Open Recommendations

Implement procedures and controls for collecting and reconciling information contained in its performance reports by developing protocols for collecting required data, handling system failures, and resolving discrepancies to ensure that all performance reports are accurate, verifiable, and reviewed before release to ORR.

Work with ORR to develop allowable methodologies to allocate salaries, develop a procedure or system to capture what programs each employee actually worked on, and determine what portion of the $1,500,218 in salaries charged based on budget estimates was accurately charged to the UAC program and refund to the Federal Government any unallowable portion

Work with ORR to determine an allocation methodology or plan to claim shared direct expenditures in proportion to benefits received, develop a policy to reflect this methodology or plan, determine whether any of the $1,352,027 in direct expenditures and up to $235,253 in related indirect expenditures allocated using the unreasonable allocation ratio was allowable, and refund to the Federal Government any unallowable portion

Develop policies and procedures for identifying allowable shared UAC program costs, including items that need advance approval, determine whether any of the $210,037 in potentially unallowable and $23,390 in potentially unallowable unapproved expenditures would be allowable under the newly approved allocation methodology or plan, and refund to the Federal Government any unallowable or unapproved portion

Develop policies and procedures for identifying shared UAC program costs not in compliance with Federal requirements and refund $10,336 in unallowable employee appreciation expenditures

Develop policies and procedures for identifying direct UAC program costs not in compliance with Federal requirements and refund $6,515 in unallowable expenditures not related to the UAC program

Develop policies and procedures for claiming indirect expenditures based on the approved indirect cost rate.

Assess, confirm, and recover the previously issued improper WHIP payments of $4,268,395 to program participants.

We recommend that the Executive Committee reconsider the need for all Railroad Retirement Board employees to have the mobile phone and the related recurring costs.

We recommend that the Executive Committee obtain state wage and unemployment data in a timelier manner in order to match with CARES Act Railroad Retirement Board payments; thereby identifying potential fraudulent CARES Act payments quicker and increasing program integrity.

In coordination with all EPA regions, ensure that guidance and planning address deployment of on-scene coordinators in the event of large incidents during pandemics, including overcoming travel restrictions to respond to large incidents.

Develop and implement a plan to coordinate relevant Agency program, regional, and administrative offices with the External Civil Rights Compliance Office to develop guidance on permitting and cumulative impacts related to Title VI.

Develop and implement a plan to complete systematic compliance reviews to determine full compliance with the Title VI program.

Verify that EPA funding applicants address potential noncompliance with Title VI with a written agreement before the funds are awarded.

Determine how to use existing or new data to identify and target funding recipients for proactive compliance reviews, and develop or update policy, guidance, and standard operating procedures for collecting and using those data.

Develop and deliver training for the deputy civil rights officials and EPA regional staff that focuses on their respective roles and responsibilities within the EPA’s Title VI program.

Complete and publish a document describing lessons learned after the BRT completes its work related to this breach.

Annually update and require refresher training for all Clearinghouse staff on the use of the data extraction tool and policies and procedures for accomplishing Clearinghouse work, up to and including the AED for EPHA.

Develop, disseminate, provide training, and implement policies and procedures on how to use this new data extraction tool to all Clearinghouse staff, up to and including the AED for EPHA. These policies must include step-by-step instructions and checklists to aid staff in completing routine tasks. These policies must include guides and checklists for supervisory review of Clearinghouse staff work.

Determine, document, and implement a structure for the Clearinghouse.

Implement the recommendations from the Human Resources study.

FDA should use the new TIRF REMS patient registry to monitor for known areas of risk, such as inappropriate conversions and off-label prescribing.

FDA should strengthen the REMS for opioid analgesics (the successor to ER/LA opioids) by requiring prescriber training.

FDA should enhance its REMS assessment review process.

FDA should seek additional authority to ensure that manufacturers are held accountable when appropriate.