Overview
The Massachusetts Commission for the Blind (MCB) was missing documentation from some of its vendor files that was necessary to determine whether vendors were eligible to participate in MCB’s Vending Facilities Program (VFP). We determined that 4 of the 28 hardcopy vendor files, for vendors that were active during our audit period, did not have documentation supporting the vendors’ completion of required training and licensing. Additionally, 3 vendor files did not have formal written vendor agreements with MCB, and 2 vendor files did not have the documentation regarding required training and licensing or formal written vendor agreements.
Without this documentation, there is a higher-than-acceptable risk that the nine vendors associated with these files were ineligible to participate in VFP.
Authoritative Guidance
According to Section 3.04(1) of Title 111 of the Code of Massachusetts Regulations (CMR),
The Commission shall issue a license for an indefinite period of time but subject to suspension or revocation to each qualified applicant who has successfully completed the appropriate training program as required by the Director, which license shall specify whether the licensee is authorized to operate a vending machine stand and/or . . . dry stand and/or cafeteria.
Additionally, according to 111 CMR 3.06(6), “Acceptance [into VFP] shall be indicated by delivering a signed vendor’s agreement to the Commission.”
Reasons for Noncompliance
MCB officials offered various reasons that this documentation might be missing from these vendor files, such as the documents may not have been filed or were misfiled and the person responsible for performing the evaluations left MCB employment in February 2020. In addition, MCB does not have policies and procedures, including a monitoring component, regarding documentation of its VFP process.
Recommendation
MCB should develop documentation requirements and related policies and procedures for its VFP. It should also develop monitoring controls to ensure that its staff members adhere to these policies and procedures.
Auditee’s Response
The MCB agrees with this recommendation. The MCB VFP has begun the process of updating and developing policies, and procedures to include monitoring governing the operation of the VFP.
Specific to this finding, the program is redesigning the vendor files, going forward to include sections on Eligibility, Training and Licensure, Evaluations, and Correspondence. The file will contain all required documentation in each section and will be reviewed for accuracy and completeness by the VFP Director before the proposed vendor is deemed eligible when entering the program and/or after license suspension as a result of failure to correct issues raised in warning letters or complaints of the site-grantor or public. After review, if satisfied, the Director of the VFP will issue a written notice that the proposed participant meets all program requirements to run a vending facility. The Director will review with all program staff all files at a minimum of biannually for compliance. Throughout the process, major policy decisions and procedures, per the regulations will be shared with the Elected Committee of Blind Vendors for comment and/or recommendation and changes.
The Director’s Manager will monitor the VFP staff compliance with policies and procedures on a quarterly basis.
Auditor’s Reply
Based on its response, MCB is taking measures to address our concerns on this matter.
| Date published: | December 16, 2022 |
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