Right Step Compliance Program

How does the Program work?

For new Contracts entered into with new Vendors

1. OSP Compliance will periodically generate a report of new acquisition contracts with new vendors 
2. OSP Compliance will filter results to only include contracts with over $100,000 in spend or over ten transactions.
3. Those contracts are then placed in a queue for review of the contract and transactions under the contract by OSP Compliance.
4. Once a review of the contract has been done, OSP Compliance will complete an Internal Review Reporting Form with any findings and recommendations.
5. OSP Compliance will meet with contract owners and their supervisors to discuss any findings and recommendations identified in the report.
6. OSP leadership will be apprised as necessary.  
7. OSP Compliance then will work with OSP leadership, contract owner, contract end user, vendor, and any other interested parties to resolve findings.

For Ad Hoc review of OSP Contracts 

1. If any overpayment, overcharge, miscalculation, allegation of potential fraud, or other compliance issue is discovered concerning a contract managed by the Office of State Procurement, the contract end user should first notify the OSP contract owner.  
2. The contract owner should then notify their supervisor, who will determine whether a review of the contract by OSP Compliance is warranted.   
3. Supervisor will then notify OSP Compliance to initiate a review of contract.  
4. OSP Compliance review of contract will consist of: a) Review of contract documents to identify terms of the contract, b) Review a representative sample of invoices to confirm payment was in line with contract terms, c) Review any other relevant documents, d) Any other actions appropriate to confirm parameters of contract are being followed.  
5. OSP Compliance will then complete Internal Review Reporting Form based on review of contract documents.
6. Once complete, Internal Reporting Form will be submitted, with any findings and recommendations to the Contract Owner and the contract owner’s supervisor. OSP Compliance will meet with Contract Owner and Contract Owner’s supervisor to go over the report if beneficial to the understanding of the report or the Contract Owner or Contract Owner’s supervisor has questions regarding the report. OSP management and CPO will be apprised as necessary. Notification up the chain of leadership should be immediate whenever there is reason to believe the state is at-risk of impending financial loss that could be prevented by immediate notification.
7. If there are findings and recommendations in the Internal Review Report that are confirmed by OSP Management, interested parties will be notified.  
8. OSP Compliance then will work with interested parties to assure final recommendations are followed and any recovery of funds will be carried out.

Interested Parties

• OSP Compliance Unit – conducts reviews of OSP managed contracts. 
• Contract Owners and their supervisors – work with OSP compliance and interested parties to mitigate identified issues.  
• OSP Management and Chief Procurement Officer – kept abreast of overarching compliance issues and specific cases that are escalated based on seriousness of issues identified.  
• All contract end users for the Office of State Procurement for all departments, agencies, offices, councils, boards, commissions, other entities in the executive branch of Minnesota  State Government, and Cooperative Purchasing Venture (CPV) members.