[Survey Report on Oversight of Concessions Operations and Fee Payments, Guest Services, Inc., and Rock Creek Park Horse Centre, Inc., National Park Service]
[From the U.S. Government Printing Office, www.gpo.gov]
Report No. 97-I-515
Title: Survey Report on Oversight of Concessions Operations and
Fee Payments, Guest Services, Inc., and Rock Creek Park
Horse Centre, Inc., National Park Service
Date: February 28, 1997
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of Inspector General, Division of Acquisition and Management Operations at (202) 208-4599.
******************************
United States Department of the Interior
MEMORANDUM
TO:
FROM:
SUBJECT SUMMARY: Final Survey Report for Your Information - "Oversight of
Concessions Operations and Fee Payments, Guest Services, Inc.,
and Rock Creek Park Horse Centre, Inc., National Park Service"
(No. 97-I-515)
Attached for your information is a copy of the subject final survey report. The objective of
the audit was to determine whether the National Park Service provided adequate oversight
to ensure that Guest Services, Inc., and the Rock Creek Park Horse Centre, Inc., were
operating in compliance with provisions of their concessions contracts and Park Service
concessions management regulations and whether the concessioners had implemented
adequate controls to ensure that all appropriate fees were paid.
We found that the Park Service's National Capital Area was generally providing adequate
management and oversight of these two concessioners. However, improved oversight was
needed in the following areas: preparing operating and maintenance plans, scheduling and
monitoring operating hours and seasons, approving rates and prices, modifying a contract for
changes in facilities, and authorizing therapeutic riding services at the Horse Centre. Also,
the Park Service had not complied fully with regulations governing utility charges and
building use fees and had not ensured that concessioners maintained adequate controls over
revenues on which f?anchise fees were based. We recommended that the Director of the Park
Service implement measures to ensure that concessioners: (1) comply with Park Service
regulations and concessions contract provisions and (2) maintain adequate records of
concessions revenues. We also recommended that the Park Service ensure that the Horse
Centre conducts operations in accordance with contract provisions.
Based on the Park Service's response, we considered two of the report's eight
recommendations resolved and implemented and six recommendations resolved but not
implemented.
If you have any questions concerning this matter, please contact me at (202) 208-5745 or
Mr. Robert J. Williams, Assistant Inspector General for Audits, at (202) 208-4252.
.
Attachment
E-IN-NPS-009-96
United States Department of the Interior
OFFICE OF INSPECTOR GENERAL
Washington, D.C. 20240
SURVEY REPORT
Memorandum
To: Secretary for Fish and Wildlife and Parks
From: Robert J. Williams
Acting Assistant Assistant Inspector General for Audits
Subject: Survey Report on Oversight of Concessions Operations and Fee Payments,
Guest Services, Inc., and Rock Creek Park Horse Centre, Inc., National Park
Service (No. 97-I-515)
INTRODUCTION
This report presents the results of our survey of the National Park Service's oversight of
concessions operations and fee payments of Guest Services, Inc., and Rock Creek Park
Horse Centre, Inc. The objective of the audit was to determine whether the Park Service
provided adequate oversight to ensure that these two Washington, D .C., area
concessioners were operating in compliance with provisions of their concessions contracts
and Park Service concessions management regulations and whether the concessioners had
implemented adequate controls to ensure that all appropriate fees were paid.
BACKGROUND
Public Law 89-249, enacted in October 1965, authorized the National Park Service to
enter into contracts with concessioners "to provide and operate facilities and services
which [are] desirable for the accommodation of visitors in areas administered by the
National Park Service. " To regulate concessions operations, the Park Service issued
"Concession Guidelines" (NPS-48), which contains guidance on concessioner
responsibilities, such as financial reporting and record keeping, and establishes standards
for the operation of concession facilities. The "Guidelines" also defines the Park Service's
concessions management and oversight responsibilities.
All levels of the Park Service organization are responsible for concessions management
and operations. The Concessions Division of the Washington Office in Park Service
Headquarters is responsible for policy and procedural guidance. As part of an August
1995 Park Service reorganization, a Concessions Program Center was established in
Denver, Colorado. The Center, which reports to the Washington Headquarters Office,
is involved in tasks such as concessions planning, contracting, financial analyses, fee
determinations, and rate and price analyses. At the operational level, field directorates,
system support offices, park superintendents, and concessions specialists are responsible
for oversight and management of concessions operations.
