Open Recommendations

2. EEOC should develop an agency-wide Improper Payment risk assessment standardoperating procedures (SOP). This SOP should include risk assessment procedures to beperformed by each identified significant program. These procedures should be based onOMB A-123 guidance found in Appendix C. For each identified significant program, aresponsible program point of contact should be established. The responsible party shouldreport results of their programs risk assessment to the EEOC responsible official (or office);

EEOC should develop a SOP to ensure annual compliance with OMB A-136 PIIA reviewand reporting requirements.

We recommend that Saint Louis University refund $263 to NIH for unallowable travel costs.

We recommend that Saint Louis University ensure that it always manages NIH awards in accordance with Federal and award requirements by strengthening procedures for reconciliation of payroll costs to approved salaries and wages and to payroll reports, and strengthening controls to ensure the timely completion and certification of employee time and effort reports after completion of each 6-month reporting period.

We recommend that Saint Louis University enhance its existing controls by developing and implementing policies and procedures to ensure that either the internal audits conducted by its internal audit firm, the University's compliance department, or both, review costs that the University claims for its NIH awards.

We recommend that Saint Louis University strengthen its controls, to include policies and procedures, to ensure that it properly monitors its subaward subrecipients, to include: evaluating its current risk assessment policies and procedures and implementing procedures to improve monitoring of subrecipients classified as high or medium risk and developing and implementing notification and followup procedures to be executed in cases of subrecipient subaward or contract cancellation.

(U) Rec. A.1.a: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security, in coordination with the DoD Chief Information Officer and DoD Component Heads, develop and implement a DoD-wide solution for automatically populating documents and e-mails with the required markings based on a set of selection criteria.

(U) Rec. A.1.b: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security revise DoD Instruction 5200.48 to require DoD Components to implement a process to track the completion of controlled unclassified information training, such as the use of a learning management system, and use that process to enforce the requirement that personnel complete the controlled unclassified information training.

(U) Rec. A.1.d: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security add a question to the controlled unclassified information questionnaire that requires DoD Components to select a sample of controlled unclassified information documents, test whether personnel are including the required markings, and report the discrepancies identified during the test.

(U) Rec. A.1.e: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security coordinate with the National Archives and Records Administration to clarify the intent of the "Federal employees only" and "Federal employees and contractors only" limited dissemination controls, and when they should apply.

(U) Rec. A.1.f: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security revise DoD guidance to reflect any changes made to the use of the "Federal employees only" and "Federal employees and contractors only" limited dissemination controls.

(U) Rec. A.1.g: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security develop and implement a process to identify systemic discrepancies with the implementation of controlled unclassified information programs across the DoD Components and provide guidance to the DoD Components to address those systemic issues.

(U) Rec. A.1.h: The DoD OIG recommended that the Under Secretary of Defense for Intelligence and Security require DoD Components that identify discrepancies within their controlled unclassified information program to develop and implement corrective action plans, and provide updates on the actions taken to resolve the discrepancies in future years questionnaires.

(U) Rec. A.2: The DoD OIG recommended that the Commanding General of the Army Training and Doctrine Command update the Training Development Capability to include the option to mark documents as controlled unclassified information and prompt personnel to add the designation indicator and portion markings, if applicable.

(U) Rec. A.3: The DoD OIG recommended that the Chief of Naval Operations update standard forms and templates to include controlled unclassified information headers and footers, and prompt personnel to add the designation indicator and portion markings.

(U) Rec. B.1.b: The DoD OIG recommended that the Defense Pricing and Contracting Principal Director coordinate with the Office of the Under Secretary of Defense for Intelligence and Security and the DoD Chief Information Officer to develop a Defense Federal Acquisition Regulation Supplement clause to require all DoD contractor personnel to complete the required DoD controlled unclassified information training.

We recommend that the Diversity, Inclusion and Dispute Resolution Office (DI/DR) perform a climate assessment for jurisdictions that frequently work with the public to identify and address concerns regarding nonemployee harassment and hostile work environments.

We recommend that the Architect of the Capitol (AOC) document and implement a process to conduct follow up inquiries after resolution to identify employee concerns, verify safety, address fears of retaliation and ensure effective reintegration (as appropriate) to minimize negative impacts on its workforce.

We recommend that the Architect of the Capitol (AOC) update AOC Order 24-1 Conciliation Program Guide, May 22, 2013, to ensure it is providing consistent and current information about the conciliation process and resources available.

The Chief Taxpayer Experience Officer should work with other IRS business units to define and identify the populations of each underserved community, and to develop and implement a comprehensive agencywide strategy to improve programs, products, and services for underserved communities when the TXO is fully operational.

HUD (a) identify all contracts related to its programs that pre-date July 1, 2013 and that have not yet been modified to include Section 4712 whistleblower protections; and (b) review all contracts entered into on or after July 1, 2013, to ensure they include a clause that requires contractors to comply with Section 4712. Status As of November 2024, we have not yet reached agreement on a management decision with HUD over the corrective action they propose to take to address the recommendation.

Seek voluntary cooperation from program participants to proactively modify pre-2013 contracts for the purpose of including a clause requiring compliance with Section 4712. Status As of November 2024, we have not yet reached agreement on a management decision with HUD over the corrective action they propose to take to address the recommendation. Analysis

Use its best efforts to include a clause requiring compliance with Section 4712 at the time of major modifications to contracts with program participants with whom HUD is unable to gain voluntary cooperation. Status As of November 2024, we have not yet reached agreement on a management decision with HUD over the corrective action they propose to take to address the recommendation. Analysis

HUD seek legislative authority to expeditiously include Section 4712 protections within contracts for which HUD believes it must otherwise wait until there is a major modification.

HUD develop and implement controls to ensure that the provisions of Section 4712 are included in all contracts.