Open Recommendations

We recommend USAID/ Philippines: Verify that Philippine Business for Education, Inc. corrects the one instance of material noncompliance detailed on pages 29 to 31 of the audit report.

Rec. A.1: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness review the religious accommodation request process for vaccinations to identify efficiencies that could be achieved during periods of high-volume requests and issue guidance accordingly to decrease processing times.

Rec. B.1: The DoD OIG recommended that the Director, Defense Health Agency, in coordination with the Secretaries of the Military Departments, develop and implement a requirement for personnel to maintain supporting documentation for medical exemptions in Service members' medical records and administrative exemptions in Service members' personnel records.

Rec. C.1: The DoD OIG recommended that the Under Secretary of Defense for Personnel and Readiness: a) develop and issue guidance to require uniform discharge types for all Service members discharged for misconduct solely for vaccination refusal; and b) develop and issue guidance to assign uniform reentry codes for all Service members discharged for misconduct solely for vaccination refusal.

Use the contract terms remaining in the contract to prompt Bechtel to meet the self-performance objective by encouraging and incentivizing more subcontracting.

Discuss the self-performance status with Bechtel, develop a mutual method of accurately calculating self-performance, and establish a plan to monitor the self-performance objective on a regular basis.

Evaluate the impact of contract time extensions on the self-performance percentage objective and its effect on the Subcontracting Plan goals, and adjust the contract (if appropriate).

Ensure Bechtel identifies all teaming arrangements, related entities, and affiliates needed to facilitate reviews for subcontractor unallowable fees on a regular basis.

Review Bechtel’s corrective actions for invoice review to validate implementation and effectiveness, and confirm that Bechtel has identified all unallowable fees that have been billed to the Department.

Evaluate the invoice review process for the depth and breadth required to make a complete and accurate review of the allowability, allocability, and reasonableness of invoice costs before payment.

Ensure that Bechtel follows its policies, procedures, and practices that allow subcontractors 30 or more days to respond to request for proposals unless a specific justification is documented.

Develop a policy or procedure to periodically evaluate whether the Department's practice of awarding terms that require payment in less than 30 days is in the best interest of the Government.

Ensure Bechtel identifies all teaming arrangements, related entities, and affiliates needed to facilitate reviews for subcontractor unallowable fees on a regular basis.

Evaluate the impact of contract time extensions on the self-performance percentage objective and its effect on the Subcontracting Plan goals, and adjust the contract (if appropriate);

Use the contract terms remaining in the contract to prompt Bechtel to meet the self-performance objective by encouraging and incentivizing more subcontracting;

Discuss the self-performance status with Bechtel, develop a mutual method of accurately calculating self-performance, and establish a plan to monitor the self-performance objective on a regular basis

Evaluate cyber risks associated with HEC assets to determine oversight and monitoring requirements, establish risk appetite, and address controldeficiencies. Consider using NASA’s Splunk enterprise platform as a shared resource.

Implement an HEC classification/category designation within Risk Information Security Compliance System for identifying HEC assets.

Document data risk impact levels, classification, and export control categorization for all HEC jobs.

Identify and mitigate gaps in the foreign national accreditation access process.

(U) Rec. 1.a: The DoD OIG recommended that the Commander of the U.S. Central Command develop minimum requirements for the U.S. Central Command End-Use Monitoring program manager's quarterly reviews of the Security Cooperation Information Portal to ensure the reviews include: * Reviewing enhanced end-use monitoring inventory and physical security inspection documentation. * Reviewing application of alternate procedures when in-person inventories and physical security inspections are not feasible. * Identifying and resolving deficiencies related to enhanced end-use monitoring.

(U) Rec. 1.b: The DoD OIG recommended that the Commander of the U.S. Central Command, in coordination with the Office of Security Cooperation-Iraq, develop a plan that could include using contractors to assist with the End-Use Monitoring program, filling the Office of Security Cooperation-Iraq End-Use Monitoring program manager position with a civilian, or expanding the authorities of the locally employed staff, to ensure continuity in the end-use monitoring program within the Office of Security Cooperation-Iraq.

(U) Rec. 1.c: The DoD OIG recommended that the Commander of the U.S. Central Command update Central Command Regulation 12-2 to include guidance on virtually inspecting security cooperation offices when in-person inspections are not feasible.

(U) Rec. 2.c: The DoD OIG recommended that the Chief of the Office of Security Cooperation-Iraq, in coordination with the U.S. Central Command, develop and implement a plan that could include using contractors to assist with the End-Use Monitoring program, filling the Office of Security Cooperation-Iraq End-Use Monitoring program manager position with a civilian, or expanding the authorities of the locally employed staff, to ensure continuity in the End-Use Monitoring program within the Office of Security Cooperation-Iraq.

We recommend the Vice President, Supply Chain, consider using early payment discount data as an evaluation tool for FIA performance and training needs.