Under a 25year contract ending December 3 1, 2010, Guest Services, Inc., is authorized
to provide recreational services at ice skating, boating, and tennis facilities and to sell food
and merchandise at sites located throughout the Washington, D.C., area. Guest Services
operates at six park units in the National Capital Area: the George Washington Memorial
Parkway, Rock Creek Park, the National Capital Parks - Central and East, the Chesapeake
and Ohio Canal National Historical Park, and the President's Park. (Sites of Guest
Services operations at each of these park units are listed in Appendix 1.)
Rock Creek Park Horse Centre, Inc., operates in Rock Creek Park and is authorized to
provide riding lessons, trail rides, horse boarding, a summer riding camp, and a riding
program for the handicapped. The Horse Centre's concessions contract was effective from
. January 1, 1988, through December 3 1, 1992. Since expiration of the contract, the Park
Service has issued annual extensions to authorize continued operations. In July 1996, the
Park Service solicited offers for a new concessions contract. As of November 4, 1996,
the Park Service was reviewing offers, but it had not set a date for contract award.
SCOPE OF SURVEY
The scope of our survey was limited to two concessioners, Guest Services, Inc., and Rock
Creek Park Horse Centre, Inc., in the National Capital Area and to Park Service
management and oversight of these concessioners' operations. We reviewed records and
observed commercial activities at 3 of 24 Guest Services sites in the National Capital Area
(the Lincoln Memorial food and retail kiosks; the East Potomac Tennis Center; and
Daingerfield Island marina, restaurant, and retail store facilities on the George Washington
Memorial Parkway) and the Horse Centre's operations at its facility in Rock Creek Park.
Our review of fee payments was limited to determining whether franchise and building use
fees were paid properly and whether there were adequate controls to ensure that all
revenues, on which franchise fees are based, were recorded accurately.
During our audit, we reviewed laws, regulations, and Park Service guidance pertaining
to concessions operations and analyzed documentation (such as contracts, annual financial
statements, operating and maintenance plans, correspondence, rate and price analyses, and
operational reviews) on the two concessioners' operations selected for review. We
interviewed Park Service officials at headquarters and field offices in Washington, D.C.,
and McLean, Virginia, and concessions officials at their business offices in Fairfax,
Virginia (Guest Services), and Washington, D.C. (the Horse Centre). We also observed
eight Guest Services kiosks in the National Capital Area to determine whether they were
operated in accordance with the approved operating schedules for these facilities.
2
The survey was conducted in accordance with the "Government Auditing Standards, "
issued by the Comptroller General of the United States. Accordingly, we included such
tests of records and other auditing procedures that were considered necessary under the
circumstances. As part of our review, we evaluated the system of internal controls related
to concessions operations and management. We found that the Park Service needed
additional controls to ensure that the concessioners operated in compliance with Park
Service regulations and adequately served the public's interests and that the Horse Centre
and Guest Services (at the East Potomac Tennis Center) maintained adequate controls over
revenues. Our recommendations, if implemented, should improve internal controls in
these areas.
We also reviewed the Department of the Interior's Annual Statement and Report, required
by the Federal Managers' Financial Integrity Act of 1982, for calendar year 1995 and
determined that no material weaknesses directly related to the objective and scope of our
survey were reported.
PRIOR AUDIT COVERAGE
Neither the Office of Inspector General nor the General Accounting Office has issued any
audit reports on concessions operations of Guest Services, Inc., or the Rock Creek Park
Horse Centre, Inc., in the past 5 years. However, the Smithsonian Institution's Inspector
General issued an audit report in April 1996 on Guest Services food service concession
at "a single component of the Institution." The report stated that Guest Services "daily
sales appeared to be accurately reported and deposited." The report also stated that Guest
Services was not reimbursing the Smithsonian for actual utility charges or for the energy _
used by staff cafeterias.
Although the Department of the Interior's Office of Inspector General has issued, during
the past 5 years, several reports on concessions management practices and on individual
concessioners, only one of these reports contained information that was relevant to our
findings. The report "Concessions Management, National Park Service" (No. 94-I-1211),
issued in September 1994, stated that the Park Service undercharged concessioners for the
use of Government-owned facilities and recommended that the Park Service determine and
assess a building use fee, based on fair value, for each Government-owned facility used
by concessioners. In its response, the Park Service said that draft guidelines for building
use fees had been prepared; would be reviewed by a Park Service task force; and would
be implemented by September 30, 1994. During our current review, we found that
procedures for calculating building use fees had been issued in December 1995. A Park
Service Headquarters official said that the procedures would be used as part of the Park
Service's negotiation of Guest Services fees.
