Open Recommendations

Work with HUD's Office of Lead Hazard Control and Healthy Homes to provide technical assistance to the Authority's staff to develop and implement policies, procedures, and controls for managing cases of children with EBLLs to ensure compliance with the LSHR, including attempts to collaborate with public health departments to identify cases of EBLL in children under 6 years of age under its HCV Program and updating its policies and procedures accordingly.

Conduct route reviews for all routes in the Puerto Rico District, create a prioritized list of routes needing adjustments based on the reviews, and coordinate with Headquarters Delivery Operations to create a plan to perform the necessary adjustments.

Enhance the Commission’s internal controls related to oversight of third-party service providers and implement performance monitoring procedures. These procedures should allow for the effective tracking of the service providers’ actual deliverables against the requirements prescribed in the IAA.

Evaluate third-party service providers’ performance against the milestones and timeline expectations identified in the IAA or SLA. The evaluation mechanisms and tools should incorporate any performance metrics outlined in the IAA or SLA.

Enhance its procedures over the review of, and reconciliation between, the data on the Request for Personnel Action (SF-52) and the Notification of Personnel Action (SF-50) for the same personnel event, to ensure that the Commission detects and addresses discrepancies in a timely manner.

Implement measures to ensure that LC3 Solutions properly completes and processes SF-52s in accordance with the nature of the personnel event.

Implement measures to facilitate closer coordination with GSA CABS to ensure that it processes and approves SF-50s in a timely manner, and that it only makes retroactive approvals based on the conditions described in the OPM GPPA.

Implement a contract tracking system that will enable the contract administration team to perform a detailed analysis of small business awards in each of the small business categories and compare the award value for each category against the total value for all awards to ensure that the Commission can effectively monitor its award activities with regard to its small business procurement goals.

Implement a contract-writing system that integrates an industry-standard, automatically updated provision and clause database. The Commission should also have associated controls in place to ensure that the database is up to date and meets the pertinent acquisition regulations and statutory requirements.

Update its COWP policy to ensure that it has appropriately evaluated and assigned its warrant threshold designations. This evaluation should be based on the contracting.

Implement a more robust contracts tracking system that includes validating data against the source documents and ensuring that when an individual updates the tracking system, another individual reviews those updates. The frequency of the quality checks or data validation reviews required is contingent on the volume and complexity of the contracting activities.

Ensure Veterans Benefits Administration staff use improved methodologies similar to the Office of Inspector Generals review to identify eligible veterans, readjudicate claims, and send outreach letters to potential Nehmer class members who could qualify for retroactive benefits under the National Defense Authorization Act.

Formally define and document in writing ISOO’s monitoring methodology to address at a minimum program risk, staff responsibilities, and monitoring of program performance.

Develop and implement written internal policies and procedures that provide clear guidelines and timelines for CUI program management and oversight processes.

Formally document processes in writing that detail ISOO personnel responsible for the preparation and regular review of CUI internal control activities and relevant risks.

Develop and document a CUI performance management and oversightplan (i.e., performance measures and controls that ensure compliance with relevant CUIpolicies and regulations) to address at a minimum staff responsibilities and frequency ofactivities performed.

Determine the allowability of the questioned unsupported costs of $1,222,684, on pages 11 of the audit report and recover any amount that is unallowable.

We recommend the Assistant Secretary for Employment and Training establish policies and procedures for monitoring, using lessons learned from the Short-Time Compensation program during the pandemic, that ensure states meet requirements for similar future temporary unemployment insurance programs that provide federal reimbursements to states.

We recommend the Assistant Secretary for Employment and Training review states’ compliance with Short-Time Compensation (STC) eligibility requirements and require all states with STC agreements to return federal funds used for reimbursements of STC benefit payments for weeks of unemployment beginning before March 27, 2020, and ending after September 6, 2021, as well as for reimbursements that exceeded benefits paid.

We recommend the Assistant Secretary for Employment and Training monitor states administering unemployment insurance programs subsidized with federal funds, including temporary programs such as Short-Time Compensation, to ensure compliance with the 3-year records retention requirements established in the Code of Federal Regulations (2 C.F.R. § 200.334).

Create a standard operating procedure to collect and handle data and define roles and responsibilities for enhanced operational efficiency.

Develop a unified information system for use by the Commission, CNAs, and NPAs participating in the Program.

Develop and implement a comprehensive plan to perform trend analyses and analyze risks posed by individuals whose consular interviews were waived by the Dos with data captured at mitigation plans., and using the results, develop and implement mitigation plans.

NRCS needs to prioritize the correction of outstanding inaccurate IIJA WFPO reporting on USAspending.gov and ensure existing award data are accurately reported to the public in accordance with OMB and DATA Act requirements.

NRCS needs to design and implement internal control activities over information processing to address inaccurate reporting identified in Recommendation 1 to ensure compliance with OMB and DATA Act requirements and the accuracy of future reporting of IIJA WFPO data on USAspending.gov.