Open Recommendations

Document a formal process to perform PIAs for proposed rules, including details on thetype of personally identifiable information collected and the number of people affected, inthe FCC Privacy Act Manual, as a requirement.

Update its business case for the MySBA investment in accordance with SOP 90 44 SBA Information Technology and Capital Planning and Investment Control Standard Operating Procedures.

Ensure the architecture review board reviews new investments to confirm compatibility with agency systems and ensure the Business Technology Investment Council approves new investments prior to purchase, as required by SOPs 90 52 1 and 90 44.

Ensure program offices create business cases prior to approval of the investment to ensure project scope, risks, and costs are fully vetted as required by SOP 90 44.

Update procedures to provide specific guidance to agency investment managers on how to utilize earned value principles to measure investment progress against both the current approved baseline and the original baseline for all major investments as required by SOP 90 52 1 and OMB Circular A-130.

Establish and implement controls to ensure all investments in the control phase are rated by the Chief Information Officer monthly using baseline factors, such as contractor cost oversight and schedule performance, and apply corrective measures as necessary as required by SOP 90 44.

Perform oversight procedures as required in OMB Circular A-11 and SOP 90 44. Specifically, ensure that post-implementation reviews, business case closeouts, TechStat sessions, operational analyses, and lessons learned are completed.

Rec. 1.a: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement), Deputy Assistant Secretary of the Navy (Procurement), Associate Deputy Assistant Secretary of the Air Force (Acquisition, Technology, and Logistics), and Defense Logistics Agency Acquisition Director require the contracting officers for the 35 open contracts identified in Appendix B to reevaluate the contractors' financial capability.

Rec. 1.a: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement), Deputy Assistant Secretary of the Navy (Procurement), Associate Deputy Assistant Secretary of the Air Force (Acquisition, Technology, and Logistics), and Defense Logistics Agency Acquisition Director require the contracting officers for the 35 open contracts identified in Appendix B to reevaluate the contractors' financial capability.

Rec. 1.b: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement), Deputy Assistant Secretary of the Navy (Procurement), Associate Deputy Assistant Secretary of the Air Force (Acquisition, Technology, and Logistics), and Defense Logistics Agency Acquisition Director require the contracting officers for the 35 open contracts identified in Appendix B to include sufficient documentation in the contract file to support the results of the reevaluation of financial responsibility.

Rec. 1.b: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement), Deputy Assistant Secretary of the Navy (Procurement), Associate Deputy Assistant Secretary of the Air Force (Acquisition, Technology, and Logistics), and Defense Logistics Agency Acquisition Director require the contracting officers for the 35 open contracts identified in Appendix B to include sufficient documentation in the contract file to support the results of the reevaluation of financial responsibility.

Rec. 1.b: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement), Deputy Assistant Secretary of the Navy (Procurement), Associate Deputy Assistant Secretary of the Air Force (Acquisition, Technology, and Logistics), and Defense Logistics Agency Acquisition Director require the contracting officers for the 35 open contracts identified in Appendix B to include sufficient documentation in the contract file to support the results of the reevaluation of financial responsibility.

Rec. 2.a.1: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director update and implement their Component policies to describe the types and extent of financial information required to document contracting officer financial responsibility determinations and to maintain the documentation in the contract file in accordance with the Defense Federal Acquisition Regulation Supplement 232.072-2.

Rec. 2.a.1: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director update and implement their Component policies to describe the types and extent of financial information required to document contracting officer financial responsibility determinations and to maintain the documentation in the contract file in accordance with the Defense Federal Acquisition Regulation Supplement 232.072-2.

Rec. 2.a.1: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director update and implement their Component policies to describe the types and extent of financial information required to document contracting officer financial responsibility determinations and to maintain the documentation in the contract file in accordance with the Defense Federal Acquisition Regulation Supplement 232.072-2.

Rec. 2.a.2: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director update and implement their Component policies to indicate that the Defense Contract Management Agency's Financial Capability Team is available to assist them in determining financial responsibility of prospective contractors.

Rec. 2.a.2: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director update and implement their Component policies to indicate that the Defense Contract Management Agency's Financial Capability Team is available to assist them in determining financial responsibility of prospective contractors.

Rec. 2.a.2: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director update and implement their Component policies to indicate that the Defense Contract Management Agency's Financial Capability Team is available to assist them in determining financial responsibility of prospective contractors.

Rec. 2.b: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director issue a memorandum to the DoD contracting officers to advise them of the policy updates made in response to Recommendation 2.a.

Rec. 2.b: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director issue a memorandum to the DoD contracting officers to advise them of the policy updates made in response to Recommendation 2.a.

Rec. 2.b: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director issue a memorandum to the DoD contracting officers to advise them of the policy updates made in response to Recommendation 2.a.

Define actions not permitted by application administrators to ensure separation of duties is adequate and implement technical controls, or determine other mechanisms, to prohibit application administrators from conducting those actions.

Ensure plans are in place for effective access controls during the expansion of CATS to uncleared personnel, or any other significant changes to the application, to help prevent account management weaknesses.

Prioritize efforts to implement automated account management to lessen the burden on administrators and ensure appropriate roles and access are granted.

Ensure that control assessment plans are developed and that they detail the scope of the assessment, including assessment procedures and specific roles and responsibilities of members on the assessment team.