RESULTS OF SURVEY
We found that the Park Service's National Capital Area was generally providing adequate
management and oversight of Guest Services, Inc., and Rock Creek Park Horse Centre,
3
Inc., to ensure that these concessioners were operating in accordance with the provisions
of their concessions contracts and in compliance with Park Service regulations. However,
additional oversight and/or controls were needed in five areas: preparing operating and
maintenance plans, scheduling and monitoring operating hours and seasons, approving
rates and prices, modifying a contract for changes in facilities, and authorizing therapeutic
riding services at the Horse Centre. We also found that the Park Service had not complied
fully with its regulations governing utility charges and building use fees and that it needed
to ensure that both concessioners maintained adequate controls over revenues on which
franchise fees are based. We believe that by providing greater oversight and control, the
Park
Service could better
ensure
that these concessions
operations serve
interest and that all revenues due the Federal Government are paid.
the public's
Oversight of Concessions Operations
We found that the Park Service needed to strengthen its oversight and to implement
additional controls to ensure that concessioners complied fully with Park Service guidance
(NPS-48) and with the terms and conditions of their concessions contracts.
Operating and Maintenance Plans. Chapters 26 and 37 of NPS-48 provide
guidance on concessioners' operating and maintenance plans. According to this guidance,
plans should clearly identify the "day-to-day operational requirements, procedures and
responsibilities of both the Service and the concessioner" and "must be designed to custom
fit the type of service" to be useful. We found that Guest Services and the Horse Centre
had fulfilled their general maintenance responsibilities under their operating and
maintenance plans. However, we also found that the Park Service had prepared one
operating and maintenance plan for all Guest Services commercial enterprises within each
park unit and that the plans, in general, had no detailed standards. As such, park units
having an assortment of Guest Services commercial operations (such as National Capital
Parks - Central, with its paddle boat rental, tennis court, and food and merchandise sales
facilities) did not have plans that were "custom fit" to the type of services rendered, nor
were operations subject to written standards governing matters such as hours of operation,
staff qualifications, employee training, visitor reservation deposit and refund policy, or
visitor and employee safety measures.
Chapters 26 and 37 of NPS-48 also require that operating and maintenance plans "be
reviewed jointly with the concessioner each year and revised as required." We found,
however, that the Park Service had not updated Guest Services maintenance and operating
plans in a timely manner. Only one of Guest Services operating and maintenance plans
had been reviewed in the past 2 years, and the other plans had not been revised, on the
average, for over 9 l/2 years. At the time of our review, two park units had prepared
revised plans, which were under negotiation with the concessioner.
Operating Hours/Seasons. According to the operating and maintenance plan for
National Capital Parks - Central, Guest Services is required to submit to the Park Service
by March 15 a proposed schedule of operations for the year. In lieu of Guest Services
submitting a schedule, the Park Service has periodically issued memoranda establishing
the seasons or hours of operations in response to Guest Services requests for such. These
memoranda identified the Guest Services kiosks that were to be operated on a seasonal or
a year-round basis and established the hours of daily operation for the kiosks. However,
there was no annual or systematic evaluation of whether the concessioner was meeting its
operating schedule, and there usually was no written approval for changes to the existing
operating schedule.
At some sites, we found that Guest Services was not maintaining the established hours or
seasons of operations. Specifically, two kiosks that should have been open year-round '
were closed when we visited the sites, and another two kiosks opened later than the
established date. At four other sites, the posted operating hours were shorter than the
established operating schedule.
Park Service concessions specialists responsible for these sites said that they had orally
approved the temporary closure of the year-round facilities (two kiosks), the delayed
opening of the two seasonal kiosks, and shortened operating hours at one site. However,
the concessions specialists said that they had not approved shortened operating hours at
the three other sites.
Rate and Price Approval. Chapter 18 of NPS-48 requires the Park Service to
approve rates or prices charged the public and to ensure that certain types of merchandise
are sold at prices within approved rates. At two of three Guest Services sites reviewed
and at the Horse Centre, we found that the Park Service had ensured that the prices of
goods and services offered to the public were within the approved rates. However, the
concessions specialist at National Capital Parks - Central had not obtained cost
documentation or a supplier's published retail price list to validate that merchandise was
priced properly at the other Guest Services site.
Contract Modification. Chapter 10 of NPS-48 requires the Park Service to amend
a concessions contract if there is a "change in services, facilities and accommodations
provided. " However, Guest Services operated four concessions (the Glen Echo Park snack
bar, the Anacostia Pavilion, the Pierce Mill tennis courts, and the Air and Space retail
kiosk) that were not authorized under its contract or any contract modification. According
to a Park Service official, Guest Services had taken over these four concessions on a trial
basis, and the Park Service had not modified the concessions contract when Guest Services
continued to operate the facilities. Park Service records showed that Guest Services had
been operating the Glen Echo facility since about 1986. However, the Park Service had
no record of the date on which Guest Services assumed operational control at the three
other sites.
