Open Recommendations

We recommend that the Secretary for the U.S. Department of the Interior or a designee coordinate with the U.S. Department of Agriculture to assign responsibility for the required annual report and ensure that each annual report is completed and that all components required in the report are addressed after the publication of the performance metric mentioned in Recommendation 2, as established in IIJASection 40206(f), "Annual Reports."

Implement a baseline of technologies that sustain and do not erode privacy protectionsrelating to the use, collection, and disclosure of information.

Implement the EDR tool that was previously acquired for privacy protection.

Identify and implement other technologies that will bring the FCC into fullcompliance with the requirement for continuous auditing of compliance with statedprivacy policies and practices.

Update its business case for the MySBA investment in accordance with SOP 90 44 SBA Information Technology and Capital Planning and Investment Control Standard Operating Procedures.

Ensure the architecture review board reviews new investments to confirm compatibility with agency systems and ensure the Business Technology Investment Council approves new investments prior to purchase, as required by SOPs 90 52 1 and 90 44.

Ensure program offices create business cases prior to approval of the investment to ensure project scope, risks, and costs are fully vetted as required by SOP 90 44.

Update procedures to provide specific guidance to agency investment managers on how to utilize earned value principles to measure investment progress against both the current approved baseline and the original baseline for all major investments as required by SOP 90 52 1 and OMB Circular A-130.

Establish and implement controls to ensure all investments in the control phase are rated by the Chief Information Officer monthly using baseline factors, such as contractor cost oversight and schedule performance, and apply corrective measures as necessary as required by SOP 90 44.

Perform oversight procedures as required in OMB Circular A-11 and SOP 90 44. Specifically, ensure that post-implementation reviews, business case closeouts, TechStat sessions, operational analyses, and lessons learned are completed.

Rec. 1.b: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement), Deputy Assistant Secretary of the Navy (Procurement), Associate Deputy Assistant Secretary of the Air Force (Acquisition, Technology, and Logistics), and Defense Logistics Agency Acquisition Director require the contracting officers for the 35 open contracts identified in Appendix B to include sufficient documentation in the contract file to support the results of the reevaluation of financial responsibility.

Rec. 2.a.1: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director update and implement their Component policies to describe the types and extent of financial information required to document contracting officer financial responsibility determinations and to maintain the documentation in the contract file in accordance with the Defense Federal Acquisition Regulation Supplement 232.072-2.

Rec. 2.a.2: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director update and implement their Component policies to indicate that the Defense Contract Management Agency's Financial Capability Team is available to assist them in determining financial responsibility of prospective contractors.

Rec. 2.b: The DoD OIG recommended that the Deputy Assistant Secretary of the Army (Procurement); Deputy Assistant Secretary of the Navy (Procurement); Deputy Assistant Secretary of the Air Force (Acquisition, Technology and Logistics); and Defense Logistics Agency Acquisition Director issue a memorandum to the DoD contracting officers to advise them of the policy updates made in response to Recommendation 2.a.

Instruct its Office of Regional Operations to implement an oversight mechanism to ensure that the Commission: (a) Performs and documents the results of subgrantee risk assessments. (b) Performs and documents annual subgrantee monitoring activities. (c) Communicates subgrantee performance measures. (d) Evaluates subgrantee performance against communicated performance measures.

Require the Commission to provide subrecipients with further guidance on the nature of F&A costs and conduct training to ensure subrecipients claim and report F&A costs consistent with AmeriCorps’ Terms and Conditions.

Require the Commission to ensure MI provides detailed accounting records from its general ledger to support the costs reported in its PERs before the Commission reimburses MI for the costs. This requirement should remain in place until MI updates its general ledger accounting system to appropriately identify Federal funds received and expended, as required per Federal regulations.

Require the Commission to provide its subgrantees with additional training and guidance regarding how to appropriately exit members, including members with CPCs. This guidance should include procedures designed to ensure its subgrantees receive and maintain a detailed justification that documents the reason(s) for the member’s exit and verifies that the circumstances causing the member to exit represent an allowable CPC prior to certifying that the member is eligible for an education award.

Require the Commission and its subgrantees to implement additional internal controls and establish additional policies and procedures to ensure that they only charge allowable costs to AmeriCorps Commission support grants. The additional controls should ensure that: (a) The Commission and its subgrantees calculate all payroll expenses charged to AmeriCorps grants using a rate commensurate with the employee’s established salary and the level of effort the employee dedicated to the AmeriCorps program. (b) Employees understand how to document trip costs to demonstrate that costs did not increase due to combining personal and business travel.

Require the Commission to determine whether AmeriCorps members who served at MI in 2016 and 2019 should receive $20,794 in additional living allowance payments.

Require the Commission to verify that MI begin tracking its Federal awards and expenditures within its general ledger accounting system. Specifically, MI’s accounting system should enable MI to identify all Federal costs and match costs reported in the PERs submitted to the Commission.

AmeriCorps’ Office of General Counsel perform a comprehensive review of all Federal Statutes and Federal Regulations to identify inconsistent guidance, make appropriate corrections to the Federal Regulations, and provide the results to AmeriCorps OIG and AmeriCorps Office of Monitoring.

AmeriCorps issue consistent, direct, and transparent communication to all AmeriCorps grantees to provide clarification on the current matching requirements for member living allowance and member support costs.

Recover from YouthBuild $520,827 of education awards that were paid to members for subgrantees within the audit scope.

Require that YouthBuild pay the $3,087,791 outstanding AmeriCorps Education awards yet to be distributed to the members of subgrantees within the audit.