OCTOBER 2004

REPORT NO. 2005-044

AUDITOR GENERAL
WILLIAM O. MONROE, CPA

DEPARTMENT OF CORRECTIONS
OUTSOURCING OF CANTEEN OPERATIONS
Operational Audit
SUMMARY
In a contract dated October 9, 2003, the
Department of Corrections outsourced Statewide
canteen operations to a private contractor (Keefe
Commissary Network). The contract is expected
to generate annual revenues of approximately $21
million for the Department. As part of our
operational audit of the Department for the period
July 2002 through February 2004 and selected
actions taken through July 25, 2004, we reviewed
the process for outsourcing canteen operations
(including needs assessment, contractor selection,
negotiation, and contract implementation). Our
audit disclosed the following:
Finding No. 1: Florida Statutes do not contain
competitive
procurement
guidelines
for
revenue-generating contracts. As the Statewide
canteen operations contract is revenue generating,
the Department concluded that it was not a
purchase contemplated by law and, consequently,
did not provide notice of the contract opportunity
to all interested parties. The Legislature should
consider revising the Statutes to include
provisions for the competitive procurement of
revenue-generating contracts. Such provisions
should require advertisement and proper notice of
the contract opportunity to all interested parties.
Finding No. 2: Prior to selecting a provider for
Statewide canteen operations, the Department
requested a best and final offer from three
vendors. Along with the request, the Department
provided analyses of net earnings from
Department canteen operations for the 2002-03
fiscal year.
The Department analyses were
generally supported by Department accounting

records and estimates of projected data were
reasonable.
However, certain revenue and
expenditure items included in the Department
analyses (such as vending machine commissions;
canteen operating salaries; and some materials,
supplies, and equipment costs) were not reflected
in the contract with Keefe Commissary Network.
Finding No. 3: Since the effective date of the
Statewide canteen operations contract, the
Department has executed three amendments.
Although some of these amendments may
potentially increase Department costs for canteen
operations (thereby reducing the net proceeds
from the original Statewide canteen operations
contract), a cost analysis or other written
justification for each contract change was not
prepared by Department staff prior to the
execution of each amendment.
Finding No. 4: An amendment to the Statewide
canteen operations contract provides that all
hardware and proprietary software installed in the
canteens at Department facilities remains the
exclusive property of Keefe Commissary Network.
However, as there is no provision for a period of
transition from the Keefe Commissary Network
system, canteen operations may be disrupted in
the
event
Keefe
Commissary
Network
discontinues canteen operations.
Finding No. 5: Department records did not
document that criminal history records checks of
all Keefe Commissary Network employees
assigned to the contract were appropriately
conducted prior to those employees beginning
work in the canteens.

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REPORT NO. 2005-044
BACKGROUND

Historically, the Department operated canteens to
provide convenience items (soft drinks, snack foods,
and other items to supplement what the Department
supplies for the inmates’ basic needs) to inmates
within Department institutions, annexes, road prisons,
forestry camps, and work camps.
Department
employees were responsible for canteen operations
and inmate labor was routinely utilized. According to
Department records, for the fiscal year ended June 30,
2003, the annual net proceeds from Department
canteen operations totaled approximately $15 million.
Department records indicate that the Department
expected that canteen revenues would be maximized
by outsourcing operations.
Accordingly, the
Department entered into a three-year contract (with an
optional two-year renewal period) on October 9, 2003,
with Keefe Commissary Network (part of the Centric
Group, LLC) for the Statewide operation of
Department canteens. Under the terms of the
contract, Keefe Commissary Network is to provide
one full-time employee at each major institution
(regardless of the number of canteens operating at the
institution) to oversee canteen operations.
The
Department is to select and provide inmates for use in
canteen operations and will continue to pay inmates
working in the canteens or performing canteen
support functions.
Each inmate with a sufficient account balance in the
Department’s Inmate Bank (and who is not otherwise
restricted) is allowed to make canteen purchases up to
a set purchase limit, exclusive of any items obtained
through mail order from Department-approved
catalogs.1 The purchase limit is set by the Department
Secretary but, pursuant to law, cannot exceed $100 per
week.2 The canteens operate on a cashless system
whereby inmates use photo identification cards in the
same manner as bank debit cards to make canteen
purchases.