Therapeutic Riding Services. Under its contract with the Park Service, the Horse
Centre was authorized to provide riding programs for the handicapped. However, instead
of providing these programs, the Horse Centre entered into a related-party agreement with
the National Center for Therapeutic Riding, a nonprofit organization whose executive
5
director is also president of the Horse Centre. Under the agreement, the National Center
paid the Horse Centre for facilities, horses, and instructors. Although the Horse Centre
recognized these payments in computing its franchise fees, it had not been authorized by
the Park Service to sublet facilities, to provide staff on a cost-reimbursable basis, or to
lease horses. A Horse Centre official said that the National Center conducted the
therapeutic riding sessions because the Horse Centre had not obtained insurance coverage
for this activity. She said that the Horse Centre believed the cost of insurance to cover the
disabled to be too expensive and that the Horse Centre, therefore, had not attempted to
obtain such coverage.
We consider the National Center's operations, which are conducted solely on national park
property, to be unauthorized because the Center is a separate corporate entity and is not
an approved subconcessioner. (The Park Service had posted signs in Rock Creek Park for
both the Horse Centre and the National Center indicating that both enterprises were
approved by the Park Service.) Further, the Park Service does not review the National
Center's financial report and does not evaluate the operations of the National Center
during its periodic performance reviews. As such, the National Center may not be subject
to Park Service oversight, which would enable the Park Service to monitor and regulate
the National Center's activity and ensure that Park Service-established standards are met
in the delivery of therapeutic riding services. Moreover, there is no arms length
relationship between the Horse Centre and the National Center, which are owned by the
same individual, to minimize the risk of improprieties or financial mismanagement.
At the time of our review, the Park Service was reviewing offers prior to awarding a new
concessions contract for the Horse Centre. We believe that if the Horse Centre is selected
as the new concessioner, the Park Service should: (1) ensure that the therapeutic riding
sessions are conducted by the Horse Centre in accordance with contract provisions and that
all revenues from this activity are reported to the Park Service or (2) approve the
operations of the National Center as a subconcession and ensure that the subconcessioner
meets Park Service operating and financial standards for such an operation.
Fee Payments
We found that the Park Service needed to ensure that concessioners were paying the
proper amounts for utility costs, building use fees, and franchise fees.
Utility Costs. Chapter 18 of NPS-48 requires the Park Service to charge
concessioners for the cost of utilities supplied "based on operating costs . . . but not lower
than comparable utility costs. " However, the Park Service did not bill Guest Services for
utilities supplied to a cafeteria that was operated inside a Park Service office building and
a retail shop at the Jefferson Memorial.
A Park Service official said that Guest Services was not charged for utilities at the
cafeteria because the Park Service occasionally used the facility for meetings and that it
would be difficult to determine the portion of utility costs attributable to the concessioner's
6
operations. Another Park Service official said that Guest Services was not charged for
utilities at the retail shop because there was no separate metering of the concessioner's
space. Because the concessioner is not paying utility costs, the Park Service is in effect
subsidizing concessions operations.
Building Use Fees. Chapter 24 of NPS-48 requires the Park Service to charge
concessioners for the use of Government-owned buildings. Specifically, the guidance
states that "all buildings, structures, or facilities assigned for concessioner use shall
provide for a fair value return" to the Government and provides for adjustments to the
appraised value, taking into consideration factors "regarding reasonable profit. "
The Guest Services concessions contract includes a list of Government-owned buildings,
which had a replacement value of $9.2 million in 1985, that are used by the concessioner.
Since 1986, Guest Services has paid $14,400 a year for these structures. A Headquarters
official said that the Park Service plans to implement the new building use fee guidance,
issued in 1995, as part of its negotiation of the fees paid by Guest Services.
Franchise Fees. Chapter 24 of NPS-48 authorizes the Park Service to require
concessioners to maintain records needed to determine whether all terms of the concessions
contract have been performed. However, the Horse Centre did not maintain adequate
records or record-keeping systems needed for the Park Service to validate revenues from
trail rides, group and individual horse riding lessons, and horse boarding. For example,
the Horse Centre did not issue tickets or use a cash register to record receipts from trail
rides and did not maintain an adequate system for tracking revenues from horse riding
lessons. As such, we were unable to verify that all revenues from trail rides and riding
lessons were reported. Also, the concessioner told us that during the past few years, it has
had a waiting list of individuals seeking to board horses. However, its financial statements
for calendar year 1995 reported horse boarding revenues that reflected less than full use
of the stables. Because the concessioner did not maintain records to document all boarding
agreements in effect during 1995 and did not require boarders to submit advance written
notification when they terminated their boarding arrangements, we were unable to
determine whether the Horse Centre had recorded all boarding fee receipts.
