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The objectives of our review of Pennsylvania Protection & Advocacy, Inc. (PP&A) were to assess its procurement practices, assess potential conflicts of interest, and evaluate PP&A's monitoring of its contractors. PP&A had contracting practices that did not reflect the use of open competition as required by Federal law; had two situations that involved conflicts of interest in violation of Federal law; and did not comply with Federal regulations in monitoring its legal services contractors because it did not verify that contractor costs billed were allowable, allocable, and reasonable.
We recommended that PP&A (1) use open competition in procuring legal services contracts or stop sole source contracting and establish in-house legal services expertise; (2) require its executive director to terminate her conflicting employment relationship; (3) decline acceptance of future contributions from any of its contractors; and (4) ensure that it complies with Federal regulations in monitoring contractor billings. PP&A concurred with our recommendations, but disagreed with the repayment part of the third recommendation, saying that its recent merger with the contractor would nullify repayment. Accordingly, we modified our third recommendation.