Open Recommendations

Develop and maintain an accessible database with all information required to effectively manage the position designation and suitability program. At a minimum, this system should contain the name of the employee or contractor, position number and title, position designation, tier of background investigation completed, entry-on-duty date, date the background investigation was requested, date the background investigation was completed, whether it was an initial investigation or reinvestigation, whether reciprocity was applied, and reinvestigation due date.

Use the information developed in Recommendation Two to track an employee’s investigation versus the designation of their position and ensure they are properly aligned.

Use an automated tool to track when employee and contractor reinvestigations are due.

Update the investigations of employees whose completed investigation has exceeded the five-year reinvestigation requirement.

Allocate the appropriate resources going forward to ensure that all reinvestigations are initiated on or before the due date.

Establish a process to include Office of Human Resources Management during the drafting of the statement of work to determine the appropriate investigative tier for contractors prior to when the request for quotes is released to potential vendors.

Develop a formal documented process (directive or standard operating procedure) for onboarding contractors.

Develop a system to communicate any changes in the onboarding process to contracting officer’s representatives and other personnel involved in the onboarding of employees and contractors.

Develop and document a systematic and repeatable risk assessment process to evaluate the risk of applying reciprocity for incoming contractors.

Regarding contractors, develop and maintain an accessible database containing the information outlined in Recommendation Two, as well as the contract number, similar CPSC position, contractor name, employer, and name of contracting officer’s representative.

Complete the work required to fully implement OPM’s recommendations from 2017.

The Bureau of Overseas Buildings Operations, in coordination with the Bureaus of European and Eurasian Affairs, Near Eastern Affairs, and Western Hemisphere Affairs, should bring principal officer residential swimming pools at Embassies Cairo, Madrid, and Quito, and Consulate General Hamilton into compliance with Department swimming pool safety standards.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to require that OT justification memos be signed, dated, and written or developed with involvement from appropriate parties, including OT Agreements Officers.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to require that OT justification memos include explicit statements as to why a traditional award instrument could not be used for a project.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to require that justifications for the continued use of OT authority be documented throughout the life of OT agreements with reconsideration required at a defined frequency.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to specify requirements for determining and documenting the fairness and reasonableness of award amounts or cost estimates provided by OT award applicants.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to specify requirements for determining and documenting the allowability of costs charged to OT awards.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to specify requirements for determining and documenting its compliance with Federal funding requirements including the proper establishment of bona fide needs through specific work requirements prior to the obligation of OT funds.

The Office of Policy, Planning, and Resources, in coordination with the Foreign Service Institute, should develop and implement a training plan with short-, medium-, and long-term objectives that address how to train public diplomacy officers and locally employed staff in core competencies based on new position descriptions for Public Diplomacy Staffing Initiative implementation.

Review the modified National Pollutant Discharge Elimination System mining permits issued by West Virginia based on the 2019 revisions to its National Pollutant Discharge Elimination System program to ensure that no backsliding has occurred, including for discharges of ionic pollution, in accordance with EPA Region 3’s approval letter dated March 27, 2019. If a permit does not contain record documentation for the reasonable potential analysis or otherwise allows backsliding, alert West Virginia of the permit inadequacies.

Review the modified National Pollutant Discharge Elimination System mining permits issued by West Virginia based on the 2019 revisions to its National Pollutant Discharge Elimination System program to determine whether the permits contain effluent limits for ionic pollution and other pollutants that are or may be discharged at a level that causes, has the reasonable potential to cause, or contributes to an excursion above any applicable water quality standard, as required by Clean Water Act regulations. If a permit lacks required effluent limits, take appropriate action to address such deficiencies.

Develop a formal internal operating procedure to facilitate timely permitreviews and transmission of EPA comments to states.

Review and provide written input on any National Pollutant Discharge Elimination System permit prepared for reissuance by the Minnesota Pollution Control Agency for the PolyMet Mining Inc. NorthMet project, if applicable, as appropriate pursuant to the requirements of the Clean Water Act, National Pollutant Discharge Elimination System regulations, the Region 5 National Pollutant Discharge Elimination System permit review standard operating procedure, and the memorandum of agreement between EPA Region 5 and the Minnesota Pollution Control Agency.

Rec. 1.e: The DoD OIG recommended that the Principal Director, Defense Pricing and Contracting clarify its policy for determining the approval level required for project awards when using consortiums and ensure the guidance is uniformly applied and implemented by contracting personnel.

Rec. 1.g: The DoD OIG recommended that the Principal Director, Defense Pricing and Contracting establish Department of Defense-level training specific to awarding other transactions through consortiums that ensures Agreements Officers receive training to demonstrate expertise in executing, managing, and administering complex acquisition instruments, and can function in a less structured environment where prudent judgment is essential.