P&C Compliance Review Program Overview

Compliance Reviews

Deputy State Procurement Officer – Risk & Compliance Management
Belinda Preacher, CPM, NCCM, NCPO, NCP

Understanding the Compliance Review Process

Compliance Review Process Overview

  • Who?
  • What?
  • Where?
  • When?
  • Why?
  • How?

Who?

  • 01 NCAC 05A .0112
    • Departments
    • Institutions
    • Boards
    • Commissions
    • Universities
    • Community Colleges
    • Others, unless specifically exempted.

What?

The key object of a Compliance Risk Assessment Framework is to effectively assess the risk exposure of an agencies procurement activities, not only in terms of adhering to applicable laws and regulations, but also to relevant internal policies and standards of conduct.

What We Request

  • Review of the purchasing organization (Org Chart).
  • Analysis of current policies, procedures, and processes (Procurement Manual).
  • Review of procurement risk assessment (Risk Assessment).
  • Review of the utilization of the E-Procurement system (Transaction review).
  • Review of procurement card transactions, if applicable (Bank of America Works Report & P-Card Manual/Policy)
  • Review of direct payment transactions (Direct Pay report).
  • Examination of purchasing transactions (Purchase Order report, CC & Univ).

What We Do With It

Generate E-Procurement (EP) Purchase Orders for FY under review

Generate P-card Report from Bank Of America (Works Program) for FY.

Receive Direct Pay Report from Agency Accounting Dept

Upload FY data from NCAS, E-procurement, P-card and Direct Pay to Microsoft Power BI.

Review all selected reports in the E-Procurement and Power BI System for compliance with North Carolina purchasing laws/regulations, and adherence to internal agency policy/procedures.

Use internal Work Paper to guide through review of Power BI and documents, developing draft report for discussion with entity on findings

Where?

Virtually, via Microsoft TEAMS mostly

Benefits:

  • Technology = efficiency gains
  • Electronic files = convenience
  • Review multiple entities at one time = quicker compliance review process.

When?

  • Every eighteen (18) months, your entity will be reviewed
  • Two (2) per month, per P&C Compliance Officer
  • Four (4) week review period
Compliance Review Schedule FY2025
Beginning in August 2024, it is our goal to review the following:
Month Mashonda Dexter Vacant Belinda Season
July Durham Tech Durham Tech Training New Team Member Summer - Jul, Aug, Sept
McDowell Tech McDowell Tech Training New Team Member Summer - Jul, Aug, Sept
Aug NCCU UNCG Training New Team Member Summer - Jul, Aug, Sept
Fayetteville State UNC Pembroke Training New Team Member Summer - Jul, Aug, Sept
Sept Elizabeth City State College of the Albemarle CC NCOSHR DIT Summer - Jul, Aug, Sept
Wilson CC Wayne CC State Ports Stanly CC Summer - Jul, Aug, Sept
Oct Montgomery CC Mayland CC Halifax CC Sandhills CC Fall - Oct, Nov, Dec
UNC Chapel Hill NCSU Surry CC Richmond CC Fall - Oct, Nov, Dec
Nov DOJ GTCC Lenoir CC DHHS Fall - Oct, Nov, Dec
Wildlife Resources Robeson CC Catawba CC State Treasurer Fall - Oct, Nov, Dec
Dec DOR Randolph CC Isothermal CC Wilkes CC Fall - Oct, Nov, Dec
Pamlico CC NC Board of Examiners UNC Asheville Roanoke Chowan CC Fall - Oct, Nov, Dec
Jan Western Carolina UNC System Office DPS Pitt CC Winter - Jan, Feb, Mar
Southwestern CC Southeastern CC Nash CC James Sprunt Winter - Jan, Feb, Mar
Feb Caldwell CC DPI w/ NC Center for Advancement of Teaching UNC Charlotte Western Piedmont CC Winter - Jan, Feb, Mar
Blue Ridge CC ASU Piedmont CC OSC Winter - Jan, Feb, Mar
Mar Gaston College Edgecombe CC Craven CC Brunswick CC Winter - Jan, Feb, Mar
Beaufort CC AB Tech UNC Wilmington Halifax CC Winter - Jan, Feb, Mar
Apr WSSU Tri-County Central Carolina CC Carteret CC Spring - Apr, May Jun
Rockingham CC NCCC System Alamance CC AOC Spring - Apr, May Jun
May NC Sch of Sci & Math DOL South Piedmont CC Sampson CC Spring - Apr, May Jun
Johnston CC Haywood CC NCA&T NCDOT Spring - Apr, May Jun
Jun ECU DOC Dept Adult Correction Martin CC Spring - Apr, May Jun
Coastal Carolina CC Cleveland CC Forsyth Tech Fayetteville Tech Spring - Apr, May Jun
Vance-Granville Dept of Natural & Cultural Resources Davidson County CC College of Albemarle Spring - Apr, May Jun
Cape Fear CC Bladen CC Spring - Apr, May Jun

