Open Recommendations

Require that SGC provide Sanctuary with the requirements of an adequate financial management system and ensure that Sanctuary implements an adequate system. The documentation provided should include guidance on how to determine the allowability of grant costs claimed and accounting for both Federal and match costs.

Require Serve Guam Commission to submit an updated Financial Federal Report for the 14AH award that removes the $18,761 of questioned match costs.

Require SGC, as part of its subgrantee monitoring processes, to perform periodic testing of subgrantees’ other direct costs to ensure that they incurred and claimed all costs in accordance with grant provisions, laws, and regulations.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to support the appraised fair market values of the 14 properties sampled to ensure that $5,920,097 in settlement costs was supported. This recommendation includes but is not limited to providing support to show that appraisals contained accurate and verified information for the subject and comparable properties, time adjustments were supported, and other adjustments were supported.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to support the appraised fair market values of the 942 other properties included in our sampling universe to ensure that $361,465,173 in settlement costs was supported. This recommendation includes but is not limited to providing support to show that appraisals contained accurate and verified information for the subject and comparable properties, time adjustments were supported, and other adjustments were supported.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to strengthen controls over the property valuation process for its program to ensure that up to $93,350,616 not yet disbursed is put to better use.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to show that $3,119,209 paid for appraisals and poststorm addenda performed by its contractor was reasonable, supported, and for services that were performed in accordance with applicable requirements or reimburse any unsupported costs from non-Federal funds.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to show that $156,940 paid for sales brochures, economic land analysis studies, and consultant fees was reasonable, necessary, supported, and for services that were performed in accordance with applicable requirements or reimburse any unsupported costs from non-Federal funds.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to provide documentation to show that $75,006 used for appraisal quality control reviews was for services that complied with applicable requirements or reimburse any unsupported costs from non-Federal funds.

We recommend that HUDs Deputy Assistant Secretary for Grant Programs require the State to strengthen controls to ensure that future Disaster Recovery funds used for appraisal services and quality control reviews under the program are for costs that are reasonable, necessary, supported, and for services that comply with applicable requirements.

Reassess the process of isolating key project personnel from instrument selection to balance their additional insight in integration and cost estimation while maintaining fairness in the announcement and mitigating conflicts of interest risks.

Develop and implement a process for periodically assessing force account risk. Based on the risk assessment, develop and implement procedures for overseeing compliance with Federal force account regulations.

Revise force account guidance for the States to clarify when cost-effectiveness determinations are required.

Develop and implement a process for determining when force account can be used for work performed outside the Federal highway right-of-way without complying with Federal requirements.

We recommend the DHS Office of the Chief Security Officer review DHS logon banners for unclassified systems at all components and determine whether they are legally sufficient.

We recommend the DHS Office of the Chief Security Officer determine, with the aid of the Office of Program Accountability and Risk Management, whether the expanded ITP is an acquisition program, what level of acquisition program it is using a Rough Order Magnitude or other Cost Estimate, and where the program is in the Acquisition Life Cycle. Determine, along with the Office of Program Accountability and Risk Management, the acquisition documentation required for the Acquisition Life Cycle Framework phase the program is in.

We recommend the DHS Office of the Chief Security Officer work with the Office of Program Accountability and Risk Management to complete the required Systems Engineering Life Cycle Framework.

For the estimated $2,979,377 overpayment for all claims outside of the Medicare reopening period, exercise reasonable diligence to identify and return overpayments in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation

Exercise reasonable diligence to identify and return any additional similar overpayments outside of our audit period, in accordance with the 60-day rule, and identify any returned overpayments as having been made in accordance with this recommendation

Rec. B.2: The DoD OIG recommended that, once the DoD issues its instruction, the Secretaries of the Army, Navy, and Air Force update the cemetery regulations accordingly.

The Executive Committee should develop a comprehensive agency-wide process for maintaining, monitoring and reporting on unapplied cash to ensure that all unapplied cash items are properly identified, recorded, monitored, reconciled, investigated, and resolved.

The Office of Programs should update all control documentation (including policies and procedures, charts of controls, and other related documentation) to reflect the changes that occurred to unapplied cash as a result of the migration to the Financial Management Integrated System.

The Office of Programs should test the updated unapplied cash controls to ensure that they are present and operating as intended.

The Office of Programs should work with the Railroad Retirement Board’s Bureau of Information Services to implement Overpayment Recovery Correspondence System modifications to ensure that unapplied cash historical files [carried over from prior years, and receipts disposed of (applied to debt)] are maintained for completeness and accountability.