Memo on Internal Control Procedures - For Immediate Implementation - CORRECTED

TO: All VESID VR Staff

FROM: Rebecca H. Cort

SUBJECT: Internal Control Procedures - For Immediate Implementation - CORRECTED

DATE: September 3, 2004

As VESID continues to address Internal Control issues for procurement activities, it is necessary that we revise our current purchasing processes in several significant ways to ensure that we have a fiscally sound environment. Therefore, effective immediately, the following practices and procedures must be followed:

  1. Procurement of Goods and Services: All procurement transactions, prior to mailing, must be approved in writing by District Office (DO) office supervisory staff. Guidelines for this process and a list of supervisors designated to review and approve authorizations in each DO will be disseminated on Tuesday, September 7, 2004. Authorizations entered into the system as of today, September 3, 2004, and every authorization hereafter, must be held at the District Office once printed until the supervisory sign-off has been completed.
  2. Equipment Purchases for Consumers: All payments for certain equipment including, but not limited to, computers, printers, scanners, camcorders, cameras and related audio/visual equipment must be approved in writing by Central Office prior to processing. Documentation including the voucher signed by the vendor, original invoice and proof of consumer receipt of equipment must be forwarded to Central Office for review and approval. Guidelines for this process will be distributed on Tuesday, September 7, 2004.
  3. Backdating Authorizations for Goods and Services: All authorizations must be issued prior to the start of the service. Backdating is not an allowable practice. Any services approved prior to the date of this memo that require an authorization must be approved in writing by the Regional Coordinator or District Office Manager. Guidelines on the process for handling canceled authorizations that need to be re-issued will follow shortly.
  4. Independent Contractors: At no time can vendor costs be charged to one consumer when other consumers benefit. All services must be provided in accordance with the service description and appropriately charged to the case of the consumer who actually received the service. These services include, but are not limited to job coaching, job development and job placement. The use of Independent Contractors can only be considered for currently approved statewide VESID services at the State approved rate. Services for which there is no State rate and/or service code, for example case-aide and group orientation, must be discontinued, effective immediately. Individuals providing such services must be informed today that we will no longer be contracting for such services. From this date forward, Central Office written approval is required for all Independent Contractors. Guidelines for obtaining this approval will follow, shortly.

These changes in procedure are absolutely necessary to immediately strengthen VESID’s internal control structure. We recognize that we will need to work together to ensure that these changes create as little disruption as possible in the delivery of services to consumers with disabilities. I am grateful for your skill and commitment that will carry us forward and know I can rely on you to implement these changes.

I look forward to meeting with you on September 7.

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