Open Recommendations

We recommend the Assistant Secretary for Employment and Training collaborate with SBA to conduct a joint study to assess and identify the UI claim data elements that should be shared for data matching with disaster program data elements for the purpose of detecting potentially fraudulent activities under both the UI and SBA disaster assistance programs.

Ensure West Virginia JCS develops policies and procedures to ensure compliance with victim assistance priority areas funding requirements.

Ensure West Virginia JCS: (1) updates its VOCA Administrative Manual with applicable VOCA Fix and federal award requirements, and (2) periodically reviews and makes necessary updates to the document to ensure compliance with federal statutes, regulations, and the award terms and conditions.

Work with West Virginia JCS to establish a monitoring mechanism that will ensure that it adheres to the frequency of on-site monitoring visits, as required by its policies.

Coordinate with West Virginia JCS to establish procedures, such as staff instructions and control mechanisms, to: (1) maintain a comprehensive schedule of monitoring activities, (2) ensure monitoring actions effectively assess subrecipients' implementation of VOCA-funded programs, (3) develop and provide to subrecipients reports of monitoring activities complete with required signatures in accordance with West Virginia JCS policies, and (4) pursue and close out monitoring report findings and recommendations.

Remedy $198,099 in unsupported subaward expenditures.

Require West Virginia JCS to establish adequate controls to ensure its monitoring staff performs monthly financial reviews in compliance with the West Virginia JCS policies and that it maintains evidence to support all claimed subrecipient expenditures reviewed as part of monitoring activities.

Work with West Virginia JCS to develop and implement written policies and procedures to ensure compliance with the Uniform Guidance requirements for pass-through agency action on subrecipient single audit reports.

Ensure West Virginia JCS updates its policies and procedures to implement a process to collect, verify, and maintain monthly progress reports and their respective support.

Ensure West Virginia JCS updates its policies and procedures to implement a process to collect, verify, maintain, and provide accurate data to the OVC that measures the performance and effectiveness of activities funded by the VOCA awards.

Require West Virginia JCS to: (1) reconcile and correct its SARs and its subaward list for the audited grants to ensure OVC has accurate information for those previously awarded VOCA subawards, and (2) implement procedures to ensure that West Virginia JCS' subaward list and SARs are accurate and submitted timely as well as periodically reviewed to make necessary updates.

Remedy $24,464 in unallowable questioned costs related to excess administrative expenditures beyond the 5-percent allowance charged to the 2018 award.

Require West Virginia JCS to develop and implement written policies and procedures to ensure compliance with the 5-percent administrative expenditure limit.

Remedy $16,168 in unsupported questioned costs related to non-personnel administrative costs.

Require West Virginia JCS to enhance its written drawdown policies and procedures to include: (1) an adequate system of internal controls over the disbursement of VOCA funds to ensure funds are only provided to subrecipients for allowable costs that were incurred, and (2) supervisory review (or another control) of the reconciliation process used to calculate drawdown amounts to ensure West Virginia JCS does not request funds in excess of its needs.

Remedy $196,776 in unallowable questioned costs related to excess drawdowns for the 2018 award.

Require West Virginia JCS to train its financial staff on the DOJ Grants Financial Guide FFR requirements and the instructions within the West Virginia JCS' Accounting Policies and Procedures.

Coordinate with West Virginia JCS to ensure FFRs are accurate and supported by accounting records going forward.

IHS should assess the relative benefits of its current recruitment and retention strategies to guide future staffing plans, as well as exploring new tools to address staffing shortfalls.

IHS should explore options for expanding housing for DSFC staff.

We recommend that the DOI Secretary or designee establish a risk appetite as required in the Office of Management and Budget Circular No. A-123 and implement a process to ensure Departmentwide awareness of the risk appetite.

We recommend that the DOI Deputy Secretary or designee implement a process to periodically reevaluate and adjust risk appetite and tolerance levels to meet DOI's needs in accordance with the Office of Management and Budget Circular No. A-123.

We recommend that the DOI Deputy Secretary or designee create a comprehensive risk profile as required by the Office of Management and Budget Circular No. A-123 and ensure it is properly approved and incorporated into discussions for decision making.

We recommend that the DOI Deputy Secretary or designee establish a risk management council or an equivalent governance system to direct and oversee the establishment of DOI's risk profiles, regularly assess risk, develop appropriate risk responses, and approve the updated risk profile annually.

We recommend that the DOI Deputy Secretary or designee define the enterprise risk management roles and responsibilities for DOI's leadership at the executive, bureau, and office level and ensure those roles and responsibilities are clearly communicated.