Everything hinges upon receipt of requested information

The sooner the information can be provided, the faster the process. Additional tools:

Why?

01NCAC 05B.1605. Compliance Reviews

  • The Division of Purchase & Contract shall conduct compliance reviews on purchasing practices at all agencies. The purpose of the compliance review shall be for determining if an agency is complying with North Carolina's purchasing statutes and rules adopted thereunder, and whether it should continue having the same level of delegation, have it reduced, or if it qualifies for an increase. A copy of the compliance report shall be provided to the agency's executive officer, the State Auditor, the State Budget Officer and State Purchasing Officer.

The Division's staff may enter the premises and obtain an agency's purchasing records for the purpose of the compliance review.

The SPO may lower, or raise if requested, an agency's (excluding the universities) general delegation, if the results of a compliance review by the compliance staff of the Division merit such action as determined by the SPO.

The SPO shall provide to each agency, upon request, the Division's assistance in educational training for the agency's staff, to better acquaint them with the purchasing statutes and rules.

And, Why?

  • REQUEST FOR DELEGATION INCREASE
  • REQUEST FOR THE PROCUREMENT CARD
  • REQUEST OF MANAGEMENT
  • ROUTINE/SCHEDULED REVIEW
  • NON-COMPLIANCE FOLLOW UP REVIEW
  • OTHER

How?

UNC - Greensboro Initial Letter
Scott, Dexter
To Preacher, Belinda; Southerland, Mashonda

Attachments:
Direct Pay_TEMPLATE.xlsx (44 KB)
PCardTemplate_FY23.v3.xlsx (54 KB)
PO Empty_TEMPLATE.xlsx (35 KB)
Procurement Risk Assessment Tool rev. 11.08.22.xlsx (33 KB)
UNIVERSITY Objectives Scope Methodology Adm Code (2022).docx
Announcement Letter - UNCG - 07302024.pdf

Hello Mr. Logan,

My name is Dexter L. Scott, I am a Compliance Officer with the North Carolina Department of Administration, Division of Purchase & Contract. This email is to inform you of UNC Greensboro's upcoming routine Compliance review.

Please find attached, Announcement Call Letter and Compliance Review Objectives, Scope, and Methodology.

I will need you to provide us with your organizational chart, internal purchasing manual, if applicable, your procurement card policy, direct pay report, P-card purchase report and purchase order report for the period July 1, 2023, through June 30, 2024. The organizational chart of purchasing personnel in your University should include names and functional titles. If purchasing is not a centralized function, explain how the function is decentralized and how responsibility is assigned.

I have attached an excel template for the direct payment, purchase order and p-card data, as well as the Procurement Risk Assessment.

Complete and return the documentation to [email protected] by Thursday August 22, 2024. Let me know if additional time is needed.

Feel free to contact me if you have questions. Once I review this information, I will contact you if additional information is needed.

I look forward to working with you!

  • Compliance Officer will contact you (email or via TEAMS) ahead of scheduled review.
  • After acknowledgement, Announcement Letter and request of documents sent via email.
  • After requested information provided/returned/uploaded, compliance review begins

Compliance
CODES POLICY RULES REGULATIONS

Risk & Compliance Staff

  • Preacher, Belinda
  • Scott, Dexter
  • Southerland, Mashonda
  • + vacancy

We are here to serve! We look forward to working with you!

[email protected]

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