Open Recommendations

Embassy Brazzaville should repair its high-frequency radio and conduct monthly checks in accordance with Department standards.

Embassy Brazzaville should establish and register a local Information Technology Configuration Control Board in accordance with Department standards.

Embassy Brazzaville should implement a records management program that complies with Department standards.

Ensure the appropriate individuals are trained through a structured ERM program training to increase knowledge and understanding throughout the organization and share key takeaways and materials with employees at all levels to effectively contribute to the organization’s program success.

Assess and update the Commission’s existing policies and procedures to ensure compliance with federal requirements and that the policies and procedures reflect the processes that it wants to adopt.

Research and adopt an appropriate ERM maturity model.

Develop and implement effective key controls that identify risks and assign the Commission’s risk tolerances by aligning each control objective with the appropriate control activity and completing an updated entity-level control and results assessment.

Include a process in the ERM program to include documenting management’s determination of key process decisions for its other process considerations.

Develop and implement a process for tracking the consolidation of risks.

Enhance risk assessment procedures to enable proper identification of processes and controls over Guarantee Loan Cancellations to insure all loans canceled in [redacted language] are completely and accurately recorded in [redacted language].

Reinforce controls over the review of the subsidy rates inputted into [redacted language] to address gaps identified in this NFR.

Enhance processes and controls over insurance cancellations to ensure all transactions are recorded by [redacted language] and are completely and accurately recorded in [redacted language].

We recommend that EXIM management design and implement monitoring controls to help ensure that password configurations for the [redacted language] are in compliance with the Standard Operating Procedures for [redacted language] Procedures and NIST SP 800-53, Revision 5.1, Release 5.1.1.

We recommend that EXIM management design and implement monitoring controls to help ensure that access to develop and implement changes into production is appropriately segregated.

Treasury OIG should follow-up with Kiowa's management to confirm if the $6,919,819 in Contracts greater than or equal to $50,000 payment type are recouped or replaced by other eligible expenditures, not previously charged to CRF, that were incurred during the period of performance. Further, based on Kiowa's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace unsupported transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for the Contracts greater than or equal to $50,000 payment type.

Treasury OIG should follow-up with Kiowa's management to confirm if the $62,744 in Contracts greater than or equal to $50,000 payment type are recouped or replaced by other eligible expenditures, not previously charged to CRF, that were incurred during the period of performance. Further, based on Kiowa's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace unsupported transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for the Contracts greater than or equal to $50,000 payment type.

Treasury OIG should follow-up with Kiowa's management to confirm if the $727,002 in Contracts greater than or equal to $50,000 payment type are recouped or replaced by other eligible expenditures, not previously charged to CRF, that were incurred during the period of performance. Further, based on Kiowa's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace unsupported transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for the Contracts greater than or equal to $50,000 payment type.

TOIG should follow-up with Kiowa's management to confirm if the $124,535 noted as ineligible expenditures within the Contracts greater than or equal to $50,000, payment type are recouped or replaced by other eligible expenditures, not previously charged to CRF, that were incurred during the period of performance. Further, based on Kiowa's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace ineligible transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for the Contracts greater than or equal to $50,000 payment type.

Treasury OIG should follow-up with Kiowa's management to confirm if the $1,832 in Aggregate Reporting less than $50,000 payment type are recouped or replaced by other supported expenditures, not previously charged to CRF, that were incurred during the period of performance. Further, based on Kiowa's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace unsupported transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for the Aggregate Reporting less than $50,000 payment type.

Treasury OIG should follow-up with Kiowa's management to confirm if the $38,162 noted as unsupported expenditures within the Aggregate Payments to Individuals payment type are recouped or replaced by other eligible expenditures, not previously charged to CRF, that were incurred during the period of performance. Further, based on Kiowa's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace ineligible transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for Aggregate Payments to Individuals.

Treasury OIG should follow-up with Kiowa's management to confirm if the $1,860 noted as ineligible expenditures within the Aggregate Payments to Individuals payment type are recouped or replaced by other eligible expenditures, not previously charged to CRF, that were incurred during the period of performance. Further, based on Kiowa's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace ineligible transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for Aggregate Payments to Individuals.

Treasury OIG should follow-up with Kiowa's management to confirm if the $654,200 noted as ineligible expenditures within the Aggregate Payments to Individuals payment type are recouped or replaced by other eligible expenditures, not previously charged to CRF, that were incurred during the period of performance. Further, based on Kiowa's responsiveness to Treasury OIG's requests and its ability to provide sufficient documentation and/or replace ineligible transactions charged to CRF with valid expenditures, Treasury OIG should determine the feasibility of conducting an audit for the Contracts greater than or equal to $50,000 payment type.

Treasury OIG should follow-up with Kiowa's management regarding the remaining $12,678 of attorney's fees expenses within the Contracts greater than or equal to $50,000 payment type not tested during Castro's desk review to determine if there are additional unsupported or ineligible questioned costs.

Treasury OIG should determine the feasibility of following up with Kiowa over the $579,443 of additional hardship payments to determine whether these amounts charged to the CRF included previously budgeted expenditures and, if so, Castro recommends Treasury OIG recoup the funds or request that Kiowa's management provide support for eligible expenditures, not previously charged to CRF, that were incurred during the period of performance.

Treasury OIG should follow-up with Kiowa's management to request they perform an analysis over its Aggregate Reporting less than $50,000 payment type claimed costs to determine if there are any additional hardship payments included within that payment type. Based on the results of this assessment, Treasury OIG should consider the feasibility of performing additional testing over these balances.