At Guest Services East Potomac Tennis Center, we found that the concessioner issued
tickets for court rental and for other services rendered and placed related receipts in a cash
register. However, in our tests of 15 days of transactions at the Tennis Center, we found
that daily receipts recorded on the Center's sales tickets did not agree with the daily sales
report, which was maintained by Guest Services accounting department, for any of the 15
days. The variance in daily revenues ranged from $290 (the daily sales reported exceeded
the day's sales receipts) to $358 (daily sales receipts exceeded the amount shown on the
daily sales report), and total revenues shown on daily sales tickets were $320 more than
the total revenues shown on daily sales reports for the 15-day period. Because of
inconsistencies in daily sales records, we could not verify the accuracy of the Tennis
Center's reported revenues.
Recommendations
We recommend that the Director, National Park Service:
1. Direct Park Service superintendents in the Washington, D.C., area to review and
revise, as required, on an annual basis, the operating and maintenance plans for Guest
Services, Inc., and to prepare operating and maintenance plans that are "custom fit" for
the particular type of service and that include specific standards of operation and
maintenance for each of Guest Services commercial activities.
2. Require concessions specialists in the Washington, D.C., area to monitor
concessioners' operating hours to ensure compliance with scheduled hours or seasons of
operation and prepare written approval for any deviation from approved operating
schedules.
-
3. Direct concessions. specialists in the National Capital Area parks to obtain cost
and/or price documentation to help ensure that concessioners' goods and services are
priced in accordance with NPS-48 guidance.
4. Amend Guest Services contract to authorize the concessioner to operate the Glen
Echo Park snack bar, the Anacostia Pavilion, the Pierce Mill tennis courts, and the Air
and Space retail kiosk if such operations are to continue. In accordance with Park Service
guidance, operating and maintenance plans should be prepared for each of these
commercial activities.
5. Ensure that therapeutic riding sessions are conducted by the Horse Centre in
accordance with contract provisions and that all revenues from this activity are reported
to the Park Service or ensure that the Park Service approves the operations of the National
Center as a subconcession so that the Center meets Park Service operating and financial
standards for such an operation.
6. Develop a procedure for identifying and recovering the cost of utilities provided
to Guest Services for its concessions operations at the Park Service office building
cafeteria and the Jefferson Memorial retail shop.
7. Ensure that the National Capital Area Field Office implements the December
1995 guidance on building use fees with respect to Guest Services use of Government-
owned buildings.
8. Ensure that the Rock Creek Park Horse Centre maintains adequate records to
allow the Park Service to validate reported revenues. Also, Guest Services should be
required to implement additional controls to ensure that all East Potomac Tennis Center
receipts are accounted for and are reported accurately.
National Park Service Response and Office of Inspector General Reply
In the January 24, 1997, response (Appendix 2) from the Field Director, National Capital
Area, National Park Service, the Park Service concurred with seven of the eight
recommendations. The Park Service disagreed with Recommendation 7, stating that the
Washington Office of Concessions Management was not the office responsible for
implementation. However, the Park Service also stated that corrective action had been
taken. We have revised the recommendation to clarify that the National Capital Area is
the responsible office. Based on the response, we consider Recommendations l-6 resolved
but not implemented and Recommendations 7 and 8 resolved and implemented.
Accordingly, the unimplemented recommendations will be referred to the Assistant
Secretary for Policy, Management and Budget for tracking of implementation.
Since the report's recommendations are considered resolved, no further response to the
Office of Inspector General is required (see Appendix 3).
The legislation, as amended, creating the Office of Inspector General requires semiannual
reporting to the Congress on all audit reports issued, actions taken to implement audit
recommendations, and identification of each significant recommendation on which
corrective action has not been taken.
We appreciate the cooperation of National Park Service personnel in the conduct of our
audit.
