Open Recommendations

KPMG recommends that ESC enhance the design of the CTA control procedures to ensure that all information used in the reconciliations are complete and accurate, including adequate consideration of transactions that may impact period-end financial reporting.

KPMG recommends that ESC document in its Standard Operating Procedure and communicate clearly defined objectives and requirements related to compliance with the Treasury requirement to reconcile all pertinent activity at the BETC level.

KPMG recommends that ESC perform a review of the population of journal entries prior to the finalization of quarterly financials to ensure the complete population of journal entries was subject to the approval control during the period.

KPMG recommends that ESC perform a review of the population of journal entries prior to the finalization of quarterly financials to ensure all journal entries were recorded.

KPMG recommends that OST establish (or revise), communicate, and enforce an internal timeline, inclusive of a deadline(s) for when Operating Administrations need to provide their respective information to OST-B30 and the General Counsel office, that allows for sufficient time to gather, review, and draft the consolidated Legal Letter and Management Schedule.

KPMG recommends that OST perform a more robust review in completing the consolidated Legal Letter and Management Schedule to ensure the process/control is performed accurately and completely.

KPMG recommends that FHWA management develop an estimation methodology responsive to fluctuations in future expenses.

Create and enforce agency-specific written policies and procedures that specify how personnel actions should be initiated, reviewed, and submitted. These policies and procedures should specify the roles and responsibilities of HR personnel relating to this process and the required elements and documentation of management's review of personnel actions prior to submission.

Perform and document routine reviews on a monthly or more frequent basis to ensure that all personnel actions processed during the review period were appropriately reviewed and approved by a second, authorized HR official.

Correct the retirement plan assignment for the identified employee and take all necessary steps to remediate the error, including the return of excess contributions to the employee if appropriate.

Create and enforce written procedures to review all employee onboarding documents, including documentation received for transferred employees and individuals returning to Federal civilian service, to ensure that the documentation is complete and accurate.

Perform and document routine reviews of employees' Official Personnel Folders to verify that payroll and benefits elections are correct, including retirement plan assignments. Take action to correct any errors, including the collection or return of excess employee contributions, when warranted.

Design, implement, and document the performance of a manual review, at least quarterly, of the general ledger activity of downward and upward adjustments of prior year obligations general ledger accounts and record journal adjustments, when needed, to properly reclassify any errors that are identified.

Update existing policies and procedures to include the performance of a manual review of downward and upward adjustment activity during the period under review.

Require MidFirst to remedy the 24 borrowers in our sample with improper foreclosure filings or take administrative actions if appropriate.

Analyze MidFirst's resolution of the manual process issues identified during its 2022 quality control review to verify that it remedied the borrowers or HUD and corrected the issues identified related to manual processing.

Require MidFirst to update its policies and procedures to comply with HUD requirements by placing foreclosure holds for loss mitigation requests made before the first legal filing.

We recommend that the Acting Chief Operating Officer for FSA—Develop and implement controls to ensure policies and procedures related to the time frames for draft final audit determination letters for close-out audits, Missing Audit PRRs, and PRRs for closed school loan discharges are followed and completed timely, including updating policies and procedures to reflect the risk-based approach FSA uses to prioritize its oversight of IHEs participating in Title IV programs.

We recommend that the Acting Chief Operating Officer for FSA— Establish and review performance measures and indicators for the timely issuance of draft final audit determination letters for close-out audits of closed IHEs, Missing Audit PRRs, and PRRs for closed school loan discharges.

We recommend that the Acting Chief Operating Officer for FSA—Evaluate whether the staffing level assigned to final audit determinations for close-out audits of closed IHEs, Missing Close-Out Audit Program Reviews, and Closed School Loan Discharge Program Reviews is sufficient to timely and effectively assess liabilities for IHEs that close, and if not, develop and implement a plan of action to address the issue.

We recommend that the Acting Chief Operating Officer for FSA—Develop and implement controls to ensure SPD closed school analysts provide FSA closed school stakeholders with required notifications, including the Acknowledgement of Intent to Close notice and the Closed School Email Alert; or specify in its policies and procedures situations that do not require the notifications.

We recommend that the Acting Chief Operating Officer for FSA—Evaluate whether the staff assigned to issue the Acknowledgement of Intent to Close notice, Closed School Email Alert, and Close-Out Reminder letter is sufficient to timely and effectively notify FSA closed school stakeholders and closed IHEs, and if not, develop and implement a plan of action to address the issue, including updating the policies and procedures to align with FSA’s priorities, available staffing levels, and prescribed time frames as necessary.

We recommend that the Acting Chief Operating Officer for FSA—Establish and review performance measures and indicators for the timely issuance of the Acknowledgement of Intent to Close notice, Closed School Email Alert, and Close-Out Reminder letters.

The Deputy Commissioner should ensure that NDAs, policies, forms, and other guidance documents include the required anti-gag provision.

The Deputy Commissioner should include information about the anti-gag provision in training programs covering WPEA protections (e.g., new employee orientation and contractor training).