Open Recommendations

We recommend that Department management enhance its FPDS-NG procurement award approval controls to ensure all contract award data are timely approved in accordance with FAR 4.604.

We recommend that Department management enhance its controls over the verification of whether awardee information in SAM.gov agrees to awardee information in the grants system at the time of award.

We recommend that Department management enhance its controls related to the timely input of financial assistance award data to FABS.

Treasury continue working with TEOAF to ensure proper submission of Equitable Sharing financial assistance awards on USAspending.gov.

Develop and implement a plan of corrective actions to promptly address outstanding accounting and processing issues related to the transition to ARC. These issues include capturing all Federal Award Identification Numbers from Momentum in Oracle to ensure completeness of all data transferred; correcting invalid object class and program activity codes; and reconciling and validating balances between the old accounting system and the new accounting system

Update the DATA Act Business Process Guide to include documenting the data inventory/mapping for Files A, B, C, D1 and D2 to ensure that standardized data elements and OMB and Treasury definitions per the DATA Act Information Model Schema (DAIMS) are used across AmeriCorps business processes, systems, and applications; identify the appropriate source systems where the data resides; and identify gaps.

Work with ARC to ensure correct and complete Object Class and Program Activity codes are programmed in the source systems in accordance with OMB A-11, Section 83.

Establish and implement processes to reconcile and maintain adequate documentation of the reconciliation of the data file linkages. In addition, the processes should include performing monthly completeness, accuracy, and timeliness tests of the data elements using the Inspector General Guide as an internal control monitoring system.

Establish and comply with a timeliness standard for resolving DATA Broker warnings addressing data quality issues. Detailed corrective actions with milestones, deadlines, and responsible staff should be established.

Establish and implement effective internal control to ensure that adequate documentation is maintained and is readily available to support procurement contracts and financial assistance awards (grants).

Establish and implement controls to require that awardees (financial and procurement) register in SAM at the time of award.

Develop, document, and implement a process to ensure that de-obligations of grants with canceled funds are reported to Financial Assistance Broker System (FABS), when they occur and not when they are administratively closed-out.

We recommend that the SAO and EXIM’s DATA Act Working Group determine the root cause of the errors in EXIM-provided data identified during the testing of the second quarter FY 2021 Files D1 and D2, and take necessary corrective action to: (a) correct the errors for records shown in USASpending.gov; (b) identify the risk of reporting incorrect data for each data element containing the error; and (c) update the policies and procedures for recording data in Comprizon, FPDS, and FABS to address the risks and include adequate verification and validation review processes performed by the data owner and a supervisor…

We recommend that the SAO and EXIM’s DATA Act Working Group continue to improve the design of its review of the procurement award data in FPDS and financial assistance award data submissions to FABS by identifying the root cause for the exceptions in those data elements for which EXIM is responsible, and by developing more effective review procedures for those data elements, as well as the data elements that the SAO and DATA Act Working Group identify as having a high risk of not being accurate, complete, or reported timely.

We recommend that the SAO and EXIM’s DATA Act Working Group review EXIM’s policies and procedures for submitting contract award data in FPDS, including procedures for reviewing and confirming the accuracy of the CAR, to ensure proper design and compliance with FAR guidelines for timeliness. Update the policies and procedures based on this review, as necessary, to ensure EXIM meets FAR timeliness guidelines.

We recommend that the SAO in coordination with the OCFO continue to implement its corrective action plan to ensure that object class codes are accurately and completely reported in all financial and award data submissions (Files B and C).

Begin submitting financial assistance award data into Financial Assistance Broker System and its File C.

The Office of Administration should incorporate into their weekly practice the review of contract awards to ensure procurement awards are approved in FPDS-NG within 3 business days of the contract award signed date.

The Office of Administration should update the DQP to include a procedure to perform and prepare reconciliation analyses to identify the activity that occurred between when the original contract/modification was awarded, when File D1 was generated, and when FPDS-NG reports are pulled to validate the amounts reported in File D1 for Current Total Value of Award and Potential Total Value of Award data elements. If the reconciliation process demonstrates these errors occur due to timing differences, RMA also recommends the Office of Administration work with Treasury to address this gap in the testing guidance to ensure these timing differences are…

We recommend that the Chief Acquisition Officer ensure internal control on approval and coordination with PRISM support required to appropriately bypass FPDS-NG when modifying a document via the double-dash process (a 90000 administrative action modification) is implemented. Moreover, clearly document in the Supplement to NARA 501, Procurement Guide, that the double-dash contract modification is a 90000 administrative action.

Refund to the Federal Government the $6,401,297 of estimated net overpayments.

Identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before or after our audit period and refund any resulting overpayments to the Federal Government.

Continue its examination of existing compliance procedures to identify areas where improvements can be made to ensure diagnosis codes that are at high risk for being miscoded comply with Federal requirements (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

Develop and apply solutions to ensure FEMA fully complies with the new DATA Act requirements in OMB Memorandum M-20-21 for reportingcumulative COVID-19 outlays on a monthly basis and linking spending to emergency and disaster appropriations through the Disaster Emergency Fund Code data element. Ensure the solutions produce complete and accurate data elements that can be independently traced and verified to an auditable file.

Develop and apply solutions to improve the implementation and use of the government-wide financial data standards for procurement andfinancial assistance data elements that had an accuracy error rate of 10 percent or more.