The Department did not ensure that the seven employees involved in the procurement of the audited contract with Vincent Roofing
Inc. completed a Nepotism Disclosure Form, as required by Texas Government Code, Section 2262.004. The Nepotism Disclosure Form is
required to be completed even in the absence of potential or actual nepotism. While auditors did not identify any instance of
nepotism, ensuring that the required disclosure forms are completed by all applicable parties could help the Department ensure that
the procurement process is fair and objective.
In addition, the individuals involved in the procurement and management of the audited contract did not complete a conflict of
interest statement. This included the seven Facilities Section employees who procured (recommended for award) the contract and the
three Facilities Section employees who managed the contract. The Department asserted that Title 34, Texas Administrative Code,
Section 20.158, requires conflict of interest disclosures be documented only when a potential or actual conflict exists. Therefore,
the Department did not require its employees involved in the procurement or management of a contract to document their asserted
absence of a conflict of interest.
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