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

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Date Issued

Thursday, February 24, 2022

Submitting OIG

Department of State OIG

Other Participating OIGs

Department of State OIG

Agencies Reviewed/Investigated

Department of State

Components

Bureau of Public Affairs

Report Number

AUD-MERO-22-19

Report Type

Other

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Open Recommendations

This report has 7 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
2	No	$0	$0
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	No	$0	$0
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	No	$0	$0
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	No	$0	$0
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	No	$0	$0
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	No	$0	$0
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	No	$0	$0
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.