31 U.S.C 1501 provides that a bond will only be covered if it is supported by the documentation of a binding agreement. The agreement should be implemented before the deadline for the availability of the funds used. We looked at 11 selected inter-institutional agreements of the Commission. We made four recommendations to the Office of Administrative Management and Human Resources Management (OAPM) to improve controls. They are: obtaining appropriate documentation to support the health unit`s commitments and the personnel assistance program; COTRs must notify the purchasing and contracting branch after a satisfactory conclusion of small purchases; distribute guidelines to ensure that purchases are made in accordance with economic law; and use 18 U.S.C 4124 as an authority for contracts with Federal Prison Industries. Four of the 11 inter-institutional agreements for the 1995 GJ committed a total of $24,000 in 1994. These mandatory appropriations were on hold from August 1995. The authority for each of these agreements was the economic law. We have tried to find documentation of inter-institutional agreements on health units and EAP services on nine of the Commission`s 13 seats, regional sites and districts (see appendix). There has not been enough documentation to support current commitments to health care units and personnel assistance programs.
For example, there was no documentation for a number of sites. Seven of the nine sites were missing for the Health Unit. Three of the nine sites did not have agreements for EAP services. Other statutes also allow for the awarding of inter-institutional contracts. For example, the Federal Property and Administrative Services Act (40 U.S.C. 481) authorizes acquisition by the General Services Administration (GSA). Another such status is 18 U.S.C. 4124, which authorizes the acquisition of Federal Prison Industries (UNICOR).
The agreements were maintained by the OAPM`s Industrial Relations Department. The Personnel Relations Division is not responsible for ensuring the adequacy of contract documentation. On the other hand, the OAPM`s P-C branch is responsible for the maintenance of contractual documentation. However, the branch of P-C was not involved in maintaining these agreements. The branch of P-C should amend the UNICOR agreement in order to obtain the right authority. The purpose of the audit was to determine whether controls on inter-institutional agreements were effective and whether agreements were cost-effective for the purchase of goods and services. We reviewed 11 Inter-Institutional Commission Agreements for a total of $1.14 million in the 1995 GJ. The revised agreements represented all open inter-institutional agreements executed by the Administrative Management Agency and Contracts (P-C) of the Administrative and Personnel Management Authority (OAPM), with the exception of four contracts that were pre-examined and contracts awarded pursuant to Section 8 (a) of the Small Business Act (15 P.C S.C 637 a).
The OAPM`s P-C branch manages most of the agencies` inter-institutional agreements. However, the OAPM personnel management function manages agreements with the Public Public Health Service for Public Health Unit and THE EAP services. PhS has established a consortium in each of its regions to provide health care units and services and EAP services under an umbrella contract.