Open Recommendations

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop and implement procedures to collect indirect cost data from implementers in a systematic manner that will allow it to comprehensively report and analyze the indirect costing methodology and rates for implementers. This information should include indirect cost rate agreement type (e.g., cognizant agency-negotiated indirect cost rate or de minimis agreements).

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop written internal control policies, procedures, or guidance specific to USAID's Overhead, Special Cost, and Closeout Branch indirect cost processes to clarify minimal documentation retention rules during every phase of the indirect cost process, notably first time, subsequent, and final negotiations.

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Develop checklists to verify completion of for-profit organizations files similar to the checklist used for non-profit organizations.

To address the weaknesses identified in the report, the firm recommend that USAID's Acting Director, Office of Acquisition & Assistance:
Consider implementation of a centralized document control methodology and tracking mechanism to improve internal document control practices.

Update the EAC Procurement Handbook to reflect current requirements in the Federal Acquisition Regulation.

Complete contractor performance evaluations for all nonexpired internal contracts.

Record the required procurement information for all nonexpired internal contracts in the Federal Procurement Data System.

Implement a process to ensure timely and accurate reporting of contractual obligations to the Federal Procurement Data System.

Evaluate and adjust, where appropriate, the monitoring process for mail handling to better identify non-compliant offices that require remediation.

Some or all of the recommendation is not publicly available due to concerns with information protected under the Freedom of Information Act.

Some or all of the recommendation is not publicly available due to concerns with information protected under the Freedom of Information Act.

Some or all of the recommendation is not publicly available due to concerns with information protected under the Freedom of Information Act.

Some or all of the recommendation is not publicly available due to concerns with information protected under the Freedom of Information Act.

Some or all of the recommendation is not publicly available due to concerns with information protected under the Freedom of Information Act.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the PuertoRico DOE to reallocate the $2.5 million in unallowable indirect costs charged to the Restart program grant.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Puerto Rico DOE to ensure that a purchasing officer assesses whether equipment purchases should be capitalized using the requirements established in 2 C.F.R. 200.1, the Department’s indirect costs agreements, and Regulation 11 “Basic Rules for the Control and Accounting of Fixed Assets,” (December 2005)

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Puerto Rico DOE to complete its process of identifying schools in need of technology equipment and redistribute the 215 technology equipment devices as appropriate

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Puerto Rico DOE to work with school staff and teachers to find the 21 technology equipment devices that are missing and follow the procedures in the Mobile Devices Management Guide to report the missing equipment to the police, if necessary.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Puerto Rico DOE to review and update written policies and procedures for the management of fixed assets and mobile equipment devices to ensure that educational regional offices and schools properly manage surplus technology equipment.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Puerto Rico DOE to perform a comprehensive physical inventory of technology equipment devices purchased with Restart program funds and ensure that the devices are being used, appropriate guidance as updated per Recommendation 2.3 is followed to manage any surplus and missing equipment, and the technology equipment inventory system and pertinent inventory records are updated accordingly.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Puerto Rico DOE to determine the total amount of payroll payments incorrectly made using Restart program funds and reallocate any unallowable amount to the Restart program grant.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Puerto Rico DOE to ensure that staff maintain and manage documents supporting activities funded with Federal education program grants so that records are readily available when needed.

OIG recommends that the Bureau of Overseas Buildings Operations, in coordination with the Bureau of Administration, develop, implement, and communicate a process to ensure that Project Directors for construction projects prepare independent government cost estimates that consider the impact that the modification will have on the overall schedule of the project to determine if extensions are justified. At a minimum, the process should include clarification of individual responsibilities and accountability.

OIG recommends that the Bureau of Overseas Buildings Operations (OBO) develop, implement, and communicate a process to ensure a separation of duties between OBO staff who receive the price proposal for a request for equitable adjustment related to a construction project and OBO staff who develop the independent government cost estimate for the construction project. At a minimum, the process should include clarification of individual responsibilities and accountability.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, develop, implement, and communicate a process to ensure that Contracting Officers prepare prenegotiation objectives for modifications to construction projects of more than $25,000 and that Project Directors do not revise independent government cost estimates during or after negotiations in accordance with the Federal Acquisition Regulation and Department of State policy. At a minimum, the process should include guidance on documenting fair and reasonable pricing and any schedule extensions for the modification and a clarification of individual responsibilities and accountability.