Open Recommendations

As expeditiously as possible, Treasury's Office of the Assistant General Counsel for General Law, Ethics and Regulation (GLER) should develop and implement standard operating procedures, including monitoring, to ensure ethics officials fully utilize the Ethics Tracker database to track requests, substantive advice and counsel provided, as well as documentation of final resolution of issues.

As expeditiously as possible, Treasury's Office of the Assistant General Counsel for General Law, Ethics and Regulation (GLER) should consider completing a cost-benefit analysis to determine if a fully integrated and automated tracking system would benefit GLER with its ethics responsibilities.

Ensure that the OHC conducts a comprehensive annual review of the control activities for administering the agency’s vision and dental programs to ensure that they are operating effectively.

Develop and periodically provide tailored training for employees who administer the agency’s vision and dental programs.

Coordinate with the Ohio AG to reexamine the Ohio AG's funding strategy, to include periodically conducting updated needs assessments and establishing an underserved population category definition.

Coordinate with the Ohio AG to ensure that the Ohio AG properly executes financial and programmatic monitoring of its subrecipients in compliance with Ohio AG policies and forms, to include that supporting documentation of each monitoring activity is collected, reviewed, and maintained.

Coordinate with the Ohio AG on the appropriate and reasonable submission of Subgrant Award Reports (SAR) for its previously awarded VOCA subgrants.

Require the Ohio AG to update its written policy to cover current matching cost requirements and match waiver procedures, including expectations for the reporting of matching costs when match waivers have been issued.

Coordinate with the Ohio AG to consider whether a formal, more inclusive solicitation strategy needs to be developed based upon the results of the Ohio AG's reexamination of its funding strategy in Recommendation Number 1.

Ensure the Ohio AG's subaward packages include all current, required grant information.

Ensure the Ohio AG revises its subrecipient monitoring policy to help ensure appropriate monitoring activities are conducted in compliance with federal requirements and that all relevant personnel are aware of this policy. In particular, the subrecipient monitoring policy should cover, at a minimum: (1) the programmatic monitoring of subrecipients; (2) subrecipient compliance with award special conditions; (3) risk assessment criteria and timeliness; (4) subrecipient single audit review, including issuing management decisions and appropriate corrective actions when necessary; and (5) documentation to support that subrecipient performance data is complete and accurate.

Require the Ohio AG to bring into alignment its subrecipient risk assessment policy and the tool designed to assess subrecipient risk.

Ensure the Ohio AG revises its financial policies and procedures to help ensure adequate administration of federal award funds and that all relevant personnel are aware of these policies. In particular, the financial policies and procedures should cover, at a minimum: (1) completing appropriate Subgrant Award Report (SAR) submissions; (2) drawdown-related reconciliation procedures, which ensure that funds are spent or returned to DOJ within 10 days of being drawn down; and (3) matching cost reporting on Federal Financial Reports (FFR) to help ensure the information reported is reconciled to supporting data, reviewed by appropriate personnel, and that data supporting the…

Ensure the Ohio AG develops a mechanism to complete subrecipient monitoring timely and in accordance with its policy.

Require the Ohio AG to develop a plan to conduct a site visit and/or desk review of those subrecipients that did not receive a review in the past 24 months, as required, with priority given to those subrecipients that did not receive a site visit and/or desk review within our audit scope.

Remedy the $68,674 in unsupported subrecipient personnel expenditures.

Coordinate with the Arizona DPS to enhance its grant administration policies and procedures to ensure that regular desk reviews and on-site monitoring of subawards is conducted for all subrecipients in accordance with the VOCA Guidelines and establish a plan to perform on-site monitoring for those subawards that have not received an on-site monitoring visit within the last 2 years.

We recommend that USAID's Office of Acquisition and Assistance, Cost, Audit and Support Division verify that Accin Contra el Hambre corrects the instances of material noncompliance, detailed on pages III-2 and III-3 of the report.

Evaluate and consider enhanced solutions to store backup data, as described inthe report, and update the Storage Systems Backup Data Protection StandardOperating Procedures, as appropriate.

Conduct an analysis to identify viable alternatives for testing restoration of ActiveDirectory from backups, or have senior management formally accept the risk ofnot testing these backups.

(U) Rec. A.1.b: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness update and implement retained organ policy to align with current policy and practice related to retained organs and specimens.

(U) Rec. A.1.c: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness continue to honor, to the extent practicable and consistent with section 1471, title 10, United States Code and current policy, proactive and timely requests from next of kin for religious accommodations related to forensic pathology investigations and disposition of remains. This includes updating and implementing the policy that retained organs and specimens are to be treated in the same manner as remains, when honoring religious accommodation.

(U) Rec. A.2: The DoD OIG recommended that the Director, Defense Health Agency, after the Under Secretary of Defense for Personnel and Readiness updates and implements policy, develop and implement Armed Forces Medical Examiner System policy, processes, and procedures related to retained organs or specimens.

(U) Rec. B.1.b: The DoD OIG recommended that the Director, Defense Health Agency consider the impact of separate disposition for organs because different specialty consultations were needed, versus disposition of decedent's retained organs together, and develop and implement policy and procedures accordingly.

(U) Rec. B.1.d: The DoD OIG recommended that the Director, Defense Health Agency update and implement system capabilities to allow Armed Forces Medical Examiner System officials to effectively and efficiently track the progression of retained organ (specimens) from collection through disposition.