Open Recommendations

Direct Clemson to strengthen its policies and procedures related to 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 expenses charged to sponsored programs.

Direct Clemson to strengthen its administrative and management processes and procedures surrounding the approval of travel expense reports. Updated procedures could include: a. Establishing clear guidance regarding the allowability of registration fees when individuals are no longer able to attend the event. b. Developing a procedure to evaluate travel that occurs near the end of an award and remove any travel costs associated with trips that occur after the award expires. c. Conducting annual training for individuals responsible for reviewing and approving expense reports within each department, to define what expenses are allowable on a sponsored program. d. Establishing clear…

Direct Clemson to establish clear guidance regarding the allowability of participant support funding for employee travel.

Direct Clemson to establish procedures to ensure that its salary payments do not exceed the employee’s Institutional Base Salary.

Direct Clemson to update its current proposal submission and award set-up practices to require that, when setting up accounts established for supplemental funding for NSF awards, personnel ensure that the accounts apply indirect costs as directed by the supplemental funding letter.

Direct Clemson to ensure that it has performed risk evaluations for all subawards issued prior to June 2018 and that these risk evaluations remain active, to validate the agreements in accordance with Federal regulations.

Direct Clemson to update its current pre-award procedures and internal controls for reviewing NSF proposal budgets to ensure that all costs included in the participant support cost budget comply with NSF terms and conditions.

Direct Clemson to update its current procedures and internal controls to ensure that Principal Investigators submit final reports to NSF in accordance with NSF’s terms and conditions. Updated procedures should require Clemson to verify the submission of the final report with both the Principal Investigators and NSF during project close-out or when the Principal Investigator is leaving Clemson.

Direct Clemson to strengthen its administrative and management procedures for equipment expenditures to ensure that the Office of Grants and Contracts Administration approves all equipment purchased with non-sponsored funds and subsequently transferred to sponsored funds.

Direct Clemson to strengthen its administrative and management procedures to confirm it has completed the subrecipient documentation package before approving non-budgeted subawards.

Direct Clemson to strengthen its administrative and management procedures and internal controls related to the effort certification process. Updated procedures could include requiring Office of Grants and Contracts Administration personnel to follow up with any personnel that do not certify their effort reports within 30 days.

Direct Clemson to strengthen its administrative and management processes surrounding document retention for purchases on sponsored awards.

Direct Clemson to strengthen its directives, procedures, and internal controls for obtaining approval for foreign travel before the trip occurs.

Direct Clemson to strengthen its directives, procedures, and internal controls for procuring contract services on sponsored projects. Updated processes could include the following: a. Conducting annual training for those individuals who procure contract services, including Principal Investigators. The training should include topics such as the process for obtaining approvals for contractors on sponsored programs, the documentation needed before work begins, and the purchase order process required before issuing payment. b. Requiring individuals who initiate contract services to complete the applicable information in the appropriate procurement forms, as required by Clemson policy for contracted service agreements on sponsored projects.

Direct Clemson to strengthen its procedures and internal controls for reviewing account codes that are required to incur indirect costs. Updated procedures could include an annual indirect cost reconciliation.

Direct Clemson to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award (except in instances where the award letter or supplement letter specifies otherwise), rather than using the rates included within the original grant proposal.

Direct Clemson to require its subawardees to apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date the subaward was granted, rather than using the rates included within the subaward budget and proposal.

Clarify officer safety-related training requirements for operational personnel, including Task Force Officers, and ensure that the requirements are clearly established in policy.

Ensure that the Training Division provides consistent and prompt assistance to those districts that do not have an assigned Tactical Training Officer.

Ensure that all Tactical Training Officers receive skills sustainment training.

Establish methods to evaluate whether the Tactical Training Officer Program is accomplishing its objectives.

Ensure that the new After-Action Review policy is implemented so that all critical incidents stemming from operations led by and/or involving U.S. Marshals Service personnel are reviewed for lessons learned and used to update and adjust officer safety-related training.

Consider including other Department of Justice law enforcement components in operational reviews of critical incidents, including but not limited to the new After-Action Review process, to allow for mutual awareness and improvements to officer safety-related training across components.

Evaluate whether modifications to training are needed to adequately cover open space encounters and to better support small teams, and, if so, develop and implement methods to ensure that training adequately addresses these.

Update and implement EXRM directives, policies, and procedures regarding position designation to reflect current EXRM operations and address current OPM policies and guidelines.