Open Recommendations

The Commissioner, Wage and Investment Division, should develop processes and procedures to ensure that continuous criminal background checks are conducted on all program participants as part of the FBI RAP Back Program. These processes and procedures should include steps to evaluate continued participation in IRS programs for individuals identified with a criminal history.

Strengthen coordination between Accounting and Financial Management Services and the Office of Budget to ensure that transactions are recorded accurately and timely. (modified repeat)

Tracking the sequence of SVs/JVs for completeness;

Appropriate use of SVs/JVs;

Determining and maintaining relevant documentation to support each SV/JV;

Use of specific and accurate SV/JV descriptions; and

Timely review and approval of SVs/JVs for accuracy and propriety. (modified repeat)

Complete the Trust Accounting Handbook to clearly reflect the assumptions used in the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator, including establishing control activities; finalize materiality thresholds applied; update accounting transactions, and clearly identify periods when adjustments will be made regardless of materiality. (new)

Develop for a more standardized, secure, and automated method to estimate the Trust obligations and Trust Service Award Liability that ensures minimal human errors. As part of the ongoing CNCS’s transition to shared service, coordinate with the service provider to determine methods that would enhance the security and quality of the existing estimation models. (new)

Strengthen controls to ensure the Trust modeling is performed by trained personnel to:

Conduct detailed analysis and validation of data sources.

Review and ensure the reasonableness of assumptions used and document the rationale behind estimation assumptions.

Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

Document and implement policies and procedures to include the following:

Establish a thorough and robust quality control process to ensure that the Trust Obligation and Liability Model (TOLM) and Monthly Obligation and Liability Calculator (Calculator) are reviewed by qualified CNCS personnel prior to relying on its outputs to record transactions. All errors identified for which management ultimately decided against making updates to the TOLM or Calculator should be documented along with an explanation as to how management arrived at the final decision;

Perform monthly reviews and reconciliations of the recorded new and outstanding obligations to ensure the accounting information is valid and proper;

Review obligation amounts to ensure amounts accurately reflect the status of the obligation;

Review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation);

Ensure obligations are sufficiently supported (i.e., by documentary evidence); and

Perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved. (repeat)

Coordinate with the Office of the Chief Risk Officer (OCRO) to properly identify the National Service Trust Fund’s financial reporting risks and incorporate those risks into the OCRO’s annual testing of key controls. (modified repeat)

Develop a succession plan to ensure the required expertise is available in anticipation of planned employee turnover, particularly with respect to the complex trust calculations. CNCS needs to:

Train, mentor, and work to retain qualified employees;