APPENDIX 1
SITES OF GUEST SERVICES, INC., AT EACH PARK UNIT
Chesapeake and Ohio Canal National Historical Park
Great Falls, Maryland (food)
Harry Thompson Boat Center(boat rentals)
George Washington Memorial Parkway
* Daingerfield Island (marina, food, merchandise)
Columbia Island (marina, food)
Great Falls, Virginia (food)
Glen Echo, Maryland (food)
National Capital Parks - Central
* Lincoln Memorial (food, merchandise)
** Dinosaur Exhibit (food, merchandise)
** American History Museum (food)
** Washington Monument Lodge (food, merchandise)
** Pershing Park (skating, food)
** Air and Space Museum (food, merchandise)
* East Potomac Tennis Center (tennis courts, lessons)
National Capital Area Office Cafeteria (food)
**
**
Jefferson Memorial (food, merchandise)
South Mall Carousel (food)
Tidal Basin (paddle boats, food)
Constitution Gardens (food)
National Capital Parks - East
Anacostia Park Pavilion (food)
Fort DuPont Park (skating)
President's Park
** President's Park Kiosk (food, merchandise)
Rock Creek Park
Reservoir Tennis Courts (tennis courts)
Pierce Mill Tennis Courts (tennis courts)
Carter Baron Amphitheater (food)
* Sites visited to review financial records and observe operations.
** Sites visited to observe operating hours/seasons
10
United States Departmeflt of the Interior
-
NATIONAL PARK SERVICE
APPENDIX 2
Page 1 of 4
C3823(NCSO-OCM)
Memorandum
To . .
Through:
Assistant Inspector General for Audits
Management Officer, Audit and Accou
1 Park Service
Thank you for the opportunity to review the subject Inspector General draft report. The
draft report was forwarded to our Concessions Management staff for comment. At this
time we would like to provide the attached comments, updates, and the individuals
responsible for complying with the recommendations.
Should you have any questions or require any further information, please contact Ed Duffy,
Chief of Concessions Management, at (202) 619-7404.
Attachment
11
APPENDIX 2
Page 2 of 4
NATIONAL PARK SERVICE, NATIONAL CAPITAL AREA
COMMENTS ON DRAFT SURVEY REPORT
(ASSIGNMENT NO. E-IN-NPS-009-96)
OVERSIGHT OF CONCESSIONS OPERATIONS AND FEE PAYMENTS
GUEST SERVICES, INC., AND ROCK CREEK PARK HORSE CENTRE, INC.
1 . Direct the National Park Service superintendents in the Washington, D.C., area to
review and revise, as required, on an annual basis, the operating and maintenance
plans for Guest Services, Inc., and to prepare operating and maintenance plans that
are "custom fit" for the particular type of service and that include specific standards
of operation and maintenance for each of Guest Services commercial activities.
AGREE. PARK SUPERINTENDENTS WITH GSI OPERATING WITHIN THEIR
BOUNDARIES WILL BE
REMINDED TO ANNUALLY REVIEW AND REVISE, AS NEEDED, THEIR MAINTENANCE
AND OPERATING
PLANS WITH THE CONCESSIONER. WE AGREE THAT THE PLANS SHOULD CONTAIN
INFORMATION
WHICH IS BOTH GENERAL AND SITE SPECIFIC. HOWEVER, WE DO NOT AGREE THAT
EACH SITE
SHOULD HAVE lTS OWN SEPARATE PLAN. WITH ONE OF THE AFFECTED PARKS
HAVING MORE
THAN A DOZEN SITES, IT WOULD NOT BE PRACTICAL OR EFFICIENT TO PREPARE
AND EXECUTE lW0
PLANS PER SITE. THEREFORE, WE WILL RECOMMEND THAT THE PARKS REVISE AND
UPDATE THEIR
MAINTENANCE PLAN AND OPERATING PLAN FOR GSI SO THAT THEY CONTAIN
GENERAL, AS WELL
AS, SITE SPECIFIC STANDARDS. THIS WILL BE ACCOMPLISHED BY THE END OF
FISCAL YEAR
1997. THE CHIEF OF CONCESSIONS MANAGEMENT, NATIONAL CAPITAL SYSTEM
SUPPORT
OFFICE, WILL BE RESPONSIBUE FOR THIS ACTION.
IT SHOULD BE NOTED THAT DURING THE TIME THIS AUDIT WAS CONDUCTED AND
THE CLOSE OUT
MEETING HELD, THAT NATIONAL CAPITAL PARKS-CENTRAL AND GEORGE
WASHINGTON
MEMORIAL PARKWAY, IWO OF THE THREE PARKS VISITED BY THE AUDITORS, HAD
ALREADY
PREPARED AND SUBMITTED PLANS TO GSI FOR SIGNATURE. NEGOTIATIONS BEMEN
GSI AND
THESE PARKS ARE ONGOING.
