Presentation on theme: "State Agency Contracts Considerations for Performance Reviews"— Presentation transcript:
1State Agency Contracts Considerations for Performance Reviews
2Introduction Performance reviews of contracts are not mysterious Your audit goals and findings will remain the sameWhat’s typically unknown: criteria, audit tasks, and evidenceWith the increase of government contracting in the last two decades, legislative interest in the accountability of contracted projects is likely to persist. To address these interests, we have to be confident in our capacity to produce meaningful audit findings when we examine these contracts. Today’s training aims to remove some of the mystery from what it means to do a consistent, well-documented performance review of a contract.In many ways, a review of contract is like any audit of an agency’s in-house activities.The goals are the same: to provide independent, unbiased, objective information on how money was spent, and identify and review vulnerable areas.Your team will develop findings that are similar to other reviews, such as whether contracts served a public purpose, whether controls were in place, and whether public funds were safeguarded.What is typically unfamiliar to auditors is the body of criteria that apply to contract management and contract quality, and what tasks and evidence will demonstrate how well a contract meets these criteria.2
3Training Objectives Participants should be able to: Identify the bodies of criteria that your state has developed to ensure high quality contractsIdentify the key players in contract management and accountabilityDevelop a checklist of issues to cover in your audit and ideas on how to address those issuesTo that end, we hope to address three objectives today (repeat above).
4Audit Criteria: State Laws and Rules for Contracts Part 1 of 3Let’s begin by discussing the criteria that you will need to consider in order to evaluate a contract. We’ll cover the bodies of general criteria set up in most states.
5Audit Criteria: State Laws and Rules Contract ComponentsContract Controls or ReviewContract ManagementContract Administration (if separate)EthicsAgency staff may need a reminder that you are auditing to existing criteria, not developing criteria about what this contract should or shouldn’t look like. These criteria are laws and rules that govern contracting, including specific direction on contract components, what controls should be in place or procedures should be completed prior to finalizing the contract, how contracts should be managed and administered, and ethics issues in contracting.
6Contract Components Section 287.058, Florida Statutes “Every procurement of contractual services in excess of the threshold amount … shall be evidenced by a written agreement embodying all provisions and conditions…”[note to trainer: Above, we present the Florida citation; please replace with your own as applicable]Typically, some state criteria exists requiring some form of a written contract between the state and a vendor, whether a purchase order from an e-procurement system or a contract for a complex service, such as foster care. One of your first audit tasks will be to obtain this document.
7Contract Components (continued) State and federal statutes…specify components or even specific language that must be a part of any state agency contractrequire basic language (e.g. terms of payment) and details unique to the state (e.g. adherence to public records laws), andare often specific to the type of purchase, e.g., service, construction, or commodities[Note to trainer: You may wish to insert the major bodies of statutes into this slide.]Suffice to say, your state and the federal government have a range of laws about how the state will write contracts.For example, in Florida, the required components of a contract range from the basic, such as language that makes payment subject to deliverables, to language that is fairly unique, such as language that specifies that any purchasing transaction and contents of a contract are a public record and as such are accessible on request to the general public. We will cover more specifics about what components should be in each contract in Part 3 today when we discuss checklists.Your background research for your project should include reviewing the relevant bodies of contract requirements in your state that are applicable to the contract you’re evaluating (e.g. construction or service or commodity contracts). For the purposes of this training today, we’ll use examples related to service contracts, as they are typically thought to be the most complex. We will discuss more about what components you may want to examine in Part 3 of our training today.
8Contract Review“Each agency shall establish a review and approval process for all contractual services contracts ….which shall include, but not be limited to, program, financial, and legal review and approval. Such reviews and approvals shall be obtained before the contract is executed.”s (19), F.S.[note to trainer: Above, we present the Florida citation; please replace with your own as applicable, and edit the suggested text below to your state’s specifications.]Some contracts are subject to more administrative approval and control than others. These are the categories of review that occur in Florida for services contracts $65,000 or greater:Program review: the leadership of the program developing the contractFiscal: the agency’s or state budget officeLegal: the general counsel or outside counsel hired to advise on this procurement or review solicitation documentsLook for: conditions (e.g. dollar value of contract) that activate review of any kind, as well as signatures or letters that document that this review occurred.
