Open Recommendations

Clarify the functional statements for the Office of the Under Secretary and FSA to clearly state whether and in what circumstances the Under Secretary may, consistent with the provisions of the HEA governing FSA as a performancebased organization, exercise the Secretary’s authority to direct the operations of FSA. Authority areas that should be clarified include but are not limited to determinations regarding changes in school ownership.

Ensure that FSA creates and retains records explaining decisions to deviate from prescribed policy for letter of credit requirements and temporary provisional program participation agreement extensions during a change in ownership and documenting how the interests of students and taxpayers are adequately protected.

Clarify the functional statements for the Office of the Under Secretary and FSA to clearly state whether and in what circumstances the Under Secretary may, consistent with the provisions of the HEA governing FSA as a performancebased organization, exercise the Secretary’s authority to direct the operations of FSA. Authority areas that should be clarified include but are not limited to dealing with potential school closures and the Department’s release of and approval for the use of surety funds.

OIG recommends that the Bureau of Administration review and update all foreign per diem locations designated in eAllowances as exchange rate adjusted in accordance with the guidance developed in response to Recommendation 3.

OIG recommends that the Bureau of Administration review its methodology for determining foreign per diem rates to identify opportunities to streamline the process. At a minimum, the Bureau of Administration should consider whether the use of independent economic data would be more efficient and cost-effective for establishing foreign per diem rates.

OIG recommends that the Bureau of Administration develop and implement a plan to revise the methodology for determining foreign per diem rates based on the results of Recommendation 11.

After implementing Recommendation 12, OIG recommends that the Bureau of Administration recalculate the foreign per diem rates for the locations based on the revised methodology.

OIG recommends that the Bureau of Administration complete its efforts to upgrade and update its eAllowances application. As part of this effort, the Bureau of Administration should ensure that posts are able to upload supporting documentation, such as reservation logs, into the application.

Rec. A.1.a: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Directors of the Defense Finance and Accounting Service and DoD Components to establish and implement business rules between all the systems that create, process, or store SF 1081 transactions and the Advancing Analytics tool to ensure that the DoD maintains a universe of SF 1081 transactions in a centralized database.

Rec. A.1.b: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/ Chief Financial Officer, DoD, work with the Directors of the Defense Finance and Accounting Service and DoD Components to establish memorandums of understanding with the system owners and the Advancing Analytics owners to define roles and responsibilities for managing the SF 1081 transactions.

Rec. A.1.d: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Directors of the Defense Finance and Accounting Service and DoD Components to develop metric reports that track the net and absolute dollar amount, and number of SF 1081 transactions by each system that creates, processes, and stores SF 1081 transactions.

Rec. A.1.f: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Directors of the Defense Finance and Accounting Service and DoD Components to ensure that all systems that create, process, or store SF 1081 transactions can differentiate between SF 1081 transactions and other types of transactions. In addition, the systems should have the capability to differentiate between SF 1081 transactions used to correct errors and those used to transfer funds.

Rec. B.1: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, work with the Director of the Defense Finance and Accounting Service to either update the Defense Joint Military Pay System to ensure that all disbursements cite the correct accounting information or develop alternative automated solutions.

Rec. B.2.c: The DoD OIG recommended that the Director of the Defense Finance and Accounting Service implement procedures to inform DoD Component management when the Component is charged for Defense Finance and Accounting Service errors.

Rec. B.2.f: The DoD OIG recommended that the Director of the Defense Finance and Accounting Service identify other processes or systems that may be using suspense accounts to record known transactions and implement corrective actions, to include updating applicable process documentation, as appropriate.

Rec. B.5: The DoD OIG recommended that the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, identify and direct the appropriate official to conduct an analysis of the various cost components that the Defense Finance and Accounting Service uses to compute the rate it charges DoD customers for its services. From this analysis, identify and implement improvements to the Defense Finance and Accounting Service operations to reduce the DoD's cost of accounting and financial management operations.

Rec. 1.h: The DoD OIG recommended that the Defense Logistics Agency-Energy Commander revise Defense Logistics Agency-Energy P-8, "Fuel Card Program," to require reviews of all invoice information to ensure the invoice matches a valid aircraft in that account, or to reconcile whether the transaction was valid and include reconciliation documentation and certification in the Aviation Into-Plane Reimbursement Card System before payment.

Rec. 2.b: The DoD OIG recommended that the Defense Logistics Agency-Energy Commander revise the Aviation Into-Plane Reimbursement Card portion of the contract with Kropp Holdings Inc. to enforce the requirement for Kropp Holdings Inc. to provide line item detail on invoices.

Rec. 2.c: The DoD OIG recommended that the Defense Logistics Agency-Energy Commander revise the Aviation Into-Plane Reimbursement Card portion of the contract with Kropp Holdings Inc. to require Kropp Holdings Inc. to allow disputes based on price reasonableness.

Rec. 2.d: The DoD OIG recommended that the Defense Logistics Agency-Energy Commander revise the Aviation Into-Plane Reimbursement Card portion of the contract with Kropp Holdings Inc. to establish a control to identify transactions that are at high risk for being unreasonable to ensure Aviation Into-Plane Reimbursement Card officials dispute charges within the required timeframe.

Rec. 2.e: The DoD OIG recommended that the Defense Logistics Agency-Energy Commander revise the Aviation Into-Plane Reimbursement Card portion of the contract with Kropp Holdings Inc. to require transparency for all Aviation Into-Plane Reimbursement Card transactions, including the charges and pricing information associated with vendor admin fees.

Rec. 3.a: The DoD OIG recommended that the Defense Logistics Agency-Energy Commander require that the Defense Logistics Agency Program Management Office and the Defense Logistics Agency Tax Branch, in coordination with the Military Services, develop a standardized Aviation Into-Plane Reimbursement Card receipt with dedicated sections for required information, including a list of approved ancillary services and fees, a corresponding column for merchant cost information, and a signature line for the card user and approving official.

Rec. 3.b: The DoD OIG recommended that the Defense Logistics Agency-Energy Commander require that the Defense Logistics Agency Program Management Office and the Defense Logistics Agency Tax Branch perform a comprehensive review of all taxes applied to Aviation Into-Plane Reimbursement Card transactions, compile a list of the erroneous taxes identified with the corresponding cause, develop a plan to prevent future erroneous taxes and fees, and recoup the erroneous charges.

Rec. 7.e: The DoD OIG recommended that the Readiness Division Chief, Headquarters Air Force, Operations Directorate, Training and Readiness Division, direct the Component Program Manager to review, at least monthly, the report created to identify transactions at high risk of being unreasonable and ensure Aviation Into-Plane Reimbursement Card officials dispute charges within the required timeframe.

We recommend that Staten Island University Hospital refund to the Medicare contractor the portion of the $11,761,274 in estimated overpayments for the audit period for claims that it incorrectly billed that are within the 4-year reopening period.