Open Recommendations

Direct Clemson to strengthen its directives, procedures, and internal controls for procuring contract services on sponsored projects. Updated processes could include the following: a. Conducting annual training for those individuals who procure contract services, including Principal Investigators. The training should include topics such as the process for obtaining approvals for contractors on sponsored programs, the documentation needed before work begins, and the purchase order process required before issuing payment. b. Requiring individuals who initiate contract services to complete the applicable information in the appropriate procurement forms, as required by Clemson policy for contracted service agreements on sponsored projects.

Direct Clemson to strengthen its procedures and internal controls for reviewing account codes that are required to incur indirect costs. Updated procedures could include an annual indirect cost reconciliation.

Direct Clemson to update its current award set-up practices to require that, when setting up accounts established for NSF awards, personnel ensure that the accounts apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of the NSF grant award (except in instances where the award letter or supplement letter specifies otherwise), rather than using the rates included within the original grant proposal.

Direct Clemson to require its subawardees to apply indirect costs using the rates that were established in the Negotiated Indirect Cost Rate Agreement in effect as of the date the subaward was granted, rather than using the rates included within the subaward budget and proposal.

Clarify officer safety-related training requirements for operational personnel, including Task Force Officers, and ensure that the requirements are clearly established in policy.

Ensure that the Training Division provides consistent and prompt assistance to those districts that do not have an assigned Tactical Training Officer.

Ensure that all Tactical Training Officers receive skills sustainment training.

Establish methods to evaluate whether the Tactical Training Officer Program is accomplishing its objectives.

Ensure that the new After-Action Review policy is implemented so that all critical incidents stemming from operations led by and/or involving U.S. Marshals Service personnel are reviewed for lessons learned and used to update and adjust officer safety-related training.

Consider including other Department of Justice law enforcement components in operational reviews of critical incidents, including but not limited to the new After-Action Review process, to allow for mutual awareness and improvements to officer safety-related training across components.

Evaluate whether modifications to training are needed to adequately cover open space encounters and to better support small teams, and, if so, develop and implement methods to ensure that training adequately addresses these.

Update and implement EXRM directives, policies, and procedures regarding position designation to reflect current EXRM operations and address current OPM policies and guidelines.

Develop and maintain an accessible database with all information required to effectively manage the position designation and suitability program. At a minimum, this system should contain the name of the employee or contractor, position number and title, position designation, tier of background investigation completed, entry-on-duty date, date the background investigation was requested, date the background investigation was completed, whether it was an initial investigation or reinvestigation, whether reciprocity was applied, and reinvestigation due date.

Use the information developed in Recommendation Two to track an employee’s investigation versus the designation of their position and ensure they are properly aligned.

Use an automated tool to track when employee and contractor reinvestigations are due.

Update the investigations of employees whose completed investigation has exceeded the five-year reinvestigation requirement.

Allocate the appropriate resources going forward to ensure that all reinvestigations are initiated on or before the due date.

Establish a process to include Office of Human Resources Management during the drafting of the statement of work to determine the appropriate investigative tier for contractors prior to when the request for quotes is released to potential vendors.

Develop a formal documented process (directive or standard operating procedure) for onboarding contractors.

Develop a system to communicate any changes in the onboarding process to contracting officer’s representatives and other personnel involved in the onboarding of employees and contractors.

Develop and document a systematic and repeatable risk assessment process to evaluate the risk of applying reciprocity for incoming contractors.

Regarding contractors, develop and maintain an accessible database containing the information outlined in Recommendation Two, as well as the contract number, similar CPSC position, contractor name, employer, and name of contracting officer’s representative.

Complete the work required to fully implement OPM’s recommendations from 2017.

The Bureau of Overseas Buildings Operations, in coordination with the Bureaus of European and Eurasian Affairs, Near Eastern Affairs, and Western Hemisphere Affairs, should bring principal officer residential swimming pools at Embassies Cairo, Madrid, and Quito, and Consulate General Hamilton into compliance with Department swimming pool safety standards.

We recommend that the National Heart, Lung, and Blood Institute strengthen its internal controls for OTs by updating its policies and procedures to require that OT justification memos be signed, dated, and written or developed with involvement from appropriate parties, including OT Agreements Officers.