9Contract Management For each services contract, state agencies should designate an employee to enforce the contract terms,establish procedures to ensure that contractual services have been rendered according to the contract terms, andpay the vendor if these terms have been mets (15), F.S.[note to trainer: Above, we present the Florida citation; please replace with your own as applicable, and edit the suggested text below to your state’s specifications.]Florida statutes establish an actual position for the contract management function indicate that the contract manager is both a liaison with the provider and an enforcer of the contract terms. We’ll discuss this role more in Part 2 of the training today. IN addition, principles of good contract management, if not your state statute, will suggest that payment to vendors should not occur if the terms of the contract have not been met.Look and ask: has an agency has designated a staffer to be a contract manager? If not, can the agency provide documentation of procedures it has to ensure that terms are met before it pays a contractor? This information may be found in the solicitation documents.
10Contract Administration “Agencies shall designate at least one employee who shall serve as a contract administrator responsible for maintaining a contract file and financial information on all contractual services contracts and who shall serve as a liaison with the contract managers and the department.”s (16), F.S.[note to trainer: Above, we present the Florida citation; please replace with your own as applicable, and edit the suggested text below to your state’s specifications.]In Florida, each agency is required to have a contract administrator (more on this role in Part 2); What does it mean to administer a contract? It involves recordkeeping, financial control, and relationship management, and may involve managing the solicitation process. If your state requires a named contract administrator, look for a staffer that is so designated. Said party is likely physically maintaining information on the contract and possesses a history of communication with agency management or other state executives about the contracted project.
11Ethics of Contracting Solicitation or acceptance of gifts Conflicting employment or contractual relationshipUnauthorized compensationMisuse of public positionUnauthorized commitment of state funds[note to trainer: you may wish to add citations to your state’s statute section as applicable]An auditor should be able to observe agency employees’ strict adherence to the ethics requirements of the law. In short, state employees’ behavior should be unaffected by personal gain and personal relationships. Ethical behavior for state employees typically involves issues of the solicitation and acceptance of gifts, a conflicting employment or contractual relationship, misuse of public position, and disclosure or misuse of certain information. Lots of other ethics issues can also come into play throughout the contracting process, such as improper payments, etc., or setting up contracts that could incur costs above the current appropriation for that activity.In Florida, as in your state, sometimes ethics issues will be pretty black and white. For example, a state of Florida employee can’t accept anything for free from an vendor unless it’s provided to everyone (e.g., water from a public area drinking fountain). Other issues are less noticeable because they’re outside the main scope of our reviews(e.g., if a vendor employee working on a contract accepted a job with the state agency that managed the same contract). Contract managers and administrators may have received training on these issues to support their roles; if they haven’t, this may be of interest to your research.
12Discussion: Part 1What’s the point of these criteria? Do they need to exist?Do these criteria encourage efficiency or are they merely symbolic safeguards? Discuss.Some ideas/discussion items to highlight1. What’s the point?safeguard the state’s financial interestsfulfilling the trust in government held by the public via: impartial decision making, transparency2. Efficiency? Probably yes. At least insofar as they:provide parameters to the contractorensure consistency of practice by the state and the contractor
13Players and roles: who will be enforcing the criteria? Part 2 of 3We’ll move on to discuss the roles of people who will ideally be asking: Why are we buying this? Why are we still buying it? Are we getting any results or benefit?Players and roles: who will be enforcing the criteria?13
14Who Ensures Contract Accountability? Finance and AccountingContract ManagerContract AdministratorLegal CounselAuditorsThe program management and staff developing a contract are hopefully not acting on their own. These five entities are among the checks and balances that many states have to ensure that the state’s investment is protected.
