By Adam Pagnucco.
Inspector General Megan Davey Limarzi has issued a new report finding several problems inside the county’s Recreation Department (REC). Specifically, the Office of Inspector General (OIG) found:
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REC paid invoices totaling over $5,842,000 that lacked adequate support.
REC still does not have formal policies and procedures governing criminal background investigations.
Not all REC facilities comply with policies related to tracking and receiving program and use fees.
REC does not consistently monitor instructor contracts or instructor performance as required by policy.
REC violated the County’s purchasing card policy.
REC did not adhere to the County’s non-local travel policy.
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Upon reading the report, the two findings that stand out for me are the ones about criminal background investigations and the county’s purchasing card policy. On the former issue, the recreation department serves a large number of children throughout the county, so background checks are important. On the latter issue, use of the county’s purchasing cards (“p-cards”) have led to repeated problems over the years. Let’s review the report’s language on those two issues in detail.
First, the report offers these comments about criminal background investigations.
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Finding 2: REC still does not have formal policies and procedures governing criminal background investigations.
In May of 2022, the OIG published OIG Publication# OIG-22-014, Criminal Background Investigations, documenting that REC did not have a formal policy concerning criminal background investigations. Specifically, the review found that REC did not always follow the processes outlined in draft policies when conducting criminal background investigations, did not have policies addressing the retention and destruction of criminal history information and related hiring records, and continued the monitoring or reinvestigation of employees after their departure from REC. At the time of the review, REC had only a draft policy from 2004. The OIG made five recommendations for REC to implement written policies related to criminal background investigations. We learned through this audit that REC still has not formally adopted policies governing the various issues identified by the OIG in 2022.
Since 1986, Maryland law has required that employees of “a recreation center or recreation program operated by the State, a local government, or a private entity primarily serving minors” undergo a federal and state criminal background investigation. Documentation shows REC has fingerprinted individuals to obtain their criminal histories since at least 1993, however procedures were inconsistent and did not follow a formalized policy. We were informed that as of February 2026, a draft of the criminal background investigations policy had been submitted to the County Attorney for review but was subsequently returned to REC with the recommendation of starting from scratch. During our inquiries related to background investigations, we were told that the delay in formalizing the criminal background investigation policy was due to vacancies in relevant positions since the OIG’s initial review four years earlier.
As of July 2026, REC has reportedly revised the draft policy with insight from other departments and is working through internal procedures to obtain stakeholder feedback. Once the Director approves the draft, it is expected to be resubmitted to the County Attorney for review and approval.
A lack of policies and procedures could lead to inconsistent treatment of applicants, inequitable hiring decisions, and inconsistent monitoring practices. The continued monitoring of individuals after they leave County employment could lead to potential violations of privacy laws.
Recommendation 2
We recommend REC implement the recommendations made in the prior OIG report, OIG Publication #OIG-22-014, Criminal Background Investigations.
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Now let’s review what the report stated about purchasing cards.
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Finding 5: REC violated the county’s purchasing policy.
From July 1, 2023, through June 30, 2025, REC expended $2,607,662 through 81647 purchase card (p-card) transactions. P-card purchases are governed by the County’s purchasing card policy manual that provides numerous restrictions on their use.
Our analysis of 45 judgmentally selected purchases from a population of transactions with indicators of noncompliance with policy found numerous instances violating policy. We noted six instances where purchases were split into multiple transactions to circumvent the County’s $9,999 P-Card single purchase limit. In one instance, REC obtained the services of a portable toilet company whose invoice exceeded $12,000. REC paid the vendor in two installments and provided the same invoice to support both payments. In another instance involving the same company, REC was provided with two sequential invoices equaling over $11,000 for the same services. The 4 remaining instances involved situations where the buyer made on line purchases back-to-back to avoid the P-Card single purchase limit. We discussed our findings related to split transactions with REC staff and were given various explanations, none of which justified the violation of policy.
We further observed a p-card transaction for over $40,000 for a hotel stay for 25 REC employees attending a conference. The p-card policy requires Director of the Office of Procurement approval for purchases over $10,000. We inquired with REC as to whether they obtained the requisite approval, but staff could not provide any evidence that an approval had been obtained.
Lastly, we noted one transaction for $12,005 where REC erroneously paid $680 in sales tax. When we inquired of staff, they agreed the sales tax was incorrectly included and subsequently paid. Finally, REC neither uploaded into the payment system, nor could provide support for one identified transaction.
Purposely avoiding vital controls by exceeding purchasing thresholds, through splitting transactions, or not obtaining requisite approvals, leaves the County vulnerable to fraud, waste, and misuse. Similarly, expending County funds that are prohibited by policy and not having proper documentation for expenditures wastes County money and limits the ability to validate compliance with Policy.
Recommendation 5
We recommend REC implement procedures to ensure staff complies with County policies related to the use of p-cards.
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And so we have decades in which one of the county’s main service departments for young people had no “formal policies and procedures governing criminal background investigations” even after an OIG report as well as deliberate violations of county purchasing policy. In his response, the chief administrative officer concurred with all of the OIG’s recommendations.
Now it will be the responsibility of the new administration to ensure that these concurrences are actually implemented.