Open Recommendations

We recommend the Acting Deputy Assistant Administrator for Resilience implement financial management procedures to ensure FEMA regional officials monitor and close HMGP property acquisition projects in a timely manner, and that they conduct Strategic Funds Management reviews, document review decisions, and implement such decisions where appropriate. These actions will help minimize as much as $134,911,248 in funds that FEMA could put to better use.

We recommend the Acting Deputy Assistant Administrator for Resilience implement management procedures to ensure HMGP property acquisition project applications and project information are complete and accurate when submitted, reviewed, closed, and maintained by FEMA.

We recommend the Acting Deputy Assistant Administrator for Resilience direct FEMA regions to ensure states monitor, inspect, and report to FEMA on acquired HMGP properties in accordance with grant requirements to confirm the properties are maintained as open space.

We recommend the Acting Deputy Assistant Administrator for Resilience and FEMA’s Office of Equal Rights continue initiatives to reduce barriers and increase opportunities pursuant to Title VI of the Civil Rights Act of 1964 for applying for and receiving FEMA HMGP property acquisition grants. Additionally, we recommend that FEMA develop guidance and implement equity considerations in program delivery, including the states’ use of demographic, economic, and other required data when selecting projects for HMGP property acquisition.

The OIG recommends the Under Secretary for Benefits, in conjunction with the Assistant Secretary for Information and Technology, establish a mechanism to gain assurance that proper Office of Information Technology project management processes and protocols are followed when establishing information technology systems and applications.

Direct Cal Poly to implement additional administrative and management procedures surrounding the payment of intra-Institution of Higher Education consulting services. Updated procedures should require that Cal Poly: • Request and receive approval from NSF before charging NSF awards for intra-Institution of Higher Education consulting payments made to Cal Poly employees. • Document the methodology used to calculate the amount of any intraInstitution of Higher Education consulting payments made to Cal Poly employees.

Direct Cal Poly to strengthen its processes and procedures surrounding the booking and approval of travel expenses. Updated procedures could include implementing additional reviews for all airfare purchases, including requiring the reviewer to verify the traveler purchased an economy-class ticket and/or has appropriate justification for a travel upgrade before charging the travel expense to an NSF award.

Direct Cal Poly to strengthen its administrative and management controls and processes for supporting the allocation of expenses to sponsored projects. Updated processes could include: • Implementing a standard documentation and retention process to support the allocation of publication costs that benefit multiple awards. • Requiring Principal Investigators or other designated staff to both document and justify the allocation methodologies used when charging expenses to sponsored projects near the grant expiration date. • Performing reconciliations at the end of each summer program to verify that the costs charged to sponsored projects were appropriate based on the number of program participants.

Direct Cal Poly to strengthen its monitoring procedures and internal control processes for applying indirect costs to federal awards. Updated procedures could include implementing an annual review process for costs charged to awards that include funding for participant support costs to ensure Cal Poly is appropriately segregating these expenses in accounts that it has excluded from its Modified Total Direct Cost base.

Direct Cal Poly to strengthen its policies and procedures for creating and retaining documentation, including introducing additional controls to help ensure that it appropriately creates and maintains all documentation necessary to support the allowability of travel expenses charged to sponsored programs. Updated procedures could include: • Requiring travelers to document the business purpose of each day of a planned trip before charging travel costs to NSF awards. • Implementing additional reviews for all airfare purchases, including requiring the reviewer to verify that the traveler purchased an economyclass ticket before charging the expense to an NSF award. • Verifying that subawardees…

Direct Cal Poly to strengthen its administrative and management procedures to ensure the appropriate personnel complete and authorize an independent contractor agreement before a consultant begins work on a project.

Direct Cal Poly to (i) strengthen its administrative and management procedures to ensure travelers submit their travel expense reports within 10 days of returning from their trip, and/or (ii) update its policies and procedures to reflect its current expense reimbursement policies.

Rec. 1.c: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security establish a process to ensure that DoD Components, the original classification authorities, and the Defense Technical Information Center comply with the requirements in DoD Manual 5200.01, Volume 1, and DoD Manual 5200.45.

Rec. 2: The DoD OIG recommended that the Defense Technical Information Center Administrator, in coordination with the Under Secretary of Defense for Intelligence and Security, establish business rules for the security classification guide index, including a security classification guide naming, numbering, and formatting convention that will facilitate original classification authority searches of existing classification guidance to enable consistent classification of similar information throughout the DoD.

The Office of Programs should post Railroad Medicare program payment integrity information in the annual financial statement and accompanying materials on the agency website, in accordance with the Payment Integrity Information Act of 2019 and the Office of Management and Budget's data call requirements, until the Railroad Retirement Board formalizes an agreement with the Centers for Medicare and Medicaid Services to take over reporting for Railroad Medicare.

The Office of Programs should publish unknown payment estimates for the Railroad Medicare Program in the Office of Management and Budget's data calls, until the Office of Management and Budget formally approves the Railroad Retirement Board's discontinuation of reporting or approves an agreement between the Centers for Medicare and Medicaid Services and the Railroad Retirement Board on how Railroad Medicare will be reported.

The Office of Programs should develop and publish a Railroad Medicare corrective action plan in accordance with Office of Management and Budget directives.

The Office of Programs should publish improper payment and unknown payment reduction targets for the Railroad Medicare Program in accordance with the annual Office of Management and Budget Data Call requirements.

The Office of Programs should demonstrate improvement and develop a plan to meet the published improper payment and unknown payment reduction targets for the Railroad Medicare Program in accordance with the Office of Management and Budget directives.

The Office of Programs should report an improper payment and unknown payment rate of less than 10 percent for the Railroad Medicare program.

The Office of Programs should accept responsibility and accountability for the Railroad Medicare Program to further improve prevention and ensure that improper payments and unknown payments are minimized.

The Office of Programs should establish procedure to ensure timely revision of improper payment methodology and procedure to reflect the most recent Office of Management and Budget guidance and requirements.

Given the sensitivity of our review, this recommendation is restricted.

Rec. 2.a: The DoD OIG recommended that the Army's Deputy Chief of Staff, G-4 (Logistics); Navy's Deputy Chief of Naval Operations for Fleet Readiness and Logistics; and Chief of the Logistics Readiness Division, Headquarters Air Force (Logistics, Engineering, and Force Protection) reinforce and periodically communicate to ordering activities DoD and Service-specific reuse policies promoting maximizing reuse of excess property as a supply source. As part of this communication, the Military Services should provide ordering activities details regarding the newly established Defense Logistics Agency Disposition Services educational sessions, reuse website information, and instructions on how to search and place orders for…

Rec. 2.b: The DoD OIG recommended that the Army's Deputy Chief of Staff, G-4 (Logistics); Navy's Deputy Chief of Naval Operations for Fleet Readiness and Logistics; and Chief of the Logistics Readiness Division, Headquarters Air Force (Logistics, Engineering, and Force Protection) establish a process to ensure that activity ordering personnel comply with DoD and Service-specific policy for completing reuse training, including ensuring that all staff complete the training, and newly?hired ordering personnel are trained on the reuse of excess property within a few months of starting their duties.