15Finance and Accounting Contract Planning: Cost principles evaluationContract Selection: Contractor financial viability assessmentCoordination: Relationship with state financial entityAccountability:Allocations and EncumbrancesInvoice ProcessingWarrant DistributionAgencies will have to pay contractors through their agency’s finance office, perhaps with final approval coming from the statewide financial entity. The agency ‘s finance/budget office may provide assistance with contract development and selection, including the financial viability of a contractor; they also coordinate with the state’s central financial entity, and will maintain information in the state accounting system.These people are resources for items like on real-time contractor payment history, appropriation balances, and invoice approval.Source for: Payment history and related support, warrant copies, compliance information
16Contract Manager Provider Selection Contract Preparation Ongoing OversightReview reports and deliverablesContract AmendmentsMonitoringCloseoutFlorida statutes indicate that for each contractual services contract, a state agency shall designate an employee to function as contract manager who shall be responsible for enforcing performance of the contract terms and conditions and serve as a liaison with the contractor. These folks are responsible for the range of activities mentioned above in order to safeguard the state’s interests. In short, they should have their hands in this project every day, and should be documenting their findings and communications. Make sure you can see how consistently they log their interactions with the vendors and the results of their communications.In addition, although states rarely have hard and fast rules about either the experience level or workload of this person, consider finding this out, and noting how it compares to other contract managers in their agency. Also, you may wish to note if the manager has received training/certifications required by the state. Lack of experience or training and high workload can lead to problems with contract implementation.Source for: Documentation of day-to day vendor communications, activity log, and of changes made based on their feedback to the vendors
17Contract Administrator Maintain FilesFinancial InformationLiaison with contract manager and state purchasing entityManagement ReportingLegislative AnalysisTechnical ResearchFlorida statutes also specify that in addition to the contract manager, agencies shall designate at least one employee who shall serve as a contract administrator responsible for maintaining a contract file and financial information on all contractual services contracts and who shall serve as a liaison with the contract managers and the department. This role could also include other administrative duties. For example, at the Florida Department of Transportation, contract administrators advertise and award road and bridge construction contracts.As such, every Florida agency has a contract administrator. This person usually is part of an agency’s administrative arm or budget office. However, agencies sometimes “wing it”: a procurement officer or contract manager might take on these responsibilities.Contract files may be public records and maintaining them is likely the responsibility of the contract administrator. Make sure you can see the files and what updates they contain. At a minimum, the files should contain solicitation documents, award documentation, correspondence, documentation of activities, invoices, deliverables, reports, and monitoring results. This data will support findings about how well the state is performing it’s oversight duties.Source for: Contract files (correspondence, deliverables), solicitation and award documentation, monitoring results
18Legal Counsel Can be internal or external, and can: Advise on solicitation methodAssist in negotiations with vendorsApprove contract componentsProvide enforcement support to contract managerThe presence/involvement of legal counsel is a proxy for a number of issues: the complexity of the contract, its expense (if in-house legal approval is required at particular costs) and the agency’s recognition of a need for additional support. Contracts for complex services may require counsel’s input on the solicitation method, how to negotiate with the vendors, the components of the contract, and as needed, support to the contract manager. Because the need for complex service contracts may be infrequent, agencies sometimes pull in external legal counsel. These folks can be effective supports in contract negotiations, particularly if they are subject matter experts (e.g. IT, or outsourcing), but it may be difficult to obtain audit information from them.These folks can be resources for explaining complex portions of the contract, information on what trade-offs were made in negotiations, and as applicable, documentation of their approval of the contract and actions taken by the agency against vendors.Source for: resolving questions about contract content, documentation of approval of contract, documentation on actions taken against vendors
19Auditors Financial, information technology, and performance audits State audit entitiesThird party CPAs (single audit)Internal Audit/Inspector GeneralAs you know, auditors and third party monitors can provide valuable accountability, through financial, IT and performance audits. External auditors are notably valuable when program management could override internal controls.A quick pitch for the value of information sharing among audit entities: when OPPAGA was asked to review the performance of our outsourced human resources contract, we utilized existing and ongoing research of three other audit entities. This included operational and information technology reviews of the contract made by our Auditor General’s office, the report on implementation progress made by the third party monitor hired by the agency that outsourced the HR system.Source for: historical information on the contract that will help determine cause, as well as implications for ongoing performance and compliance.
20Discussion: Part 2Review/Discuss: What kinds of evidence/documentation (beyond the content of the contract) would you look for to determine whether agency staff were adequately safeguarding the state’s interests?Why might it be problematic for a contract manager to also be a contract administrator?Some ideas/discussion items to highlight1. Examples: contract Manager’s logs and frequency of contact with the vendor/contractor; evidence supplied to support invoice payment; deliverable timeliness, nature of contract amendments, etc.2. The separation of these roles, if required in your state, can facilitate objectivity and independence. For example, a contract manager may become too embedded in a contractor’s viewpoint or work. Having an administrator that is outside the contracted activity can provide additional accountability and can focus the workload of the contract manager.
