Open Recommendations

Work with the prime award recipients that had subaward reporting deficiencies to ensure that
their subaward information is reported or reported accurately.

Update and expand the guidance on FFATA subaward reporting requirements provided to prime
award recipients by (1) updating program website(s) with comprehensive information about FFATA,
(2) implementing training, (3) issuing formal communication, and (4) implementing a feedback
mechanism to ensure that all prime award recipients have the opportunity to share challenges with
HUD and ask questions.

Integrate FFATA reporting requirements into program monitoring procedures for all programs
and conduct regular reviews to assess compliance.

Ensure that programs with subaward activity include specific clauses related to FFATA
compliance in their grant agreements, and notices of funding opportunities.

Work with the prime award recipients that had subaward reporting deficiencies to ensure that
their subaward information is reported or reported accurately.

Update and expand the guidance provided to prime award recipients by (1) updating program
website(s) with comprehensive information about FFATA, (2) implementing training, (3) issuing
formal communication, and (4) implementing a feedback mechanism to ensure that all prime award
recipients have the opportunity to share challenges with HUD and ask questions.

Integrate FFATA reporting requirements into the program monitoring procedures for all
programs and conduct regular reviews to assess compliance.

Develop a policy or update the existing Grants Management Policy to include 1) the process and
controls that HUD will use to hold the prime recipients accountable for FFATA compliance and 2)
clearly defined roles and responsibilities between OCFO and the program offices to ensure that action
is prioritized by the correct responsible parties regarding FFATA compliance.

Work with applicable program offices to develop training materials and tools, such as dashboards,
to assist program offices in monitoring their grant portfolios for subaward reporting compliance.

(U) Rec. 1.a: The DoD OIG recommended that the Commander of the Security Assistance Group-Ukraine update contract work orders in coordination with contracting officers to standardize the information tracked by field service representatives for all weapons systems provided to the Ukrainian Armed Forces.

(U) Rec 1.b: The DoD OIG recommended that the Commander of the Security Assistance Group-Ukraine revise the Remote Maintenance and Distribution Center-Ukraine standard operating procedures or develop separate business rules that provide detailed validation guidance for repair part requests with specific criteria and rationale for disapproving requests.

(U) Rec. 1.c: The DoD OIG recommended that the Commander of the Security Assistance Group-Ukraine establish a formal agreement with the Ukrainian Armed Forces Logistics Command to provide routine updates on the inventory of the major assembly and controlled parts provided to them by the United States that they have as on-hand stock in their depots and warehouses.

(U) Rec. 1.d: The DoD OIG recommended that the Commander of the Security Assistance Group-Ukraine develop and implement a plan with actions and milestones to assist the Ukrainian Armed Forces in fully integrating an electronic, automated, supply management system that provides the Ukrainian Armed Forces with the capability to efficiently and routinely provide the DoD with the status of on-hand, U.S., repair part stock.

(U) Rec. 1.e: The DoD OIG recommended that the Commander of the Security Assistance Group-Ukraine establish a formal agreement with the Ukrainian Armed Forces to return a designated list of recoverable parts, including timely U.S. Government provision of return receipts, and implement validation procedures that would cause the rejection of requests for these same parts if the Ukrainian Armed Forces has an excessive quantity (as defined by Security Assistance Group-Ukraine) that it has not sent back for turn-in credit or repair.

We recommend that the Deputy Secretary update policies and procedures to provide additional clarification to help supervisors and employees work through each step in the reasonable accommodation process, such as clarifying supervisors’ responsibilities when a request is first received, when a medical review officer assessment is requested, when an interim accommodation is provided, when extenuating circumstances or delays exist, and when a decision is made.

We recommend that the Deputy Secretary require OEEOS management to research reasonable accommodation policies and procedures of other Federal agencies to identify and adopt best practices to improve the clarity, transparency, and efficiency of the Department’s reasonable accommodation policies and procedures.

We recommend that the Deputy Secretary ensure that reasonable accommodation materials and guidance, including training materials, are readily available and are consistent with Department policies and do not establish additional requirements beyond what is in Department policy.

We recommend that the Deputy Secretary require OEEOS to hold or offer periodic refreshers or trainings on the reasonable accommodation program in addition to mandatory, online trainings, to encourage the proper handling and processing of reasonable accommodation requests.

We recommend that the Deputy Secretary establish a formal process for the Department and FSA to coordinate the administration of their respective reasonable accommodation programs, to include ensuring that FSA is aware of Department policy and that any additional program guidance developed by FSA is consistent with Department policy.

We recommend that the Deputy Secretary ensure Department policy is followed regarding reasonable accommodation requests from applicants, to include determining whether requests are associated with a qualifying disability, and that the Program Manager is not in a decision-making role.

We recommend that the Deputy Secretary develop an appropriate system for documenting all reasonable accommodation requests in a manner where the documentation is complete, organized, and readily available for examination.

We recommend that the Deputy Secretary assess whether OEEOS has allocated sufficient resources and assistance to the reasonable accommodation program and make changes as appropriate.

We recommend that the Deputy Secretary direct the Program Manager to develop and implement a tracking system that includes appropriate data validation checks and captures all of the information the Department is legally required to track and report.

We recommend that the Deputy Secretary ensure the Program Manager is populating the tracking system with dates that comply with definitions established in policy (e.g., request dates; provision dates).

We recommend that the Deputy Secretary develop and implement the use of a form that supervisors are required to complete and submit to the Program Manager within a specified timeframe after a reasonable accommodation request is received to assist with ensuring the Program Manager is notified of all requests and captures needed data for tracking and reporting purposes.