that establishes a mechanism for regular and <br />frequent review and reporting of stakeholder progress. <br />The auditors also recommend that the County Council adopt an ordinance to clearly <br />establish the County's authority to audit any entity with which it contracts, regardless of <br />whether the procurement is subject to or exempt from State and County procurement code <br />provisions. In keeping, DEM should consult with the Finance Department and the <br />Corporation Counsel to update its written policies and procedures relating to procurement <br />and contracting, including the award of grant monies to non - profit and for - profit entities. <br />The auditors recommend that the County consider implementing a standardized policy <br />regarding documentation of any and all communications received by a department from <br />federal and State governmental agencies concerning possible regulatory violations or <br />sanctions, and require prompt transmittal of any and all such communications to the <br />Mayor, Managing Director, Finance Director, Corporation Counsel, and County Council <br />for information and input. <br />The auditors recommend that DEM evaluate areas of possible risk, exposure, and control <br />deficiencies, and develop and implement necessary internal controls. DEM should <br />document all tasks and processes for which it is responsible, using "flow charts" or <br />"process mapping" to aid in evaluating the adequacy of staffing levels and training. DEM <br />should consult with other County departments and State agencies to develop "best <br />practices" for program compliance, effectiveness, and efficiency. DEM should implement <br />regular and frequent program reviews to monitor compliance and progress in an effort to <br />maximize effectiveness and efficiency, while minimizing risk and exposure to <br />