21Players and roles: who will be enforcing the criteria? Developing an Audit Checklist for Contract ReviewsPart 3 of 3Scoping a review of a contract involves at least identifying which components of the contracting process your team will examine, what information you may need, and how you’ll get that information. To that end, we will discuss the components of contracting, and provide lists of issues you may wish to cover in your review (these will of course, be driven largely by your state’s criteria!). We’ll also provide examples of how you could obtain evidence on particular issues.Players and roles: who will be enforcing the criteria?21
22Components of the Contracting Process PlanningDecision to ContractVendor Performance RequirementsSolicitation Process (e.g. RFP process)Award ProcessAward DecisionContract ProvisionsMonitoringThe Performance Audit Committee of the National State Auditors Association identifies these components to use in identifying and evaluating best practices in contracting for services. We will not address commodity purchases here today, but some of the same issues can apply.We will go through some of the best practices to approach evaluation of each component, but this training will not present an exhaustive list. The goal is for this to be a starting point for your team. The scope of your review may include one, several, or all of these components. Be sure to refer to state law as your primary source of criteria/review checklists for each component.Trainer: you may wish to add statutory citations to this slide.
23Audit Checklist: State Agency Planning An agency’s plan to contract for services should demonstrate:what services are neededhow they should be providedwhat provisions should be in the contracthow services will be evaluatedwhat approvals will be required, if anyWhat does planning do?Planning is the foundation for contract award and monitoring, as it allows agencies to effectively structure their solicitations.It identifies what services are needed (e.g. therapy for state prison inmates); how they should be provided (e.g. on site, in person); and what provisions should be in the contract (e.g., about fees or type of therapy provided).Your state’s laws about competitive bidding and contracting will guide what documentation/evidence you will need to evaluate whether proper planning has occurred. For example, in Florida, approval of high dollar contracts by the Legislature and Governor is based in part on evaluating an agency’s business case and cost benefit analysis that is part of an agency’s budget request – real planning documents that auditors can obtain and review.
24Audit Checklist: The Decision to Contract The agency should have:Determined whether state law either prohibits contracting for these services or requires the agency to demonstrate its need to contractAnalyzed its business needs, goals, objectivesConducted a cost/benefit analysis and evaluate optionsOnce a need for a service is identified, the agency needs to determine whether or not to contract for the service. To make this decision, the agency should have done some basic assessments, includingDetermine whether state law either prohibits contracting for services or requires the agency to demonstrate its need to contract.Analyze its business needs, goals, objectives, and services and determine whether or not the service is necessary.3. Conduct a cost/benefit analysis and evaluate options, such as whether contracting is more or less expensive than using agency staff.Agencies should be able to show a paper trail of this planning process. In Florida, documentation of such planning isn’t required in all cases. However, agencies may still conduct such analyses. For example, in our review of Florida’s outsourced human resources function, the agency provided us with a cost justification (e.g. reduced appropriations of dollars or staff) that would result from outsourcing. We gave the agency credit for having developed decision documentation, but found that they had done so poorly.
25Audit Checklist: Vendor Performance Requirements The contract should:Clearly state the services expectedClearly define performance standards and measurable outcomesIdentify how vendor performance will be evaluatedInclude positive or negative performance incentivesIdentify the staff that will be responsible for monitoring vendor performanceDefine procedures and conditions for modification to the contractOnce the decision to contract has been made, the agency should develop performance requirements that will hold vendors accountable for the delivery of quality services.Performance requirements should:1. Clearly state the services expected. This is often the hardest part of the contract to write – any wiggle room or ignorance on the agency’s part will likely result in numerous contract amendments..2. Clearly define performance standards and measurable outcomes.3. Identify how vendor performance will be evaluated.4. Carrot and stick: contracts may include positive or negative performance incentives. For example, our Medicaid disease management contract in Florida contained language for incentive payments if reductions in hospitalizations occurred with managed clients.5. Identify the staff that will be responsible for monitoring vendor performance. Ensure that sufficient staff resources are available to handle vendor/ contract management properly. Although your state is unlikely to have specific procedures about contract manager workload, etc.6. Clearly define the procedures to be followed if, during the course of performance of a service contract, unanticipated work arises that requires modification to the contract.
