Open Recommendations

Investigate potential controls or processes that could identify 1358s that should be reported until the system modernization can implement a solution.

Develop and implement oversight policies and procedures to ensure component entities report financial assistance awards timely.

Coordinate with USAC management to develop and implement processes for obtaining all required data elements from awardees prior to issuing an award. This may include updating or creating program forms to include all required data elements needed for Financial Assistance Broker Submission.

Develop and implement oversight policies and procedures for monitoring data reported by component entities to ensure that all DATA Act information is being reported timely, accurately, and completely.

Enforce that documentation is maintained to evidence changes to a loan and ensure that awarding actions are entered into the source systems in a timely manner.

Update policies and procedures to require that Awardee/Recipient Legal Entity Name and Legal Entity Address data elements match SAM.gov at the time of the award and any award modifications for all contracts and grants. At the time of any award modification, update the Agency’s contracts or grants management system and the Federal Procurement Data System with any changes to these data elements.

Update the EPA’s grants management system to align with the data standards of the Digital Accountability and Transparency Act of 2014, including all parts of data elements reported therein, and to allow input only of the acceptable values outlined for each data element in DATA Act Information Model Schema, Reporting Submission Specification.

Update the Catalog of Federal Domestic Assistance Titles on an annualbasis, as required in DATA Act Information Model Schema, Practices and Procedures, Appendix F, “Update Cadence for Data Sources.”

We recommend that Department management enhance its FPDS-NG data error checking controls (including manual investigation and resolution by Contracting Officers), and controls over the input of award data in FPDS-NG to effectively identify and correct incomplete and inaccurate data within FPDS-NG prior to the Department's submissions.

We recommend that Department management enhance its FPDS-NG procurement award approval controls to ensure all contract award data are timely approved in accordance with FAR 4.604.

We recommend that Department management enhance its controls over the verification of whether awardee information in SAM.gov agrees to awardee information in the grants system at the time of award.

We recommend that Department management enhance its controls related to the timely input of financial assistance award data to FABS.

Treasury continue working with TEOAF to ensure proper submission of Equitable Sharing financial assistance awards on USAspending.gov.

Develop and implement a plan of corrective actions to promptly address outstanding accounting and processing issues related to the transition to ARC. These issues include capturing all Federal Award Identification Numbers from Momentum in Oracle to ensure completeness of all data transferred; correcting invalid object class and program activity codes; and reconciling and validating balances between the old accounting system and the new accounting system

Update the DATA Act Business Process Guide to include documenting the data inventory/mapping for Files A, B, C, D1 and D2 to ensure that standardized data elements and OMB and Treasury definitions per the DATA Act Information Model Schema (DAIMS) are used across AmeriCorps business processes, systems, and applications; identify the appropriate source systems where the data resides; and identify gaps.

Work with ARC to ensure correct and complete Object Class and Program Activity codes are programmed in the source systems in accordance with OMB A-11, Section 83.

Establish and implement processes to reconcile and maintain adequate documentation of the reconciliation of the data file linkages. In addition, the processes should include performing monthly completeness, accuracy, and timeliness tests of the data elements using the Inspector General Guide as an internal control monitoring system.

Establish and comply with a timeliness standard for resolving DATA Broker warnings addressing data quality issues. Detailed corrective actions with milestones, deadlines, and responsible staff should be established.

Establish and implement effective internal control to ensure that adequate documentation is maintained and is readily available to support procurement contracts and financial assistance awards (grants).

Establish and implement controls to require that awardees (financial and procurement) register in SAM at the time of award.

Develop, document, and implement a process to ensure that de-obligations of grants with canceled funds are reported to Financial Assistance Broker System (FABS), when they occur and not when they are administratively closed-out.

We recommend that the SAO and EXIM’s DATA Act Working Group determine the root cause of the errors in EXIM-provided data identified during the testing of the second quarter FY 2021 Files D1 and D2, and take necessary corrective action to: (a) correct the errors for records shown in USASpending.gov; (b) identify the risk of reporting incorrect data for each data element containing the error; and (c) update the policies and procedures for recording data in Comprizon, FPDS, and FABS to address the risks and include adequate verification and validation review processes performed by the data owner and a supervisor…

We recommend that the SAO and EXIM’s DATA Act Working Group continue to improve the design of its review of the procurement award data in FPDS and financial assistance award data submissions to FABS by identifying the root cause for the exceptions in those data elements for which EXIM is responsible, and by developing more effective review procedures for those data elements, as well as the data elements that the SAO and DATA Act Working Group identify as having a high risk of not being accurate, complete, or reported timely.

We recommend that the SAO and EXIM’s DATA Act Working Group review EXIM’s policies and procedures for submitting contract award data in FPDS, including procedures for reviewing and confirming the accuracy of the CAR, to ensure proper design and compliance with FAR guidelines for timeliness. Update the policies and procedures based on this review, as necessary, to ensure EXIM meets FAR timeliness guidelines.

We recommend that the SAO in coordination with the OCFO continue to implement its corrective action plan to ensure that object class codes are accurately and completely reported in all financial and award data submissions (Files B and C).