Open Recommendations

We recommend that the Administration for Children and Families provide training to program officials and contracting staff as appropriate that covers requirements for:

o administering nonpersonal services contracts for professional support services,
o specifying that contracts must not be used for the performance of inherently governmental functions,
o providing written consent for the use of subcontractors,
o reviewing and approving invoices, and
o maintaining documentation to support costs for services performed

We recommend that the Administration for Children and Families update its policies and procedures for receipt and oversight of deliverables and to incorporate Federal requirements related to the: (1) review, approval, and monitoring of invoices and (2) use of CLINs to properly account for and pay contractor expenditures.

We recommend that the Administration for Children and Families review potentially unallowable costs and obtain supporting documentation or take appropriate action to recoup from Deloitte any improperly paid amounts for the following:

o $2,022,468 for invoices that did not identify CLINs to track expenses,
o $1,362,621 in overtime charges,
o $1,226,649 of labor charges for invoices that did not include specific dates when each employee performed work,
o $244,174 in nonlabor costs that were not supported by receipts, and
o $112,945 of unsupported subcontractor charges

We recommend that the Administration for Children and Families review and correct potential Antideficiency Act violations by deobligating and obligating funds to appropriate CLINs used and report an Antideficiency Act violation if the violation cannot be corrected.

We recommend that the Administration for Children and Families develop and implement policies and procedures:
o requiring contracts to include FAR clauses related to overtime requirements in contracts
o for tracking and verifying that all contractor staff (including subcontractors) assigned to work on a contract complete required trainings before performing any work under the contract (or within the allowed time).

We recommended BHA develop and implement a process to determine the appropriate number of AORs needed for a given award portfolio based on factors including, but not limited to, the number of awards, amount of funding, and operating environment.

We recommend BHA develop and implement a process to regularly assess the completeness of required award documentation in ASIST and address identified gaps.

We recommend BHA update guidance for monitoring in nonpermissive environments to include criteria that trigger an assessment by BHA at the start of a response whether a country monitoring plan is necessary, and perform and document this assessment periodically, as applicable.

We recommend BHA establish a mechanism to enforce the use of guidance for monitoring in nonpermissive environments, to include assessing and determining the need for a third-party monitor and identifying and defining context-specific approaches to verify data.

We recommend BHA assess BHA's third-party monitor contracting processes and timelines, determine if adjustments are necessary to strengthen BHA's acquisition of third-party monitor support, and update BHA guidance accordingly.

We recommend BHA establish a mechanism to enforce BHA's use of internal guidance for Response Team Staffing to develop a DART staffing strategy for disaster responses.

We recommend BHA update BHA award language to clarify (1) the relationship with incident reporting requirements in USAID standard provisions and (2) ambiguous terminology related to reporting timeliness and incident impact.

We recommend BHA develop and implement a framework to address implementer noncompliance with BHA incident reporting requirements that defines response options and identifies triggers for escalation.

We recommend BHA develop and implement a process to ensure the storage and transfer of incident documentation between team files, Abacus, and ASIST, in accordance with BHA guidance.

Revise their policies and procedures to improve internal controls in place over maintenance of accounting records to ensure costs incurred for Federal awards are accurately recorded and supported by documentation prior to reporting financial information.

Work with ARC to resolve the questioned cost totaling $15,510 for A&E fees claimed as non-ARC matching cost.

Revise policies and procedures to ensure expenditures incurred and reported align with the approved scope of work and budget of the grant project.

Work with ARC to resolve the total questioned costs in the amount of $58,666 of non-ARC matching construction cost.

Implement policies and procedures to ensure that property records accurately reflect all required data elements included in the Uniform Guidance.

We recommend the Assistant Secretary for Employment and Training enhance and implement written policies or procedures to ensure H-2A applications have the correct wage information when certified by analysts.

We recommend the Assistant Secretary for Employment and Training enhance and implement written policies or procedures for post adjudication audits that target a representative number of applications appropriate for the level of risk in its application process.

We recommend the Assistant Secretary for Employment and Training enhance and implement written policies or procedures that provide specific guidelines to ensure analysts obtain sufficient evidence of payment of wages earned and expenses incurred.

We recommend the Assistant Secretary for Employment and Training enhance and implement written policies or procedures to ensure analysts provide a rationale and obtain sufficient evidence to document how they determine employers’ compliance with the program requirements reviewed.

We recommend that Indian Affairs develop and implement minimum standards for the operation of detention programs that are binding on both direct service and contract programs.

We recommend that Indian Affairs conduct risk-based Program Monitoring Reviews of all direct service and contract programs.