26Audit Checklist: Solicitation Process An RFP should…Clearly state performance requirements and scopeInclude a statement of workIdentify constraints, deadlines, mandatory itemsSpecify required deliverables and payment termsClearly state pricing requirements and evaluation criteriaAllow sufficient time for vendors to prepare good proposalsThe decision to employ a Request for Proposal commits an agency to a formal process based on fair and open competition and equal access to information. This decision allows the agency to systematically define the acquisition process and the basis on which the proposals will be assessed. The RFP itself provides a standardized framework for vendor proposals and highlights the business, technical and legal issues that must be included in the final contract.The RFP should:1. Clearly state the performance requirements and the scope of the services that are to beprovided.2. Include a statement of work that flows from the business needs analysis, and shouldpresent a logical plan to address the stated needs.3. Identify constraints, schedules, deadlines, mandatory items, and allowable renewals.4. Specify required deliverables, reporting obligations and payment terms.5. Clearly state pricing requirements and bid submission expectations, including closingtime, date, and location. A standard bid price form is helpful to ensure an "apples toapples" cost comparison.6. Clearly state the evaluation criteria and weighting factors for scoring proposals.7. Allow sufficient time for vendors to prepare good proposals.
27Audit Checklist: Solicitation Process (continued) An RFP also should:Avoid specifications that favor a particular bidderSpecify qualifications for the vendor personnel who would be assigned to the projectIdentify federal and state requirements vendors need to knowOutline all communication devices the agency will use to ensure equal access to information by biddersAvoid specifications that favor a particular bidder or brand.9. Specify the qualifications for the company and/or personnel who would be assigned to the project.10. Identify federal and state requirements that govern the contracting process and the delivery of services.11. Outline all procurement communication devices to ensure all appropriate bidders or potential bidders have access to the same information, i.e. pre-bid conferences, Q & A's, whom to contact with questions, etc.
28Audit Checklist: Award Process The contract award process should:Ensure proposals are responsive to agency needsEnsure contracts are awarded fairlyAssure best value and defensible award decisionsAlthough vendor evaluation methods vary, the contract award process shouldEnsure vendor proposals are responsive to the agency's needs, consistently and objectively evaluated, and contracts are awarded fairly to responsible vendors. Without proper awarding practices, there is little assurance an agency is selecting the most qualified vendor at the best price (best value). Furthermore, contracting decisions may not be defendable if challenged.Your team should consider analyzing evaluation criteria of vendors and assessing the independence of evaluation and negotiation teams. On the next slide, we’ll provide more detail.
29Audit Checklist: Award Decision When an agency makes an award decision, it should:Control bids upon receipt to prevent leaks and additional opportunities to cure deficits.Have appropriate procedures for handling late or incomplete proposalsEnsure that an adequate number of proposals were receivedUse a trained, independent evaluation committeeUse fixed, clear, consistent scoring scales to measure proposals against RFPCheck vendor referencesDocument award decision and keep supporting materialsWhen making an award decision, the agency should safeguard the process via a number of steps. You may wish to review related documentation!Control the security of the bidding process. This will ensure that bids are not opened prematurely to give late bidding vendors confidential pricing information, bids are not accepted after the due date, and that inferior bids are not given extra opportunity to cure deficitsHave appropriate procedures for handling late or incomplete proposals.Insure that an adequate number of proposals were received.Use an evaluation committee, comprised of individuals who are trained on how to scoreand evaluate the proposals and who are free of impairments to independence.Use fixed, clearly defined, and consistent scoring scales to measure the proposal againstthe criteria specified in the RFP.Carefully check vendor references.Document the award decision and keep supporting materials.
30Audit Checklist: Contract Provisions Goals of the contract provisions:Protect the interests of the agencyIdentify the responsibilities of all parties to the contractDefine what is to be deliveredDocument the mutual agreement, substance, and parameters of the termsMost contract provisions are in state law, and we discussed common contract components earlier in this presentation. This slide covers some essential components that will help your team, develop findings about how well a contract was put together. At a minimum, contracts for the purchase of services must be formal, written documents. Contracts should(1) protect the interests of the agency, (2) identify the responsibilities of the parties to the contract, (3) define what is to be delivered, and (4) document the mutual agreement, the substance, and parameters of what was agreed upon.
