Open Recommendations

We recommend the TSA Chief Information Officer direct the selected High Value Asset system owner to review and document the approval of all privileged users’ system access before granting system access. In addition, privileged users’ system access should be reviewed and removed according to applicable DHS and TSA requirements if it is no longer needed.

We recommend the TSA Chief Information Officer require the selected High Value Asset system owner to develop and implement procedures to remove system access for separated users.

We recommend the TSA Chief Information Officer direct the selected High Value Asset system owner to require all system users sign Computer Access Agreements to acknowledge the rules of behavior when accessing the system.

We recommend the TSA Chief Information Officer direct the selected High Value Asset system owner to enforce users to receive security awareness training when they are given system access and annually thereafter.

We recommend the TSA Chief Information Officer direct the selected High Value Asset system owner to strengthen its system-level Information Security Continuous Monitoring by ensuring (1) security documents contain current and accurate information about the system; (2) relevant policies and procedures are developed, reviewed, and approved; and (3) Plans of Action and Milestones are remediated promptly and include all required information.

We recommend the TSA Chief Information Officer require the selected High Value Asset System’s Contingency Plan and Contingency Plan Test to be reviewed and approved in accordance with DHS and National Institute of Standards and Technology guidance.

We recommend that the Chief Operating Officer for Federal Student Aid (FSA) require USC to— 1.1 Calculate the actualamount of improper Pell and any other Title IV payments made to the 13 students for whom it did not apply professionaljudgment other than dependency override in accordance with section 479A of the HEA and return those funds to theDepartment.

We recommend that the Chief Operating Officer for Federal Student Aid (FSA) require USC to— 1.2 Review its records forthe 6,062 students for whom the school reported that it applied professional judgment other than dependency override foraward year 2019–2020 or award year 2020–2021 but were not included in our sample and (a) identify those students forwhom it improperly adjusted the value of data items affecting AGI based on allowances or expenses unrelated to specialcircumstances, (b) provide FSA with a listing of the improperly disbursed Title IV funds and the records associated withthose students for whom financial aid administrators improperly applied…

We recommend that the Chief Operating Officer for FSA require USC to— 2.1 Review its records for the 6,162 studentsfor whom the school reported that it applied professional judgment other than dependency override for award year2019–2020 or 2020–2021; identify records adequately documenting the use of professional judgment; and provide therecords for any students with inadequately documented professional judgment to FSA along with a listing of the amount ofTitle IV funds, if any, that were improperly awarded and disbursed to students.

We recommend that the Chief Operating Officer for FSA require USC to— 3.1 Provide additional records that adequatelydocument the financial aid administrators’ determinations of independence for the six students or return to the Department$3,700 in Pell funds and $26,200 in Direct Loan funds.

We recommend that the Chief Operating Officer for FSA require USC to—Review its records for the 81 students notincluded in our sample; identify records adequately documenting the financial aid administrators’ determinations ofindependence; and provide the records for any students with inadequately documented dependency override to FSA alongwith a listing of the amount of Title IV funds, if any, that the school improperly awarded and disbursed to the students.

We recommend that the Chief Operating Officer for FSA require USC to— 4.1 Develop and implement procedures forconfirming that its student information system data are corroborated by its financial assistance records before reportingthe use of professional judgment to the Department’s Central Processing System.

We recommend that the FEMA Administrator resolve questioned costs totaling an estimated $24,438,662 for expenses deemed ineligible by FEMA’s Individual Assistance Program and Policy Guide and determine the amount of any debts owed by recipients for erroneous payments.

We recommend that the FEMA Administrator ensure that future iterations of the Individual Assistance Program and Policy Guide and supporting procedures (a) provide consistent guidance on eligibility of funeral expenses for all future disaster declarations; and (b) allow for reimbursement of only necessary expenses and serious needs, consistent with the law.

We recommend that the FEMA Administrator ensure that FEMA provides its COVID-19 Funeral Assistance call center contractor the guidance and training necessary to meet the quality control and production monitoring metrics as prescribed by its agreement with the contractor.

We recommend that the Office of Insular Affairs work with the U.S. Virgin Islands Department of Finance to revise the Department of Finance Standard Operating Procedure 604 to include all methods of allocating compensation costs by documenting responsibilities and procedures for determining the allocation.

We recommend that the Office of Insular Affairs work with the U.S. Virgin Islands Department of Finance to develop and implement written procedures for determining cost allowability and for reviewing drawdown requests.

The OIG recommended the under secretary for benefits modify policies and procedures for full-file loan reviews to include detailed steps for loan specialists to conduct reviews, as well as the risk factors and methodology for loan selection.

The OIG recommended the under secretary for benefits develop and update policies and procedures to ensure invoices or bills are obtained for all third-party charges and lenders report itemized closing costs at the lowest level of detail.

The OIG recommended the under secretary for benefits develop and update policies and procedures for the state deviation process and requirements, assess the extent of missing VA authorizations on the schedule of state deviations and obtain the necessary documentation, and obtain a legal opinion from the VA’s Office of General Counsel on the allowability of state deviation charges in excess of the state-published amounts, and then review the potential overcharges identified in the audit sample to determine if action is needed to make the borrowers whole.

The OIG recommended the under secretary for benefits modify policies and procedures for full-file loan reviews to include detailed steps for loan specialists to conduct reviews, as well as the risk factors and methodology for loan selection. 9. Update policies and procedures to ensure the borrower is reimbursed for any overcharges identified during regional loan center quality reviews.

We recommend the Executive Associate Director for Homeland Security Investigations develop and implement a work plan detailing prioritized upgrades to the Repository for Analytics in a Virtualized Environment, Data Analysis & Research for Trade Transparency System, estimated funding requirements for those upgrades, and timelines for implementing the upgrades. The upgrades should include processes to achieve program objectives and respond to program risks such as capabilities to facilitate identifying trade-based money laundering transactions.

We recommend the Executive Associate Director for Homeland Security Investigations conduct an analysis of the Trade Transparency Unit workforce to determine the number of full-time staff needed to accomplish the unit’s mission and convey those requirements to the Office of the Chief Financial Officer for future funding consideration.

(U) Rec. 1.a: Recommendation is Classified.

(U) Rec. 1.b: Recommendation is Classified.