Open Recommendations

We recommend that the Administration for Children and Families review and correct potential Antideficiency Act violations by deobligating and obligating funds to appropriate CLINs used and report an Antideficiency Act violation if the violation cannot be corrected.

We recommend that the Administration for Children and Families develop and implement policies and procedures:
o requiring contracts to include FAR clauses related to overtime requirements in contracts
o for tracking and verifying that all contractor staff (including subcontractors) assigned to work on a contract complete required trainings before performing any work under the contract (or within the allowed time).

We recommend the Assistant Secretary for Employment and Training enhance and implement written policies or procedures for post adjudication audits that target a representative number of applications appropriate for the level of risk in its application process.

We recommend the Assistant Secretary for Employment and Training enhance and implement written policies or procedures that provide specific guidelines to ensure analysts obtain sufficient evidence of payment of wages earned and expenses incurred.

We recommend the Assistant Secretary for Employment and Training enhance and implement written policies or procedures to ensure analysts provide a rationale and obtain sufficient evidence to document how they determine employers’ compliance with the program requirements reviewed.

We recommend that Indian Affairs develop and implement minimum standards for the operation of detention programs that are binding on both direct service and contract programs.

We recommend that Indian Affairs conduct risk-based Program Monitoring Reviews of all direct service and contract programs.

We recommend that Indian Affairs provide timely reporting in accordance with Office of Justice Services' guidelines to Tribes and BIA correctional staff regarding the results of Program Monitoring Reviews.

We recommend that Indian Affairs assess the level of resources needed to accomplish the oversight mission at direct service and contract programs.

We recommend that Indian Affairs establish and implement standards for consistency and thoroughness in data entry of serious incidents in the Incident Management, Analysis, and Reporting System and facility log records for direct service and contract programs.

We recommend that Indian Affairs provide training to staff and management at direct service and contract programs regarding serious incident reporting.

We recommend that Indian Affairs provide guidance to Corrections Program Specialists on performing and documenting serious incident report reconciliation to ensure that Incident Management, Analysis, and Reporting System data follows established standards for consistency and thoroughness.

We recommend that Indian Affairs establish oversight procedures to ensure direct service and contract program compliance with serious incident reporting standards and guidance.

We recommend that Indian Affairs develop and distribute a strategic recruiting plan that is updated periodically with the goal to fill staffing vacancies at detention facilities and alleviate effects of low detention staffing at direct service and contract programs.

We recommend that Indian Affairs develop and implement guidance, including a clear definition of overcrowding, to ensure consistent reporting of overcrowding incidents for direct service and contract programs. This guidance should consider appropriate industry standards and policies.

We recommend that Indian Affairs conduct a comprehensive analysis of direct service and contract detention programs to determine capacity limits.

We recommend that Indian Affairs develop and implement a plan to address overcrowding to the maximum extent possible for all direct service and contract programs.

We recommend that Indian Affairs establish oversight procedures to ensure review of occupancy levels and physical inmate counts for all direct service and contract programs.

We recommend that Indian Affairs develop and implement binding minimum standards for the maintenance of detention facilities that BIA directly maintains or are maintained by contract.

We recommend that Indian Affairs develop policy and procedures that require appropriate facility personnel at facilities that BIA directly maintains or are maintained by contract to have access to and record work orders in the Indian Affairs - Facility Management System.

We recommend that Indian Affairs require that all facilities that BIA directly maintains or are maintained by contract be inventoried in the Financial and Business Management System and the Indian Affairs - Facility Management System.

We recommend that Indian Affairs require that all deficiencies identified by facility managers, safety managers, and detention program personnel at facilities that BIA directly maintains or are maintained by contract be recorded in the Indian Affairs - Facility Management System as work orders.

We recommend that Indian Affairs coordinate with the Division of Facilities Management and Construction and BIA regions to continue exploring avenues to fill staffing vacancies and alleviate effects of low staffing.

We recommend that Indian Affairs establish oversight procedures to ensure review of facility and maintenance conditions at facilities that BIA directly maintains or are maintained by contract.

CMS should engage Medicare Administrative Contractors regarding opportunities and barriers to improving security measures for EFTs that were reported in response to OIG's survey.