Open Recommendations

We recommend that the Assistant Secretary for Elementary and Secondary Education require the Commissioner Nominee of the Virgin Islands DOE to update its monitoring and internal control plan once an external evaluator is contracted to include the role the external evaluator will ultimately have in assisting the Virgin Islands DOE in monitoring the Restart program and information about how the Virgin Islands DOE will oversee the contractor to ensure contract deliverables are met.

We recommend that the Assistant Secretary for Elementary and Secondary Education require the Commissioner Nominee of the Virgin Islands DOE to staff its Internal Audit Division at planned levels and develop and implement standard operating procedures to provide reasonable assurance that it will fulfill its responsibilities.

We recommend that the Assistant Secretary for Elementary and Secondary Education require the Commissioner Nominee of the Virgin Islands DOE to assess the risk of fraud in the Restart program and develop and implement control activities to prevent, detect, and respond to potential fraud.

We recommend that the Assistant Secretary for Elementary and Secondary Education require the Commissioner Nominee of the Virgin Islands DOE to develop and implement a fraud reporting mechanism and display in public places the U.S. Department of Education Office of Inspector General hotline contact information, as required by Section 9203 of the Every Student Succeeds Act.

Develop and implement controls to ensure that the data entered into PMS and IFS is accurate and consistent with CPSC policies and procedures.

Develop procedures to review applicable regulations and laws on an annual basis in order to ensure the property management policies and procedures remain accurate and complete.

Establish and implement POA&M management procedures to ensure that all identified security weaknesses, including PMS application-specific and inherited control weaknesses, are fully documented and tracked.

Establish and implement POA&M management procedures to ensure that changes to estimated completion dates should be documented and reflected in the POA&M tracker.

Estimated completion dates should be documented and reflected in the POA&M tracker.

Upon a justifiable determination of PMS’s system categorization, design and implement standard procedures for requesting and approving user access to roles and resources in PMS.

Upon completion of the risk analysis, develop and implement procedures to ensure that CPSC users do not have unmonitored conflicting access across multiple systems.

Perform and document a risk analysis to identify potential SoD conflicts within PMS.

Upon the completion of the risk analysis noted above, management should develop and implement procedures that ensure PMS users do not have sufficient access to allow the unmonitored execution of incompatible transactions.

We recommend that the Office of Programs submit a plan, within 90 days, to the Senate Committee on Homeland Security and Governmental Affairs, the House Committee on Oversight and Government Reform, and the Office of Management and Budget, describing the actions that the agency will take to become compliant.

We recommend that the Office of Programs achieve a gross improper payment rate of less than 10 percent for Railroad Medicare. The Office of Programs through the Railroad Retirement Board’s Specialty Medicare Administrative Contractor should continue to work with Medicare providers to communicate the documentation requirements and monitor the adherence to such requirements throughout the year.

We recommend that the Office of Programs obtain and maintain the applicable Railroad Medicare sampling and estimation plan agency certification. It must be a Centers for Medicare and Medicaid Services’ certification, Railroad Retirement Board Chief Financial Officer’s certification, or other Railroad Retirement Board program official’s certification.

We recommend that the Office of Programs obtain the Railroad Medicare sampling and estimation plan for the fiscal year 2019 payment integrity reporting cycle.

We recommend that the Office of Programs establish a written policy to ensure subsequent Railroad Medicare sampling and estimation plans are obtained and readily available for review so that a qualified statistician would be able to replicate what was done or so that Office of Management and Budget, agency Inspector General, or Government Accountability Office personnel can evaluate the design.

We recommend that the Office of Programs submit the Railroad Medicare sampling and estimation plan for fiscal year 2019 to the Office of Management and Budget by the June 30th deadline.

We recommend that the Office of Programs obtain the Office of Management and Budget approval for Railroad Medicare’s overall reduction target rate.

We recommend that the Office of Programs and the Office of Administration work together to update the Memorandum of Understanding (MOU13-61) to describe the applicable agency responsibilities as they pertain to Improper Payments Elimination and Recovery Act laws and Office of Management and Budget guidance for payment integrity reporting.

We recommend that the Office of Programs include a brief narrative of the reduction in improper payments that is attributable to the Do Not Pay Initiative for Railroad Medicare and associated systems.

We recommend that the Office of Programs identify, publish, and provide a justification for Railroad Medicare uncollectible amounts.

We recommend that the Office of Programs adopt the Office of Management and Budget’s recommended best practice and describe statutory or regulatory barriers in the fiscal year 2019 Performance and Accountability Report.

We recommend that the Office of Programs update applicable performance appraisals with specific criteria for meeting applicable improper payment reduction targets and establish and maintain sufficient internal controls to reduce improper payments in accordance with Office of Management and Budget Circular A 136.