Federal Reports

During our unannounced inspection of Pulaski County Jail, we identified violations of U.S. Immigration and Customs Enforcement (ICE) detention standards that threatened the health, safety, and rights of detainees. In addressing COVID-19, Pulaski did not consistently enforce precautions including use of facial coverings and social distancing, which may have contributed to repeated COVID-19 transmissions at the facility. Pulaski did not meet standards for classification, medical care, segregation, or detainee communication. We found that the facility was not providing a color-coded visual identification system based on the criminal history of detainees, causing inadvertent comingling of a detainee with significant criminal history with detainees who had no criminal history. The facility generally provided sufficient medical care, but did not provide emergency dental services and the medical unit did not have procedures in place for chronic care follow-up. We also found that the facility was not consistently providing required oversight for detainees in segregation by conducting routine wellness checks. Finally, we found deficiencies in staff communication practices with detainees. Specifically, ICE did not specify times for staff to visit detainees and could not provide documentation that it completed facility visits with detainees during the pandemic. We did find that Pulaski generally complied with the ICE detention standard for grievances. We made five recommendations to ICE’s Executive Associate Director of Enforcement and Removal Operations (ERO) to ensure the Chicago ERO Field Office overseeing Pulaski addresses identified issues and ensures facility compliance with relevant detention standards. ICE concurred with all five recommendations.

For our audit of NIST’s Working Capital Fund for fiscal year ended September 30, 2019, our objective was to determine whether budgetary controls over the fund were adequate. Specifically, the audit focused on determining whether the fund was (1) recovering the full cost of reimbursable services; (2) appropriately accounting for advances and carryover balances; and (3) maintaining a reasonable fund balance, in accordance with applicable laws, regulations, and policies.We contracted with Ollie Green & Company, CPAs, LLC, LLC (OG&C)—an independent firm—to perform this audit of NIST in accordance with Government Auditing Standards. Our office oversaw the progress of this audit; however, OG&C is solely responsible for the attached report and the conclusions expressed in it. We do not express any conclusions about the adequacy of the fund’s budgetary controls, including its recovery of the full cost of reimbursable services, accounting for advances and carryover balances, and reasonableness of the fund balance in accordance with applicable laws, regulations, and policies.

What OIG Evaluated: 

The objectives of this audit were to evaluate 1) the adequacy of the Library’s grants operations policies and procedures, 2) the Contracts and Grants Directorate and the Program Office’s compliance with those procedures, and 3) the grantees’ compliance with those procedures.

What OIG Found: 

- The Library Could Improve Its Procedures for Performing Financial Monitoring of Grantees
- The Library Could Improve Its Procedures for Performing Financial Reviews of Proposed Grant Costs
- The Library Should Consider Limiting Extensions to a Grants Period of Performance
- The Library Did Not Follow Its Procedures for the Closeout and Award of Grants

What OIG Recommends: 
- Conduct training for Contracts and Grants Directorate on how to obtain and review grantees’ Single Audit  reports. The training should also include the process for Identify Fiscal  Yearly internal control deficiencies, performing follow-up activities, and reviewing SEFA expenditures. In addition, the training should define audit terminology. 
- Require grantees to provide grant expenditure reports that detail the grantee’s expenditures at the cost code and transaction level at least on an annual basis. These reports should come directly from the grantees accounting system. Also, require the grantee to reconcile these expenditures to the expenditures it  reported by budget category in the Budget Summary Reports that it submitted to the Library. Ensure that the grantee researches and resolves any differences.
- Require that any grantees that are not subject to A-133 undergo an independent audit. 
- Include the following steps in its  grantee risk assessment procedures: (1) If a Single Audit  report is available for the grantee, review the report for any internal control or compliance findings that could affect the grantee’s performance under a Library award. Determine whether the grantee has taken any corrective actions to address the Audit  findings. (2) Reconcile the expenditures that the grantee reported in its  FFR, Budget Summary Report, and drawdowns or advances to the expenditures that the grantee may have reported in its  SEFA or Audit  report. Research and resolve any discrepancies. (3) Reconcile the grant expenditure reports that detail the grantee’s expenditures at the cost code and transaction level to the expenditures  reported by budget category in the Budget Summary Reports that it  submitted to the Library. Research and resolve any differences. (4) Review the transactions in the grantee’s expenditure reports and request explanations for any large transactions, transactions that do not appear to be allowable or allocable to the grant, and unusual journal entries.
- Implement writ ten procedures for performing and documenting its  financial reviews of costs included in grantees’ original proposals and proposal amendments. Writ ten procedures could include verification that (1) Labor costs are supported by payroll records (2)Proposed fringe benefit  cost rates are supported by grantee records. (3) Subgrantee and consultant costs are based on existing proposals and commitments to perform work under the grant. (4) Travel costs are reasonable. (5) The grantee applied its  indirect cost rates to the correct allocation base. (6) Other direct costs are supported by vendor quotes. (7)The grantee’s Single Audit  reports do not include internal control or compliance weaknesses that could affect the grantee’s performance. (8) For nonpublic entities, Audit  reports are available to support that the organization is solvent and is able to perform under the award.
- Consider limiting the number of times that it can extend a grant’s period of performance.
- Consider updating its guidelines and procedures to include policies for the novation or transfer of a grant to a new organization, and consulting with the Library’s Office of General Counsel.