Open Recommendations

Ensure Bechtel identifies all teaming arrangements, related entities, and affiliates needed to facilitate reviews for subcontractor unallowable fees on a regular basis.

Review Bechtel’s corrective actions for invoice review to validate implementation and effectiveness, and confirm that Bechtel has identified all unallowable fees that have been billed to the Department.

Evaluate the invoice review process for the depth and breadth required to make a complete and accurate review of the allowability, allocability, and reasonableness of invoice costs before payment.

Ensure that Bechtel follows its policies, procedures, and practices that allow subcontractors 30 or more days to respond to request for proposals unless a specific justification is documented.

Develop a policy or procedure to periodically evaluate whether the Department's practice of awarding terms that require payment in less than 30 days is in the best interest of the Government.

Ensure Bechtel identifies all teaming arrangements, related entities, and affiliates needed to facilitate reviews for subcontractor unallowable fees on a regular basis.

Evaluate the impact of contract time extensions on the self-performance percentage objective and its effect on the Subcontracting Plan goals, and adjust the contract (if appropriate);

Use the contract terms remaining in the contract to prompt Bechtel to meet the self-performance objective by encouraging and incentivizing more subcontracting;

Discuss the self-performance status with Bechtel, develop a mutual method of accurately calculating self-performance, and establish a plan to monitor the self-performance objective on a regular basis

Evaluate cyber risks associated with HEC assets to determine oversight and monitoring requirements, establish risk appetite, and address controldeficiencies. Consider using NASA’s Splunk enterprise platform as a shared resource.

Implement an HEC classification/category designation within Risk Information Security Compliance System for identifying HEC assets.

Document data risk impact levels, classification, and export control categorization for all HEC jobs.

Identify and mitigate gaps in the foreign national accreditation access process.

(U) Rec. 1.a: The DoD OIG recommended that the Commander of the U.S. Central Command develop minimum requirements for the U.S. Central Command End-Use Monitoring program manager's quarterly reviews of the Security Cooperation Information Portal to ensure the reviews include:
Reviewing enhanced end-use monitoring inventory and physical security inspection documentation.
Reviewing application of alternate procedures when in-person inventories and physical security inspections are not feasible.
Identifying and resolving deficiencies related to enhanced end-use monitoring.

(U) Rec. 1.b: The DoD OIG recommended that the Commander of the U.S. Central Command, in coordination with the Office of Security Cooperation-Iraq, develop a plan that could include using contractors to assist with the End-Use Monitoring program, filling the Office of Security Cooperation-Iraq End-Use Monitoring program manager position with a civilian, or expanding the authorities of the locally employed staff, to ensure continuity in the end-use monitoring program within the Office of Security Cooperation-Iraq.

(U) Rec. 2.c: The DoD OIG recommended that the Chief of the Office of Security Cooperation-Iraq, in coordination with the U.S. Central Command, develop and implement a plan that could include using contractors to assist with the End-Use Monitoring program, filling the Office of Security Cooperation-Iraq End-Use Monitoring program manager position with a civilian, or expanding the authorities of the locally employed staff, to ensure continuity in the End-Use Monitoring program within the Office of Security Cooperation-Iraq.

The Chief of Staff ensures providers complete the Comprehensive Suicide Risk Evaluation following a patient’s positive suicide risk screen.

The VA Maine Healthcare System Director verifies that patients identified as having suicidal ideations or behaviors have personalized safety plans documented in the electronic health record, and monitors compliance.

Develop and implement monitoring procedures to identify trends in sole-source purchasing. This could include (1) determining the specific reports that will be used for monitoring sole-source purchase orders, (2) establishing the frequency of the reports, and (3) identifying a list of individual directors and management officials who will receive reports. In addition, develop clear guidelines on what constitutes discrepancies and how they are identified, addressed, documented, and retained for future reference.

We recommend that HUD require the City to reassess the eight infrastructure projects still in the design or planning phase to determine whether the City can complete the projects or how the remaining funds could be best used within the 6 years remaining for the grant period to ensure that the City is protected from future storm and rain events.

We recommend that HUD require the City to for the $14,683,335 originally budgeted for the Milneburg and Microgrid projects, work with HUD to (1) determine whether its planned action plan amendment would constitute the need to submit a substantial action plan amendment, (2) ensure that any modifications in its action plan amendment would lessen the susceptibility of rain and flood events within the Gentilly area, and (3) require that any activities pursued under the action plan amendment could reasonably be expected to be completed by the September 30, 2029, deadline.

We recommend that HUD require the City to review the number and type of positions for its National Disaster Resilience staff that are responsible for the oversight and completion of infrastructure projects and ensure that it has the appropriate staffing levels to complete adequate monitoring and oversight of the projects.

We recommend that HUD require the City to revise its risk assessment plan and process to ensure that monitoring is regularly conducted for its infrastructure projects through project completion, including establishing a monitoring schedule to ensure the progression and completion of the infrastructure projects.

We recommend that HUD require the City to develop and submit to HUD for approval an updated planning and administration budget and staffing plan, after reassessing the infrastructure projects in recommendation 1A, to complete the National Disaster Resilience projects with the funds and within the timeframe remaining.

We recommend that HUD require the City to analyze the method used to charge planning and administration costs to ensure that all costs are applied to the correct costs category and are valid charges to the National Disaster Resilience grant.