Open Recommendations

We recommend BHA assess BHA's third-party monitor contracting processes and timelines, determine if adjustments are necessary to strengthen BHA's acquisition of third-party monitor support, and update BHA guidance accordingly.

We recommend BHA establish a mechanism to enforce BHA's use of internal guidance for Response Team Staffing to develop a DART staffing strategy for disaster responses.

We recommend BHA update BHA award language to clarify (1) the relationship with incident reporting requirements in USAID standard provisions and (2) ambiguous terminology related to reporting timeliness and incident impact.

We recommend BHA develop and implement a framework to address implementer noncompliance with BHA incident reporting requirements that defines response options and identifies triggers for escalation.

We recommend BHA develop and implement a process to ensure the storage and transfer of incident documentation between team files, Abacus, and ASIST, in accordance with BHA guidance.

Revise their policies and procedures to improve internal controls in place over maintenance of accounting records to ensure costs incurred for Federal awards are accurately recorded and supported by documentation prior to reporting financial information.

Work with ARC to resolve the questioned cost totaling $15,510 for A&E fees claimed as non-ARC matching cost.

Revise policies and procedures to ensure expenditures incurred and reported align with the approved scope of work and budget of the grant project.

Work with ARC to resolve the total questioned costs in the amount of $58,666 of non-ARC matching construction cost.

Implement policies and procedures to ensure that property records accurately reflect all required data elements included in the Uniform Guidance.

We recommend the Assistant Secretary for Employment and Training enhance and implement written policies or procedures to ensure H-2A applications have the correct wage information when certified by analysts.

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.