Recommendation: OATS should update and strengthen their procurement policy to match UG and DOL guidelines, and create a policy for verifying vendors are not suspended, debarred, or otherwise excluded per UG guidelines. The Organization should ensure these policies are followed for all vendors and that documentation related to these policies are maintained.
Explanation of disagreement with audit finding: There is no disagreement with the audit finding.
Action planned/taken in response to finding: OATS Procurement Policy was revised in July 2022 using the template provided by the Missouri Department of Transportation in compliance with Federal Transit Administration rules pertaining to procurement. The Policy states that OATS is to ensure vendors are not debarred or suspended for purchases greater than $25,000. The
method used by OATS to do this is by a search of the database maintained on the System of Award Manager (SAM) website. During the course of the audit, OATS was unable to provide proof of a search of the database for Guardian Insurance. This vendor provides life insurance offered as part of OATS Employee Benefits package. The initial contract with Guardian was signed in December 2011 and a copy of the search was not able to be produced. In response to this finding, OATS has implemented a process whereby a SAM search on all vendors with whom we spend more than $25,000 will be conducted annually – not just at time of initial procurement.
Name(s) of the contact person(s) responsible for corrective action: Dorothy Yeager, Executive Director and Jill Stedem, Administrative Services Director.
Planned completion date for corrective action plan: Done