Internal Controls Are Needed To Safeguard Inherently Governmental Functions at the Global Engagement Center

Submitting OIG:

Department of State OIG

Date Issued:

Thursday, February 24, 2022

Agency Reviewed / Investigated:

Department of State

Submitting OIG-Specific Report Number:

AUD-MERO-22-19

Component, if applicable:

Bureau of Public Affairs

Location(s):

Agency-Wide

Type of Report:

Other

Questioned Costs:

Funds for Better Use:

Number of Recommendations:

View Document:

Attachment	Size
AUD-MERO-22-19-Web-Posting508.pdf	1.84 MB

Recommendation Number	Recommendation Status	Significant Recommendation
2	Open	No
OIG recommends that the Global Engagement Center review all active cooperative agreements and grants to verify whether the award provisions comply with Office of Management and Budget Policy Letter 11-01 requirements regarding inherently Governmental functions and U.S. Federal employee decision-making authority over all programmatic aspects of the awards and, for those that do not, revise the award provisions to comply with those requirements.
3	Open	No
OIG recommends that the Global Engagement Center review the assigned roles, authorities, and responsibilities of its award management team members (Federal employees and third-party contractors) to determine (a) authorities and responsibilities that are inherently Governmental functions and (b) whether those authorities and responsibilities are assigned to or performed by team members who are not Federal employees or Personal Service Contractors, as appropriate.
4	Open	No
OIG recommends that the Global Engagement Center transfer to Federal employees or Personal Service Contractors, as appropriate, those authorities and responsibilities found to be inherently Governmental functions that are currently assigned to third-party contractors (as determined by the review in Recommendation 3).
5	Open	No
OIG recommends that the Global Engagement Center develop and implement a process to verify that inherently Governmental functions are only assigned to and performed by Federal employees or Personal Service Contractors, as appropriate.
7	Open	No
OIG recommends that the Global Engagement Center (GEC) develop and implement a process to formally notify GEC award management personnel and award recipients of all roles, authorities, and responsibilities that are inherently Governmental and are only to be assigned to and performed by Federal employees and Personal Services Contractors, as appropriate. The notification process should highlight all revisions to previous guidance and practice, beginning with the revisions to GEC’s Policies and Procedures Manual (Version 1.6, December 2020) following the implementation of Recommendations 1 through 6.
8	Open	No
OIG recommends that the Global Engagement Center design and implement controls, rather than relying only on the State Assistance Management System, to ensure that Grants Officers designate a Grants Officer Representative prior to awarding cooperative agreements or grants and throughout the award’s period of performance.
9	Open	No
OIG recommends that Global Engagement Center (GEC) Grants Officers implement controls to comply with GEC’s Policies and Procedures Manual (Version 1.6, December 2020), “Post-Award: Changes,” requirements to notify award recipients about changes to Grants Officer Representative (GOR) assignments and furnish award recipients with fully-executed copies of GOR designation memoranda.

Recommendation Number

Recommendation Status

Significant Recommendation

Additional Details

Open

OIG recommends that the Global Engagement Center review all active cooperative agreements and grants to verify whether the award provisions comply with Office of Management and Budget Policy Letter 11-01 requirements regarding inherently Governmental functions and U.S. Federal employee decision-making authority over all programmatic aspects of the awards and, for those that do not, revise the award provisions to comply with those requirements.

Open

OIG recommends that the Global Engagement Center review the assigned roles, authorities, and responsibilities of its award management team members (Federal employees and third-party contractors) to determine (a) authorities and responsibilities that are inherently Governmental functions and (b) whether those authorities and responsibilities are assigned to or performed by team members who are not Federal employees or Personal Service Contractors, as appropriate.

Open

OIG recommends that the Global Engagement Center transfer to Federal employees or Personal Service Contractors, as appropriate, those authorities and responsibilities found to be inherently Governmental functions that are currently assigned to third-party contractors (as determined by the review in Recommendation 3).

Open

OIG recommends that the Global Engagement Center develop and implement a process to verify that inherently Governmental functions are only assigned to and performed by Federal employees or Personal Service Contractors, as appropriate.