Open Recommendations

Evaluate the effectiveness of control activities specifically for authorization rate outliers and determine whether new or stronger controls are needed.

Establish procedures to track all non-cash and cash equivalent non-tangible items purchased with the expense purchase card and record applicable information in the eAwards system.

Conduct periodic reviews of 1) expense purchase card transactions for compliance with policy and 2) non-cash and cash equivalent items to ensure they are entered into eAwards timely.

Designate a senior executive to lead the effort to receive a clean audit opinion by granting agencywide authority to issue directives, monitor compliance, and enforce remediation priorities across all program offices.

Leverage best practices to implement a plan for using consistent, frequent communication to ensure all agency personnel are made aware of the agencywide commitment to obtain an unmodified audit opinion.

Integrate the agencywide goal of remediating the financial statements into SBA’s strategic plan and set specific, measurable targets in the agency’s annual performance plan.

Implement a process to conduct data-driven reviews regularly using defined audit remediation goals to align program leaders’ personal performance plans with outcome-based remediation goals to hold leaders accountable for improving program data quality, in accordance with OMB Circular A-11, Part 6.

We recommend that the Assistant Secretary for Elementary and Secondary Education require CSDE to amend Connecticut’s State plan by updating its procedures for identifying schools for CSI to ensure that they align with the procedures in CSDE’s Accountability Guide and definition of a school identified for CSI in the ESEA.

We recommend that the Assistant Secretary for Elementary and Secondary Education require CSDE to provide CSI to the five Title I public schools that should have been identified for CSI in the fall of 2022.

We recommend that the Assistant Secretary for Elementary and Secondary Education verify that CSDE implemented corrective actions to fix the system coding error to ensure that it correctly identifies student subgroups needing ATSI in the future.

We recommend that the Assistant Secretary for Elementary and Secondary Education verify that WVDE correctly applied the minimum number of students per subgroup restriction when it identifies schools for ATSI in the fall of 2025.

We recommend that the Assistant Secretary for Elementary and Secondary Education verify that WVDE does not consider the 12 schools that it incorrectly identified for ATSI for CSI-ATS identification in the fall of 2025.

We recommend that the Assistant Secretary for Elementary and Secondary Education require WVDE to keep all records showing that it is providing all planning and collaboration, diagnostic and monitoring activities, and technical assistance to LEAs with schools identified as needing CSI or CSI-ATS, as described in West Virginia’s approved State plan, WVDE’s written plans for CSI and CSI-ATS schools, or both.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to return the more than $20 million that was used for ARP EANS-funded services and assistance for ineligible nonpublic schools or take other remedial actions as appropriate, such as making accounting adjustments to other valid and allowable obligations incurred during the ARP EANS period of availability.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to provide documentation showing that the $838,829 in CRRSA and ARP EANS funds that were recovered from the ineligible nonpublic school were returned to the Department.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to obtain supporting documentation that all nonpublic schools that received EANS-funded services and assistance have a nonprofit status.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to return the $21,312 in CRRSA EANS funds that were expended improperly for services and assistance for a nonpublic school.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to require the contractor to provide sufficient support for the $297,477 of unsupported CRRSA and ARP EANS-funded expenditures or return funds to the Department.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to conduct a full review of the contractor’s vendor service fees to determine reasonableness. Return EANS funds for any vendor service fees deemed to be unreasonable.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to ensure that assets purchased with EANS funds are tracked in accordance with Federal requirements.

FHFA's DBR Deputy Director should ensure that ORAM evaluates its current internal model risk management practices in line with FHFA’s model risk management supervisory expectations (defined in AB 2013-07 and AB 2022-03) and design controls to (1) periodically review and maintain its model risk inventory (to include a risk-based validation schedule), (2) engage external resources to perform independent model validations in accordance with the validation schedule, and (3) conduct model performance tracking. Further, ORAM should update and finalize its policies and procedures to reflect the internal model risk management practices adopted.

FHFA's DBR Deputy Director should ensure that ORAM evaluates its current practices for maintaining documentation of the review and approval of inputs and outputs and implements policies and procedures to communicate requirements for maintaining this documentation.

FHFA's DBR Deputy Director should ensure that ORAM evaluates its current tracking mechanism for FHLBank requests for approval of market risk model changes and implement policies and procedures to ensure that the date that a complete model change approval request is received is tracked.

Rec 1.a: The DoD recommended that the Under Secretary of Defense for Research and Engineering develop or revise their existing procedures to require that implementation plans be developed based on industry best practices and include, at a minimum, timelines with specific milestones, roles and responsibilities, and metrics for evaluating and monitoring progress.

Rec 1.b: The DoD recommended that include in the procedures developed in accordance with Recommendation 1.a, a requirement to review and update implementation plans, at a minimum of once each year.