Open Recommendations

1. We recommend that the NOAA Under Secretary of Commerce for Oceans and Atmosphere and NOAA Administrator ensure OCM program staff document deviations from the cooperative agreement's budget and awards.

2. We recommend that the NOAA Under Secretary of Commerce for Oceans and Atmosphere and NOAA Administrator implement a financial oversight process to ensure award recipients seek budget revision approvals for any changes to the approved budget categories.

3. We recommend that the NOAA Under Secretary of Commerce for Oceans and Atmosphere and NOAA Administrator ensure PRDNER obtains and retains all required documentation, including (a) all procurement documentation including sole-souce justifications and award decisions from General Services Administration, (b) notifications to NOAA of costs not included in the budget, and (c) approvals from the NOAA Grants Officer, when required.

4. We recommend that the NOAA Under Secretary of Commerce for Oceans and Atmosphere and NOAA Administrator collaborate with PRDNER, Puerto Rico's Office of Management and Budget, and the Office of the Administration and Transformation of Human Resources administrators to develop and implement a plan to hire sufficient staff, or consider subcontracting personnel, to resolve JBNERR's staffing challenges.

5. We recommend that the NOAA Under Secretary of Commerce for Oceans and Atmosphere and NOAA Administrator consider options for a split-operations award with a supporting entity to assist JBNERR in meeting its performance requirements.

Work with ARC to resolve the questioned costs totaling $5,000 for ARC funded personnel costs.

Work with ARC to resolve the questioned costs totaling $17,383 for ARC funded equipment costs.

Work with ARC to resolve the questioned costs totaling $14,956 for non-ARC match personnel costs.

Work with ARC to resolve the questioned costs totaling $40,400 for non-ARC match other in-kind costs.

We recommend the FSA Chief Operating Officer ensure that best practices are followed in maintaining the BPO masterschedule for the remaining transition activities, including updating schedules and tasks to reflect current progress,keeping task identification numbers and names consistent on updates to the master schedule, and maintaining aschedule narrative to provide an explanation of changes made to the master schedule.

We recommend the FSA Chief Operating Officer ensure that BPO vendor project schedules are reviewed for alignmentwith the FSA master schedule and with each other.

We recommend the FSA Chief Operating Officer ensure that FSA’s LMM is followed for the remaining phases to betransitioned, to include completing all required steps and documentation, maintaining required documentation, andobtaining required signatures for each stage gate before system release.

We recommend the FSA Chief Operating Officer ensure that each task in the master schedule has staff assigned to itwho will be responsible for ensuring that the task gets completed.

We recommend the FSA Chief Operating Officer ensure that FSA provides adequate staffing resources to the Next Genoffice to effectively transition assigned servicing and recovery activities to the BPO vendors.

We recommend the FSA Chief Operating Officer establish a baseline schedule for the specialty servicing transition assoon as possible now that transition timeframes have been established.

We recommend the FSA Chief Operating Officer continue to assess the SLA targets for non-servicing activities to ensurethey are realistic and achievable while also providing FSA and its customers FSA’s desired level of service.

We recommend the FSA Chief Operating Officer review specialty servicing and recovery related SLAs to ensure they arerealistic and achievable before the activities are transitioned to the BPO vendors.

We recommend that the Assistant Secretary for the Office of Finance and Operations ensure that the office ofAcquisition, Grants, and Risk Management develops and implements a process for ensuring that contractor,subcontractor, grantee and subgrantee employees are notified in writing of their whistleblower protections in thepredominant native language of the workforce.

We recommend that the Assistant Secretary for the Office of Finance and Operations ensure that Federal Student Aidand Contracts and Acquisition Management staff are aware of and adhere to applicable Department policy (e.g.,Acquisition Alerts) and FAR requirements and that the Department's contract review processes are following currentrequirements and policy.

We recommend that the Assistant Secretary for the Office of Finance and Operations include reference to 2 C.F.R.200.300, which includes a specific reference to the Section 4712, or other language highlighting a grantee's responsibilityto inform their employees of whistleblower protections, in new Grant Award Notifications, similar to the specific referenceincluded in contract awards.

We recommend that the Assistant Secretary for the Office of Finance and Operations ensure that the contracts noted inthe OIG's review that included the incorrect clause are updated.

We recommend the Executive Associate Director of Enforcement and Removal Operations assign an office responsible for managing and overseeing the risk classification assessment process.

We recommend the Executive Associate Director of Enforcement and Removal Operations establish and implement a formal policy and procedure for using the risk classification assessment process. The policy should include requirements for when officers should apply the risk classification assessment process and how officers should sufficiently document justifications to ensure the rationales for their decisions are clear, especially when deviating from the risk classification assessment’s recommended decision.

We recommend Senior Vice President, Power Operations, and the Vice President and Chief Information and Digital Officer, Technology and Innovation, develop a contingency plan for the operational technology at the site.

We recommend Senior Vice President, Power Operations, and the Vice President and Chief Information and Digital Officer, Technology and Innovation, complete the ongoing inventory project for the operational technology at the site.