Department of Corrections Rule 33-203.101, Florida
Administrative Code.
2 Section 945.215, Florida Statutes.
1

Items to be sold in the canteens and any additions or
deletions of canteens are subject to Department
review and approval. Item prices may only be
increased by up to 10 percent every six months until
the statutory limit (fair market price) is reached.3
According to the contract, canteen operations were to
be transferred to Keefe Commissary Network over a
150-day period in accordance with an agreed-upon
Implementation Plan and Transition Schedule.
Beginning on the date Keefe Commissary Network
assumed responsibility for the operation of each
facility’s canteens, the Department was entitled to
receive $.82 per inmate per day based on the
Department’s official midnight count of inmates in
that facility. According to Department records, the
average daily inmate population for the fiscal year
ended June 30, 2003, was 68,491. The transition of
canteen operations to Keefe Commissary Network
was completed the week of February 23, 2004. At that
time, there were 238 canteens in operation Statewide.
Two canteens have been added since the contract was
executed. Revenue generated for the Department by
the Keefe Commissary Network contract totaled $10.9
million for the 2003-04 fiscal year.
FINDINGS AND RECOMMENDATIONS
Finding No. 1:

Revenue-Generating Contract

To ensure that State agencies procure commodities
and contractual services in accordance with legislative
intent,4 competitive procurement guidelines (including
purchasing categories and threshold amounts above
which State agencies must utilize competitive
procurement procedures) are established in law.5
However, these guidelines do not address the
procurement of contracts for which the State agency
does not intend to expend State funds.
In the contract with Keefe Commissary Network, the
Department states that the contract is for commodities
purchased for resale which may be procured without
Section 945.215(1)(e), Florida Statutes.
Section 287.001, Florida Statutes, Legislative Intent.
5 Chapter 287, Florida Statutes.
3
4

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REPORT NO. 2005-044

receipt of competitive bids or proposals. Although
the law6 exempts commodities purchased for resale
from competitive procurement procedures, the scope
of the work described in the Keefe Commissary
Network contract is the operation of Department
canteens—an activity formerly performed by the
Department. By outsourcing canteen operations, the
Department will no longer purchase canteen items for
resale and all canteen sales will be conducted by the
vendor. As such, it appears that the primary purpose
of the contract is the procurement of a contractual
service, not a purchase of commodities for resale.
In the contract with Keefe Commissary Network, the
Department also states that the contract is “revenue
generating and is not a purchase contemplated by
Chapter 287, Florida Statutes.” The law requires that
competitive procurement procedures be employed for
contractual services and commodity procurements that
are in excess of purchasing categories and threshold
amounts. By utilizing purchasing categories and
threshold amounts as the basis for requiring
competitive procurement, the law does not address
other value or consideration provided to a contractor
in exchange for commodities or contractual services.
Such value or consideration could include the
authority for a contractor to receive revenue generated
by a contractual agreement.
The legislative intent for procurement describes a
process whereby contracts are awarded equitably and
economically. Similarly, it is in the State’s best interest
that revenue-generating contracts be awarded to the
highest responsive and responsible vendor. Without a
competitive procurement process, the Department
cannot demonstrate that contracts are awarded
equitably or that the greatest amount of revenue for
the best available services will be provided.

highest responsive and responsible vendor, such
provisions should require advertisement and
proper notice of the contract opportunity to all
interested parties. Notwithstanding the current
absence of a statutory requirement to
competitively
procure
revenue-generating
contracts, as a matter of good business practice
the Department should competitively procure
these services.

In response to Finding No. 1, the Department
stated that “it is clearly speculation that the
department could have obtained a higher rate
through the use of one of the statutorily defined
competitive procurement processes.” The point
of our finding was not to speculate whether a
higher rate could have been obtained, but to
emphasize that fair procurement methods should
be utilized to ensure that revenue-generating
contracts are equitably awarded and provide the
greatest amount of revenue for the best available
services. We continue to recommend that the
Department utilize procurement procedures that
ensure all eligible contractors are notified of the
prospective State procurement and are given a
reasonable opportunity to compete for the
contract.
Finding No. 2: Department Analyses of Canteen
Net Earnings
Notwithstanding the Department’s determination that
competitive procurement procedures were not
applicable for the outsourcing of canteen operations,
the Department contacted three vendors (by letter
dated August 22, 2003) and requested a best and final
offer for the operation of the canteens.
Each of the three vendors contacted by the
Department submitted a best and final offer. The
three vendors and the respective offers are shown in
the following table:

Recommendation:
The Legislature should
consider revising current law to include provisions
for
the
competitive
procurement
of
revenue-generating contracts. To ensure that
contracts are awarded equitably and to the

6

Section 287.012(5), Florida Statutes.