2 .
Require concession specialists in the Washington, D.C., area to monitor concessioners'
operating hours to ensure compliance with scheduled hours or seasons of operation
and prepare written approval for any deviation from approved operating schedules.
AGREE. PARK CONCESSION SPECIAUSTS WILL BE NOTIFIED TO COMPLY WITH THIS
RECOMMENDATION. THE PROPER OPERATING HOURS FOR EACH SITE WILL BE
PLACED IN EACH
OPERATING PLAN AND APPROVAL OBTAINED IN WRITING FOR ANY TEMPORARY OR
PERMANENT
CHANGE. THIS WIU BE ACCOMPLISHED BY THE END OF FISCAL YEAR 1997. THE
CHIEF OF
CONCESSIONS MANAGEMENT, NCSO, WIU BE RESPONSIBLE.
3 .
Direct concession specialists in the National Capital Area parks to obtain cost and/or
documentation to help ensure that concessioners' goods and services are priced in
accordance with NPS-48 guidance.
12
APPENDIX 2
Page 3 of 4
3
AGREE. PARK CONCESSION SPECIALISTS WIU BE REMINDED TO STRICTLY FOLLOW
THE PRICING
GUIDELINES SET FORTH WITHIN NPS48. IT SHOULD BE NOTED THAT THE NATIONAL
CAPITAL
AREA RECENTLY EXPERIENCED AN EXTENSIVE TURNOVER IN PARK CONCESSION
SPECIAUSTS
STAFF. \NlTH FEW EXCEPTIONS, THE MAJORlTY OF THE PARK SPECIALISTS HAVE 1
YEAR OR LESS
EXPERIENCE. AT THE TIME THE AUDIT BEGAN, THE CONCESSION SPECIALISTS IN
THE AUDITED
PARKS, HAD APPUED FOR, BUT NOT YET TAKEN, THE EVALUATION AND PRICING
TRAINING
REQUIRED FOR AU SPECIAUSTS. IN MAY, ONLY A FEW MONTHS AFTER THE AUDIT
BEGAN, Two
OF THE THREE SPECIAUSTS SUCCESSFUUY COMPLETED THIS TRAINING. THIS HAS
BEEN
ACCOMPUSHED. THE CHIEF OF CONCESSIONS MANAGEMENT, NCSO, WIU FORWARD
COPY OF
THIS RESPONSE AND WI11 REVIEW ANNUAL REPORTING DOCUMENTS TO INSURE
COMPUANCE.
4 .
Amend Guest Services Inc., contract to authorize the concessioner to operate Glen
Echo Park snack bar, the Anacostia Pavilion, the Pierce Mill tennis courts, and the Air
and Space retail kiosk if such operations are to continue. In accordance with National
Park Service guidance, operating and maintenance plans should be prepared for each
of these commercial activities.
AGREE. THE CONCESSIONS MANAGEMENT STAFF OF THE SYSTEM SUPPORT OFFICE
IS IN THE
PROCESS OF AMENDING THE GSI CONTRACT NOT ONLY TO INCLUDE THESE SITES,
BUT ALSO TO
REFLECT THE RECENTLY NEGOTIATED FRANCHISE FEE. SEE NUMBER 1 FOR
NATIONAL PARK
SERVICE COMMENT REGARDING SITE SPECIFIC MAINTENANCE AND OPERATING
PLANS. THE
CONTRACT AMENDMENT WIU BE EXECUTED BY APRIL 1, 1997.
5 .
Ensure that therapeutic riding sessions are conducted by the Horse Centre in
accordance with contract provisions and that all revenues from this activity are
reported to the National Park Service, or ensure that the National Park Service
approves the operations of the National Center as a subconcession so that the Center
meets Park Service operating and financial standards for such an operation.
AGREE. THE THERAPEUTIC RIDING CLASSES ARE A SERVICE AUTHORIZED BUT NOT
REQUIRED
UNDER THE CONCESSION CONTRACT. THE SUPERINTENDENT FOR ROCK CREEK
PARK WILL
ENSURE THAT THE CONCESSIONER, ROCK CREEK PARK HORSE CENTRE, INC., WIU
BE THE SOLE
ENTITY PROVIDING SERVICES, INCLUDING THERAPEUTIC RIDING CLASSES, TO THE
PUBUC. THE
NATIONAL PARK SERVICE WIU NOT BE APPROVING A SUBCONCESSION AGREEMENT
BETWEEN OUR
CONCESSIONER AND THE NATIONAL CENTER FOR THERAPEUTIC RIDING. OUR
CONCESSIONER
WILL CONTINUE TO BE THE ONLY BUSINESS ENTITY AUTHORIZED TO PROVIDE
SERVICES TO THE
PUBUC AT THE ROCK CREEK PARK HORSE CENTRE. THIS WILL BE ACCOMPLISHED
BY THE PARK
CONCESSION SPECIAUST THROUGH INFORMAL VISITS AND PERIODIC INSPECTIONS.
