Open Recommendations

Reinforce the New Jersey Small Business Development Center’s adherence to requirements on allowable types of hospitality cost under 13 CFR § 130.465 and Program Terms and Conditions, Section 7. Compare the $8,217 in unallowable costs to any overmatch funds per 13 CFR § 130.450(g) and recover costs as appropriate.

Instruct the New Jersey SBDC to submit an updated budget that reflects the $420,700 impact of the service center closure to evaluate whether funds are allowable in accordance with 2 CFR § 200.308(c)(5)(7).

Update the SBA resource partner website to reflect active New Jersey Small Business Development Center service centers.

Instruct the New Jersey Small Business Development Center to reconcile $75,247 of program income across the network to ensure generated income and expenses are accounted for and reported accurately in accordance with 13 CFR § 130.480.

Enforce the requirement for the New Jersey Small Business Development Center to timely adhere to export certification requirements and regularly report on its compliance status to SBA in accordance with Notice of Funding Section 5.1.4.4.

Ensure the New Jersey Small Business Development Center is maintaining sufficient accessibility to its facilities and appropriate staff levels and notifying clients of service centers’ hours of operation in accordance with 15 USC § 648(c)(2).

Ensure the New Jersey Small Business Development Center implements a process to ensure all personnel funded by federal grant funds are notified of their whistleblower protection rights in accordance with 41 U.S.C § 4712.

Ensure the New Jersey Small Business Development Center relates financial data and program accomplishments toward meeting the performance goals for the entire performance period as 2 CFR § 200.329(b) requires.

Ensure all facility staff respond appropriately during use of force incidents and applying adequate de-escalation techniques.

Ensure facility staff assess all response techniques prior to addressing noncompliance from a detainee when the situation does not require immediate force.

Ensure ICE staff respond to all detainee requests within the required 3 business days.

Ensure facility staff respond to all detainee grievances and appeals within the required 5 days.

Ensure facility staff maintain a complete log of all grievances, to include paper submissions.

Provide outdoor recreation equipment for detainees housed in the SMU.

Ensure detainees always wear identification wristbands and that any unreadable wristbands are immediately replaced with new ones.

Ensure the facility fills medical staffing vacancies, to include a permanent dentist and physician, as soon as possible.

We recommend that USAID/Democratic Republic of Congo verify that Invisible Children Inc. corrects the four instances of material noncompliance detailed on pages 43 to 47 of the audit report.

Determine the allowability of $25,536 in questioned costs ($17,482 ineligible and $8,054 unsupported) on page 11 and 27 of the audit report and recover any amount that is unallowable.

Verify that DIM-FHIS/SEDECOAS corrects the two material weaknesses in internal control detailed on page 25 of the audit report.

Verify that DIM-FHIS/SEDECOAS corrects the one instance of material noncompliance detailed on page 33 of the audit report.

Rec 1: The DoD OIG recommended that the the U.S. Property and Fiscal Officer for the Nevada National Guard issue a memorandum to the auditors assigned to the Internal Review Division emphasizing that when auditors do not comply with Generally Accepted Government Auditing Standards requirements, the auditors should take the following actions in accordance with Generally Accepted Government Auditing Standards 2.19 and 9.05.
a. Assess the significance of noncompliance to the engagement objectives.
b. Document the assessment, along with the reasons for not following the requirement.
c. Determine which type of Generally Accepted Government Auditing Standards compliance statement to use…

Rec 2: The DoD OIG recommended that the that the U.S. Property and Fiscal Officer for the Nevada National Guard develop and implement a process for the monitoring and documentation of quality in their office in accordance with Generally Accepted Government Auditing Standards 5.43 and 5.44.

Rec. 3: The DoD OIG recommended that the U.S. Property and Fiscal Officer for the Nevada National Guard require that auditors assigned to the Internal Review Division obtain training on performing nonaudit services in accordance with Generally Accepted Government Auditing Standards.

Rec. 4: The DoD OIG recommended that the National Guard Bureau Internal Review Office Director issue a memorandum to the auditors at the National Guard Bureau Internal Review Office Headquarters and the Internal Review divisions of the United States Property and Fiscal Office to emphasize the requirement to inquire of the audited entity's management whether any investigations or legal proceedings significant to the audit objectives have been initiated or are in process with respect to the period under audit, in accordance with Generally Accepted Government Auditing Standard 8.27.

Rec. 5: The DoD OIG recommended that the National Guard Bureau Internal Review Office Headquarters Director and U.S. Property and Fiscal Officer for the Maryland National Guard develop and implement a tool, such as a fraud risk assessment template, to help ensure that the auditors assess the risk of fraud that is significant in the context of the audit objectives, in accordance with Generally Accepted Government Auditing Standard 8.71.