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Vendor
Aramark Corporation
Trinity Services Group, Inc., and
Canteen Correctional Services
Keefe Commissary Network

Offer Per
Inmate
Per Day
$ 0.7408
$ 0.7500
$ 0.8200

OCTOBER 2004

REPORT NO. 2005-044

After reviewing the offers, the Department selected
the vendor with the highest offer, Keefe Commissary
Network. Subsequent to the selection of Keefe
Commissary Network, two vendors filed formal
written protests.
One of these protests was
subsequently withdrawn by the vendor,7 while the
second protest (asserting that the Department had not
followed statutory procurement requirements) was
dismissed by the Department.8

Canteen Operations
(1)
for the 2002-03 Fiscal Year
Estimated Revenues:
Merchandise Sales(2)
Vending Machine Commissions
Total Estimated Operating Revenues:

Estimated Gross Profit:

17,967,182
1,935,936
412,992
254,849
308,274
2,912,051

Estimated Net Earnings from
Department Canteen Operations

$ 15,055,131

Average Daily Inmate Population(4)
Number of Days in a Year
Total Inmate Days in a Year(5)

68,491
365
24,999,215
$

0.602

Notes:
(1)

(2)

(4)
(5)
(6)

According to Department personnel, Trinity Services
Group, Inc., subsequently withdrew the protest because the
vendor “just wanted to make sure that the contract with
Keefe reflected the terms of the offer made by Keefe.”
8 The Department dismissed the protest (made by a vendor
who had not been requested to submit an offer) because
“there is no statutory requirement that the contract for
statewide canteen operations be secured through
competitive bid.”

28,293,560

Net Earnings Per Inmate Per Day(6)

(3)

7

Estimated Direct Expenditures:
Cost of Sales(2)(3)
Estimated Other Operating Expenditures:
Store Manager Costs
Canteen Accounting Salaries
Canteen Operating Salaries (Inmates)
Materials, Supplies, and Equipment
Total Estimated Other
Operating Expenditures:

For vendor reference in preparing an offer, the
Department included an overview of Statewide
canteen operations including revenue and profit
amounts for the 2002-03 fiscal year and the minimum
operational requirements (e.g., hours of operation,
staffing levels, etc.) in Attachment 1 to the letter
requesting best and final offers. In the Attachment,
the Department indicated that the Department’s net
earnings from canteen operations were $.602 per
inmate per day.
We reviewed the financial information used in the
Department’s canteen revenue and profit analyses that
were provided in Attachment 1 to the letter soliciting
best and final offers from three vendors. This
financial information is shown in the following table:

$ 45,634,774
625,968
46,260,742

This is a compilation of analyses prepared by Department staff using
available revenue, expenditure, and inmate population data. In some
instances, Department staff annualized partial-year data to estimate the
2002-03 fiscal year net earnings from Department canteen operations.
Merchandise Sales and Cost of Sales do not include amounts related to
mail-order catalog sales.
The Department computed Cost of Sales as 62 percent of Merchandise
Sales based upon historical data.
Average Daily Inmate Population is for the 2002-03 fiscal year and
excludes inmates at work release centers and contracted facilities.
Total Inmate Days in a Year was calculated by multiplying the Average
Daily Inmate Population by the Number of Days in a Year.
Net Earnings Per Inmate Per Day was calculated by dividing the
Estimated Net Earnings from Department Canteen Operations by
the Total Inmate Days in a Year.

Our review of the Department’s calculations disclosed
that the amounts included in the Department analyses
were generally supported by Department accounting
records and estimates of projected data were
reasonable. However, we noted that the estimated
gross profit was overstated by approximately 3 percent
due to the inclusion of sales tax collections (for taxable
items) in merchandise sales.
We also noted that certain revenue and expenditure
items included in the Department’s canteen revenue
and profit analyses were not reflected in the resulting

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OCTOBER 2004
contract with
Specifically:

REPORT NO. 2005-044
Keefe

Commissary

Network.

