Open Recommendations

We recommend the FEMA Assistant Administrator for Recovery strengthen FEMA's transportation assistance policies and procedures and coordinate with FEMA Assistant Administrator for Mission Support to: a) require the collection and retention of eligibility documentation or where applicable, document the steps taken to validate applicant statements in FEMA's system of record, and b) ensure future information technology updates support the collection, use, and retention of unique Vehicle Identification Numbers to enable FEMA to cross-reference national databases to confirm insurance coverage and identify applicants' second vehicles.

We recommend the FEMA Assistant Administrator for Recovery, in accordance with the Stafford and Improper Payments Acts; develop controls to identify payments not used for critical transportation needs.

Comply with DOT Order 1200.9's financial completion and IAA closeout process requirements for the IAAs identified in table 3 of this report, and determine whether to close them and deobligate the appropriate portions of the $5,966,933 we identified. Implementing this recommendation across the 854 IAAs in our audit universe could potentially put up to $33.3 million in funds to better use.

We recommend that the Office of Administration/Division of Acquisition Management update Administrative Circular OA-14 and implement the necessary updates to align procurement procedures with current federal acquisition regulation and agency practices.

We recommend that the Office of Administration/Division of Acquisition Management update standard policies and procedures to clearly convey the documentation required to be maintained in the contract file in order to support the solicitation phase.

We recommend that the Office of Administration/Division of Acquisition Management develop and implement standard checklist guidance to be included in the contract file that lists the required solicitation documentation, identifies if the documentation was applicable to the solicitation, and indicates the section in which the supporting documents are located.

We recommend that the Office of Administration/Division of Acquisition Management update standard policies and procedures to clearly convey the documentation required to be maintained in the contract file in order to support the award and administration phase.

We recommend that the Office of Administration/Division of Acquisition Management develop and implement standard checklist guidance to be included in the contract file that lists the required award and administration documentation, identifies if the documentation was applicable to the award, and indicates the section in which the supporting documents are located.

We recommend that the Office of Administration/Division of Acquisition Management obtain the signed copies of the contracting officer’s representative designation letter for the identified contracts and include them in the contract files.

We recommend that the Office of Administration/Division of Acquisition Management include obtaining the signed contracting officer’s representative designation letter as part of standard checklist guidance to be included in the contract file listing required award and administration documentation, identifying if the documentation was applicable to the award, and indicating the section in which supporting documents are located.

We recommend that the Office of Administration/Division of Acquisition Management establish a checklist or other control process to ensure that the required conflict of interest statement is presented to vendors.

We recommend that the Office of Administration/Division of Acquisition Management establish standard procedures for identifying and tracking contracts that have been physically completed.

We recommend that the Office of Administration/Division of Acquisition Management take steps to ensure the remaining balances are de-obligated in Financial Management Integrated System in a timely manner.

We recommend that the Office of Administration/Division of Acquisition Management review the established control process used to transmit information to the Federal Procurement Data System and update the process in order to report information more accurately.

We recommend that the Office of Administration/Division of Acquisition Management revise the information previously reported in the Federal Procurement Data System to reflect the correct contract numbers and amounts.

We recommended that the Office of Programs in coordination with the RRB Executive Committee establish a permanent entity within RRB responsible for continuously assessing fraud risk, implementing corrective actions, and monitoring the effectiveness of those actions as they relate to the Railroad Retirement Board disability programs. There are two existing entities, the Fraud Prevention Task Force and the Internal Controls Assessment Team that could be considered for this designation.

We recommended that the Office of Programs in coordination with the Railroad Retirement Board Executive Committee establish an on-going fraud risk assessment process that regularly gathers information about disability programs fraud risk, assesses the potential likelihood and impact, determines fraud risk tolerance, examines the suitability of existing fraud and documents the fraud risk profile specifically for the disability programs.

We recommended that the Office of Programs in coordination with the Railroad Retirement Board Executive Committee conduct risk-based monitoring tied to the fraud risk profile of the disability programs to evaluate the effectiveness of preventive activities and use the results to improve the design and implementation of fraud risk management activities within the disability programs.

We recommended that the Office of Programs/Disability Benefits Division define definitive fraud risks within the disability programs based on a comprehensive fraud risk assessment.

We recommended that the Office of Programs/Disability Benefits Division use the fraud risks identified to establish a scoring or other process for determining those applications where a higher risk of fraud or abuse occurring exists.

We recommended that the Office of Programs/Disability Benefits Division establish additional supervisory review and documentation protocols to ensure that decisions for higher risk applications are sufficiently reviewed and consistently documented to reflect the basis for the decision.

We recommended that the Office of Programs establish procedures specifying how differences in medical assessments between medical experts, including the disability claims examiner, should be documented and reviewed to ensure the basis for the final decision is clearly evident in the disability case file.