Open Recommendations

To improve cooperation between FBI and HSI along the Southwest border, we recommend that FBI and HSI: Jointly develop a memorandum of understanding or similar written agreement governing Federal Bureau of Investigation and Homeland Security Investigations operations on overlapping criminal investigative areas.

Ensure DGCCVS revises and implements its policies and procedures for assessing the financial capability of the subgrantee applicants. DGCCVS should verify the applicant’s financial management responses from the AmeriCorps Readiness Self-Assessment.

Verify that DGCCVS revise its subgrantee monitoring procedures to ensure it complies with pass-through entity responsibilities for sub-recipients’ Single Audits and includes the following procedures:

Review the single audit report for all subgrantees with CNCS expenditures for each fiscal year for findings that affect CNCS grants to determine if DGCCVS records require an adjustment and take enforcement action against noncompliant subgrantees;

Develop a documented process to determine if subgrantees accurately presented CNCS awards on the Schedule of Expenditures of Federal Awards (SEFA);

Ensure DGCCVS implements a process to determine whether the results of the subgrantee’s audit or other monitoring indicate conditions that necessitate an adjustment to its own records; and

Retain documentation of DGCCVS monitoring and reviews of subgrantee audit reports, along with management decisions made or corrective actions implemented.

Require DGCCVS to revise its subgrantee monitoring procedures to include formal and timely subgrantee feedback to address: When the monitoring site visit took place; What the monitoring covered; The monitoring results; Required corrective actions; and Disallowed costs, if applicable.

Require DGCCVS to revise its subgrantee monitoring procedures to include formal reporting of follow-up conducted on any outstanding corrective actions.

Verify that DGCCVS is performing on-site monitoring of its subgrantees in accordance with its revised internal policies and procedures.

Verify DGCCVS has controls in place to ensure fees collected for grant-supported events were used to cover the cost of those events.

Verify DGCCVS used the fees collected for the event to reduce the Federal share charged to the grant or were used as match.

Ensures DGCCVS strengthens its monitoring to verify subgrantee compliance with CNCS best practices for member NSOPW check.

Confirm DGCCVS has established and implemented a procedure to have all staff involved in conducting subgrantee on-site monitoring to have a NSCHC.

Ensure DGCCVS revises its Program Director Handbook to include guidance on how to address and document a change in member living allowance when a member’s term is changed to ensure living allowance payments after conversion is correct.

Ensure DGCCVS strengthens its monitoring to verify subgrantee compliance with member living allowance requirements.

Work with DGCCVS to resolve the living allowance underpayments to DPR members.

Ensure DGCCVS strengthens its monitoring to verify subgrantee compliance with DGCCVS approval requirement for changes in a member’s term of service.

Ensures DGCCVS strengthens and implements its monitoring tools to verify subgrantee compliance with timekeeping requirements.

Require DGCCVS put procedures in place to ensure that DGCCVS is providing reporting guidance and reporting templates to the subgrantees before the end of the first month of the subgrantee’s program year and all subgrantees are reporting its costs in accordance with the DGCCVS Program Director Handbook.

Require DGCCVS to obtain PERs from DPR covering the Federal and match costs incurred during the program year 2017-2018 as of March 31, 2018, along with transaction-level detail, so that CNCS can test those costs for allowability.

Rec. 1.a: The DoD OIG recommended that the Secretary of Defense direct an organization or group to develop a risk-based approach to prioritize commercial off-the-shelf items for further evaluation.

Rec. 1.b: The DoD OIG recommended that the Secretary of Defense direct an organization or group to develop a process to test high-risk commercial off-the-shelf items.

Rec. 1.c: The DoD OIG recommended that the Secretary of Defense direct an organization or group to develop a process to prohibit the purchase and use of high-risk commercial off-the-shelf items, when necessary, until mitigation strategies can limit the risk to an acceptable level.

Rec. 2.a: The DoD OIG recommended that the Under Secretary of Defense for Acquisition and Sustainment update existing DoD acquisition policies or develop and implement new policy to require organizations to review and evaluate cybersecurity risks, including supply chain and counterintelligence risks, for high-risk commercial off-the-shelf items prior to purchase, regardless of purchase method.