¾ Vending machine commissions were not
transferred to Keefe Commissary Network.
¾ Canteen operating salaries (inmates) and some
materials, supplies, and equipment costs will
continue to be paid by the Department.
As these items were not reflected in the contract, the
usefulness of the analyses as a meaningful tool to
evaluate the potential canteen revenues due to the
Department under the contract with Keefe
Commissary Network is limited. Also, as noted in
Finding No. 3, subsequent contract amendments
further dissociate the resulting contract from the
analyses. For example, increasing inmate spending
limits potentially increases canteen operation revenues;
however, the Department analyses of net earnings did
not consider the effect of increasing inmate spending
limits on earnings from Department operation of the
canteens.
Recommendation:
Prior to signing a contract,
the Department should ensure that the contract
provisions reflect the elements included in
Department analyses that accompany or support
requests for offers, proposals, or bids.
In
addition, we recommend that the Department
take more care when preparing analyses for
distribution to vendors and other users.

In response to Finding No. 2, the Department
indicated that the differences between the initial
analyses and the October 9, 2003, contract with
Keefe Commissary Network were the result of a
dynamic process. However, the Department
failed to provide documentation of management’s
consideration of the effect of those differences on
net contract earnings. While the Department has
concluded in its response that such dynamic
changes actually resulted in an increase in the
value of the contract to the Department, it is not
apparent that the increase was the result of a
careful management evaluation of contract terms.
Finding No. 3: Contract Amendments
As of July 25, 2004, the contract had been amended
three times since the effective date of the contract
(October 9, 2003). The contract changes that resulted

from the three amendments are shown in the
following table:
Amendment
Number and
Effective Date

Significant Changes to the Contract
Amendment No. 1 Increases inmates' weekly spending limit from
(Effective 02/25/04) $65 to $90.
Adds a provision that if Keefe staff are not
available to receive canteen commodities,
Department warehouse staff will receive and
sign for the boxes and pallets. Keefe is
responsible for accountability of all
commodities received by Department staff on
Keefe's behalf.

Amendment No. 2 Reduces the types of canteen supplies that
(Effective 05/03/04) Keefe is required to provide (thereby increasing
the canteen supplies that will be provided by
the Department).
Adds a provision recognizing the proprietary
nature of Keefe's software and hardware
installed in the canteens and that such software
and hardware remains the exclusive property of
Keefe.
Adds a provision that Keefe is responsible for
claiming exemption from the public records law
(Chapter 119, Florida Statutes) for any pertinent
materials (e.g., computer software).
Amendment No. 3 Acknowledges that the rights and
(Effective 07/25/04) responsibilities of the Access Catalog contract
(No. C1656) have been assigned to Keefe and
prohibits price increases for catalog items.
Allows moneys to be recouped from an
inmate's salary for inventory shortages directly
related to the inmate.
Increases the amount of compensation that
Keefe will provide the Department from $.82
to $.827 per inmate per day based on the
Department's official midnight count.

In addition to the three amendments referred to in the
table above, at the conclusion of audit field work,
according to Department records, the Department was
considering a fourth amendment increasing the
inmates’ weekly canteen spending limit to the statutory
maximum of $100 (which would result in a cumulative
increase in the spending limit of $35 since Keefe
Commissary Network assumed canteen operations).
Although some of the contract changes in the
amendments may potentially increase Department
costs related to canteen operations, Department staff
did not prepare a cost analysis or otherwise document
the justification for each contract change prior to
execution of the amendments. In response to audit
inquiry, Department staff indicated that “although
additional written justification may not have been

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REPORT NO. 2005-044

separately generated, this does not in any way mean
that an amendment is generated and processed on a
whim. Each issue being considered as an amendment
is carefully weighed as to the potential impact on
public safety and additional expense/revenue to the
department.”
Recommendation:
Absent documentation of
Department decisions that justify the contract
amendments, the Department cannot readily
demonstrate that the amendments are in the best
interest of the State and do not diminish the
benefits expected when the Department
outsourced Statewide canteen operations.
Accordingly, to demonstrate that Department
costs associated with canteens are minimized
while Statewide canteen operations contract
revenue is maximized, we recommend that the
Department prepare written justification of the
advantage to the Department (e.g., through
preparation of a cost-benefit analysis) prior to
executing any future contract amendments.

