Open Recommendations

Proactively and independently initiate discussions with Legal Counsel on an at least quarterly basis in order to identify contingent liabilities which should be recognized and/or disclosed in the Corporation's financial statements and footnotes so that appropriate entries can be recorded, and/or notes disclosures prepared, prior to the finalization of the financial statements and footnotes.

Document the actions taken to verify that the information received is complete and whether information is needed from other sources to complete the financial reporting process.

Update the Corporation's standard operating procedures to incorporate timely inquiries of legal counsel during the preparation of the financial statements and footnotes.

STB management should amend its existing policy regarding the review and approval of journal vouchers to include a review of all non-reversing entries recorded during the fiscal year and to review all year-end journal vouchers before they are recorded in the agency's general ledger.

STB management should perform and document a review of all manual journal entries that includes a before and after analysis which illustrates the effect of the entry on the principal financial statements using the current year Treasury United States Standard General Ledger (USSGL) Section V Crosswalks to the financial statements. If accounts are presumed to offset, then they must offset within the same line of the same financial statement within the same fiscal year reporting period (i.e., before closing entries are recorded following the end of the fiscal year).

At least quarterly, STB management should initiate and document a review of all entries and account balances for which a manual correcting entry may be needed to address potential misstatements due to system posting logic, such as offsetting upward and downward adjustments of prior year obligations, and record the appropriate entries to prevent misstatement of financial statement accounts and line items.

During the review of manual journal vouchers, STB management should verify and document that the authoritative guidance and internal tools used to support the entry are valid and current.

The STB Finance Team should complete training relating to adjusting entries, including the selection of USSGL accounts, to improve the quality and precision of the review and approval process.

STB management should independently review the most current version of OMB Circular A-136 and the USSGL Treasury Crosswalks to identify changes in data elements, classification, and presentation and ensure that these changes are incorporated into financial statement and footnote templates for current year reporting. A search for new versions of the USSGL Crosswalks and OMB Circular A-136 should be performed each time the financial statements are prepared.

STB management should review the current version of OMB Circular A-136 to independently verify that all required footnotes are included and bring any omissions to the service provider's attention so that errors or omissions can be corrected.

STB management should review the service provider's Financial Statement and Notes Review Checklist to verify that the checklist is up to date and includes all required elements per OMB and Treasury guidance and then complete the checklist independently. Alternatively, STB management should develop and complete its own review checklist based on current Treasury and OMB reporting requirements.

STB management should request its financial management service provider to:
Reevaluate the inclusion of account balances that were excluded in the Other Liabilities footnote, or
Disaggregate (i.e., separately report) intragovernmental other liabilities balances reported as a single line item on the balance sheet that are not included in the footnote so that the total amounts reported for Other Liabilities on the balance sheet and in the footnote agree.

STB management should ensure that its review process includes procedures to disaggregate material balances reported in the financial statements and footnotes, agree balances to source documents, agree the footnotes to the principal financial statements, and verify the mathematical accuracy of all statements and schedules included in the financial statement package.

STB management's review and certification of the financial statements and footnotes should be clearly documented and indicate what was reviewed, when the review was performed, and who performed the review for each reporting period.

STB financial management should complete training relating to the preparation and/or review of financial statements and footnotes to improve management's understanding of Federal reporting requirements and to ensure that the financial statements and footnotes are complete, accurate, and appropriately presented.

STB should perform a review of 100 percent of employee benefit elections and Official Personnel Folders (OPFs) to ensure they are complete and accurate.

STB should develop policies and procedures that include the performance of periodic reviews of employees' OPFs to ensure that they are complete and accurate.

STB should address missing or unavailable supporting documentation with its shared service provider to ensure that document retrieval tools are available and are working properly to allow retrieval of all stored documents.

STB should obtain replacement documentation for employee forms and other documentation that have been determined to be incomplete or irretrievable from databases and other electronic sources following management's initial and periodic routine reviews.

STB management should implement and enforce its existing policies and procedures requiring the periodic review of all open obligations to ensure that closeout of completed contracts, including the de-obligation of funds and return of the balances for any advanced payments, is performed regularly and timely.

Clearly identify and publicly publish MSHA's jurisdiction, including obtaining any needed legal opinion from the U.S. Department of Labor Office of the Solicitor on the U.S. territories and the Federated States of Micronesia, the Republic of the Marshall Islands, and the Republic of Palau, requesting any needed legislative changes.

Revise MSHA's implementation plan for when it will begin inspecting mines within American Samoa, Guam, and the Commonwealth of the Northern Mariana Islands and begin implementing the plan. The revised plan should address: (1) when enforcement of the Mine Act and MSHA regulations will begin; (2) how inspections will occur in future years (e.g., travel from a specific MSHA district or setting up a field office nearby); (3) whether additional training will occur and how (e.g., in-person, virtual, hybrid, via grants, et cetera); and (4) how funding will be obtained to conduct required MSHA activities in FY 2025

Develop and implement a plan to enforce the Mine Act in the Federated States of Micronesia, the Republic of the Marshall Islands, and the Republic of Palau, having first obtained legal authority verifying they are still under MSHA's jurisdiction. If the legal authority opines MSHA has jurisdiction over them, MSHA's plan should address: (1) whether future legislative changes to the Mine Act are needed and requests to Congress; (2) when enforcement of the Mine Act and MSHA regulations will begin; (3) how inspections will occur in future years (e.g., travel from a specific MSHA district or setting up a field…

Verify mines within American Samoa, Guam, and the Commonwealth of the Northern Mariana Islands have properly submitted their Part 50 data to MSHA.

Update the status history for all mines within American Samoa, Guam, and the Commonwealth of the Northern Mariana Islands, including to reflect the periods for which they were operational. This should include adjustments needed after verifying the mines properly submitted their Part 50 data.