31Audit Checklist: Contract Provisions (continued) Scope, terms, renewalsDeliverables and reportingPayment amounts, schedulesLimits on the state’s liabilityPerformance standards/incentivesAudit and inspectionConditions for terminationConditions for renegotiation and/or price escalationTying payments to deliverablesAppropriate signatures/reviewAs we discussed, what’s in a contract can be dictated by state law. However, some general principles hold. Specifically, the contract should:1. Clearly state and define the scope of work, contract terms, allowable renewals as well asprocedures for any changes.2. Provide for specific measurable deliverables and reporting requirements, including duedates.3. Describe the methods of payment, payment schedules, and escalation factors ifapplicable.4. Limit the state’s liability for work performed either before or after the contract’s scope.5. Contain performance standards, performance incentives and/or clear penalties andcorrective actions for non-performance, with a dispute resolution process. The contractalso should include a requirement for a performance bond when appropriate.6. Contain inspection and audit provisions. For example, a provision that requires the auditor’s office access to proprietary information if required in the course of a review.7. Include provisions for contract termination.8. Include provisions for contract renegotiation and / or price escalations if applicable.9. Tie payments to the acceptance of deliverables or the final product, if possible.10. Contain all standard or required clauses as published in the RFP. The contract may alsoincorporate the RFP itself. Order of precedence should be addressed in case of adiscrepancy between the RFP and the body of the contract for example.11. Contain appropriate signatures, approvals, acknowledgements or witnesses.12. As necessary, allow for legal counsel's review of the legal requirements for forming thecontract
32Audit Checklist: Contract Monitoring Goals of monitoring:Ensure that contractors comply with contract termsEnsure that performance expectations are achievedIdentify and resolve problemsContract monitoring is an essential part of the contracting process. Monitoring should ensure that contactors comply with contract terms, performance expectations are achieved, and any problems are identified and resolved. Without a sound monitoring process, the contracting agency does not have adequate assurance it receives what it contracts for.Our office learns more about how agencies monitor contracts and develop controls via interviews with staff and reviews of policies and procedures. For example, we learned in an interview how infrequently an agency communicated with an out-of-state vendor. When we asked this agency for procedures it follows to structure a relationship with the vendors, it could not produce any.As you know, when agencies don’t monitor, this creates opportunities for waste, fraud and abuse. For example, a Florida state agency once contracted for construction of a building. the contract manager never visited the building site. For a year, the contract manager forwarded invoices to the budget office based on the contractor’s statement that certain stages of construction were complete. When he finally visited the site, there wasn’t even a hole in the ground – no construction had taken place.
33Contract Monitoring (continued) Proper monitoring includes:Assigning a contract manager with adequate skills, authority, resources, and timeTracking budgets and compare charges to terms an conditionsEnsuring on-time deliverables and document acceptance/rejectionWithholding payment until deliverables are receivedRetaining documentation supporting charges against the contractEvaluating the contractor’s performance against pre-established criteriaFindings about contract monitoring/administration require lots of documentation. Look to see that an agency has:1.Assigned a contract manager with the authority, resources, and time to monitor theproject.2. Ensured that the contract manager possesses adequate skills and has the necessarytraining to properly manage the contract.3. Tracked budgets and compare invoices and charges to contract terms and conditions.4. Ensured that deliverables are received on time and document the acceptance or rejectionof deliverables.5. Withheld payments to vendors until deliverables are received.6. Retained documentation supporting charges against the contract.7. After contract completion the agency evaluates the contractor's performance on thiscontract against a set of pre-established, standard criteria and retains this record ofcontract performance for future use. If agencies do maintain a record of contractor pastperformance, it has the potential use as an evaluation element under "Award Decision".
34Discussion: Part 3Review/Discuss: What controls should be in place to ensure a defensible award?What did we miss today, or what additional information would your team need to develop findings related to the contracting process?Some ideas/discussion items to highlight:independence of the evaluation team, a consistent scoring method, transparent/consistent proceduresDiscuss
35Links National State Auditors Association www.nasact.org/ National Association of State Procurement OfficersAs many of you know, the performance audit section of the national state auditors association is a great resource. Their publications were the primary source of part 3 of this presentation.The national association of state procurement officers is a great resource if you need evidence of best practices in procurement and contract management. Their site has white papers, surveys, and state contacts. Some materials are available at cost, but may be available through your state’s procurement office.
36Contact the Florida Legislature’s OFFICE OF PROGRAM POLICY ANALYSIS For More InformationContact the Florida Legislature’sOFFICE OF PROGRAM POLICY ANALYSISAND GOVERNMENT ACCOUNTABILITY(850)