In response to Finding No. 3, the Department
indicated that a cost-benefit analysis had been
prepared during the evaluation of amendment
No. 3. During audit field work we requested
documentation justifying amendment No. 3 and
the Department provided calculations in an
August 19, 2004, memorandum that purported to
demonstrate that the amendment, which
increases the amount due from Keefe Commissary
Network by $.007 per inmate per day, will
effectively maintain the canteen revenue stream
after the assignment of the Access Catalog
contract. However, the Department did not
provide any documentation prepared prior to the
date of the amendment (July 25, 2004) to support
the calculations and we noted that the
calculations appeared flawed. For example, the
purported net revenue amount considered cost
savings for staff time for canteen accounting
positions that had already been eliminated when
the canteen operations were first outsourced. (As
shown in the table in Finding No. 2, the
Department considered the Canteen Accounting
Salaries related to these positions as cost savings
in the initial computation of Net Earnings Per
Inmate Per Day.)
The Department also stated that amendments
Nos. 1 and 2 did not impact the per diem
structure.
We disagree as each of these
amendments contain a provision that requires the
Department to incur costs related to canteen

operations which impact the per inmate per day
amount.
The finding did not imply that the amendments
were generated on a whim or were not approved
by appropriate personnel. However, there is no
documentation to clearly establish that, prior to
amending the contract, the Department
considered the financial effect of these
amendments or whether other alternatives would
have been more advantageous.
Finding No. 4: Transition of Operations
To facilitate canteen operations, the contract requires
Keefe Commissary Network to implement its own
technology system. Due to the size and complexity of
the anticipated system, the contract allows Keefe
Commissary Network an 18-month transition period
after the execution of the contract to implement the
system.
During the transition period, the
Department’s cashless canteen computer system
(hardware and software) is available for Keefe
Commissary Network’s use and the Department is
responsible for maintenance and support of the
system. After transition, existing Department canteen
point-of-sale, file server, and other computer
equipment will be retired from service and will not be
available for Keefe Commissary Network’s use.
At the end of the transition period, Keefe Commissary
Network is required to provide, in each canteen
operated under the contract, a turnkey point-of-sale
system, including all software and equipment for
transactions, receipt printing, and inventory control.
The system must interface with the Department’s
Inmate Bank System that maintains account data for
each inmate.
On May 3, 2004, the Department executed
Amendment No. 2 to the contract. This Amendment
states that “the Department acknowledges the
proprietary nature of the Contractor’s software and
hereby agrees not to reproduce or transfer the
software without written permission of the
Contractor.” In addition, the Amendment provides
that all hardware and Keefe Commissary Network
proprietary software installed in Department facilities

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REPORT NO. 2005-044

remains the exclusive property of Keefe Commissary
Network. However, the amendment does not provide
for a transition period from the Keefe Commissary
Network system in the event Keefe Commissary
Network discontinues Statewide canteen operations.
As there is no provision for a period of transition
from the Keefe Commissary Network system, canteen
operations may be disrupted if the Department elects
to resume canteen operations, the Department selects
another vendor, or Keefe Commissary Network elects
to discontinue providing Statewide canteen operations.
Although, under the contract terms, the Department
will retain the canteen computer system the
Department currently owns, given the relatively short
useful life of information technology equipment, the
current system may no longer be useful after the
contract term expires. In fact, Department staff
indicated that the Department’s current canteen
system is already outdated.
In addition, the analyses of net earnings prepared by
the Department prior to contracting with Keefe
Commissary Network did not consider the costs of
maintaining, supporting, or replacing the canteen
computer system. These costs may negate any
cost-savings or revenue enhancements realized by the
Department from the current contract.
Florida Statutes do not currently require that State
agencies contractually provide for a transition or
phase-out period in the event of contract termination.
Such a provision may reduce disruptions in operations
or activities.
Recommendation:
We recommend that the
Department amend the contract to provide for a
period of transition from the Keefe Commissary
Network canteen computer system in the event
Keefe Commissary Network discontinues
Statewide canteen operations. In addition, to
ensure that operations or activities performed by
contractors are undisrupted in the event of
contract termination, we recommend that the
Legislature consider adding statutory language to
require that State agencies contractually provide
for a transition or phase-out period that includes
consideration of information technology systems.