6 .
Develop a procedure for identifying and recovering the cost of utilities provided to
Guest Services for its concessions operations at the National Park Service office
building cafeteria and the Jefferson Memorial retail shop.
13
APPEFJDIX 2
Pace 4 of 4
0
4
NPS COMMENT:
7 .
Ensure that Washington Office concessions officials implement the December 1995
guidance on building use fees with respect to Guest Services use of Government-
owned buildings.
DISAGREE. THE WASHINGTON OFFICE OF CONCESSIONS MANAGEMENT DOES NOT
IMPLEMENT GUIDANCE SUCH AS THE 1995 MEMORANDUM. HOWEVER, THE
NATIONAL CAPITAL
AREA FIELD OFFICE IN CONCERT WITH THE WASHINGTON OFFICE RECENTLY
COMP~ED A NEW
FRANCHISE FEE STRUCTURE FOR GSI. DURING THIS PROCESS, AU POTENTIAL
IMPACTS,
INCLUDING INCREASING BUILDING USE FEES, WERE CONSIDERED AND THE NEW
FEE REPRESENTS
THE FAIR MARKET VALUE OF THE CONTRACT IN ACCORDANCE WITH PUBLIC LAW
89-249. THIS
ACTION HAS BEEN ACCOMPUSHED.
8 .
Ensure that the Rock Creek Park Horse Centre maintains adequate records to allow the
Park Service to validate reported revenues. Also, Guest Services should be required
to implement additional controls to ensure that all East Potomac Tennis Center receipts
are accounted for and are reported accurately.
AGREE. THE SUPERINTENDENTS AND APPROPRIATE STAFF AT ROCK CREEK PARK
AND
NATIONAL CAPITAL PARKS-CENTRAL HAVE BEEN INFORMED OF THIS PROBLEM.
THE PARKS HAVE
BEGUN WORKING DIRECTLY WITH THE CONCESSIONERS TO ENSURE THAT MORE
ACCURATE SALES
RECORDS ARE MAINTAINED AT ROCK CREEK PARK HORSE CENTRE AND THAT GSI
WILL
IMPLEMENT ADDITIONAL CONTROLSTO ENSURE THAT EAST POTOMAC TENNIS
CENTER RECEIPTS
ARE ACCOUNTED FOR AND REPORTED ACCURATELY. FOR AU INTENT AND
PURPOSES, THIS
ACTION HAS BEEN ACCOMPLISHED. PERIODIC REVIEW TO ENSURE CONTINUED
COMPUANCE WILL
BE CONDUCTED BY THE PARK CONCESSION SPECIAUSTS THROUGHOUT THE YEAR.
14
APPENDIX 3
STATUS OF SURVEY REPORT RECOMMENDATIONS
Finding/Recommendation
Reference
Status Action Required
1, 2, 3, 4, 5, and 6
Resolved; not
implemented
No further response to the Office
of Inspector General is required.
The recommendations will be
referred to the Assistant Secretary
for Policy, Management and
Budget for tracking of
implementation.
7 and 8
Implemented
No further action is required.
15
ILLEGAL OR WASTEFUL ACTIVITIES
SHOULD BE REPORTED TO
THE OFFICE OF INSPECTOR GENERAL BY:
Sending written documents to: Calling:
Within the ContinentkJnited States
U.S. Department of the Interior
Office of Inspector General
1849 C Street, N.W.
Mail Stop 5341
Washington, D.C. 20240
Our 240hour
Telephone HOTLINE
l-800-424-508 1 or
(202) 208-5300
TDD for hearing impaired
(202) 208-2420 or
l-800-354-0996
Outside the Continental United States
Caribbean Region
U.S. Department of the Interior
Office of Inspector General
Eastern Division - Investigations
1550 Wilson Boulevard
Suite 410
Arlington, Virginia 22209
(703) 235-9221
North Pacific Region
U.S. Department of the Interior
Office of Inspector General
North Pacific Regiori
238 Archbishop F.C. Flares Street
Suite 807, PDN Building
Agana, Guam 96910
(700) 550-7428 or
COMM 9-O1l-67l-472-7279