Finding No. 5: Criminal History Records
Checks
Pursuant to the contract, Keefe Commissary Network
shall not offer employment to any individual or assign
any individual to work under the contract who has not
had a Florida Crime Information Center/National
Crime Information Center background (criminal
history records) check conducted. In order to carry
out the criminal history records check, upon request,
Keefe Commissary Network staff are required to
provide personal data (name, race, date of birth, social
security number, driver’s license number, etc.) and to
submit to fingerprinting. In addition, prior to any new
contractor staff being hired or assigned to work under
the contract, Keefe Commissary Network is to
provide the information needed to conduct a criminal
history records check.
Although Department records indicated that all of the
Keefe Commissary Network employees assigned to
Department canteens as of April 5, 2004, had been
subject to criminal history records checks, the dates
the checks were conducted were not documented.
Absent notation of the date the check was conducted,
the Department cannot demonstrate that the criminal
history checks of all assigned Keefe Commissary
Network employees were appropriately conducted
prior to those employees beginning work in the
canteens.
Recommendation:
To
demonstrate
that
criminal history records checks are conducted
prior to Keefe Commissary Network employees
beginning work in the canteens, Department staff
should note the date each records check was
conducted and maintain that information with the
results of the records check for each Keefe
Commissary Network employee assigned to the
contract.

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REPORT NO. 2005-044
¾ To review the controls over Keefe
Commissary Network’s access to and use of
the Inmate Bank System.

OBJECTIVES, SCOPE, AND METHODOLOGY
The objectives of our operational audit of the
Department and the outsourcing of canteen
operations were:
¾ To evaluate the effectiveness of established
internal controls in achieving management's
control objectives in the categories of
compliance
with
controlling
laws,
administrative rules, and other guidelines; the
economic, efficient, and effective operation of
State government; the validity and reliability
of records and reports; and the safeguarding
of assets.
¾ To evaluate management’s performance in
achieving compliance with controlling laws,
administrative rules, and other guidelines; the
economic, efficient, and effective operation of
State government; the validity and reliability
of records and reports; and the safeguarding
of assets.
¾ To determine whether the Department had
adequate documentation to justify the need
for or benefits of the outsourcing of canteen
operations and to determine whether the
contract was administered and services and
contractor payments were provided in
accordance with contract terms.

The scope of our audit included various aspects
related to the outsourcing of canteen operations,
including: projected revenues and cost savings, the
negotiation and contracting processes, contractor
responsibilities
and
contract
deliverables,
compensation, and monitoring. In conducting our
audit, we interviewed Department personnel, tested
selected Department records, and completed various
analyses and other procedures. Our audit included
examinations of various documents (as well as events
and conditions) applicable to the period July 2002
through February 2004 and selected actions taken
through July 25, 2004.
AUTHORITY
Pursuant to the provisions of Section 11.45, Florida
Statutes, I have directed that this report be prepared to
present the results of our operational audit.

William O. Monroe, CPA
Auditor General

¾ To evaluate the Department process for
monitoring compliance with the canteen
operations contract.
¾ To follow-up on audit reports Nos. 03-022
and 2004-050 and determine whether the
Department has timely completed appropriate
reconciliations of the Inmate Trust Fund;
disposed of any unidentified differences; and
timely assigned security profiles for Inmate
Bank users.

AUDITEE RESPONSE
In a response letter dated September 30, 2004, the
Secretary of the Department provided responses to
our findings and recommendations. This letter is
included in its entirety at the end of this report

To promote accountability in government and improvement in government operations, the Auditor General makes
operational audits of selected programs, activities, and functions of State agencies. This operational audit was made in
accordance with applicable Government Auditing Standards issued by the Comptroller General of the United States. This
audit was conducted by Stanley E. Mitchell, CPA, and supervised by Sherrill F. Norman, CPA. Please address inquiries
regarding this report to Dorothy R. Gilbert, CPA, Audit Manager, via E-mail (dorothygilbert@aud.state.fl.us) or by telephone
(850-488-5444).
This report and other audit reports prepared by the Auditor General can be obtained on our Web site
(http://www.state.fl.us/audgen); by telephone (850-487-9024); or by mail (G74 Claude Pepper Building, 111 West Madison
Street, Tallahassee, Florida 32399-1450).

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