Open Recommendations

OIG recommends that the Office of the Coordinator on Global Anti-Corruption (CGAC) develop and submit a Foreign Affairs Manual entry that establishes the offices organizational structure in accordance with Recommendations 1 and 2 and formally codifies CGACs roles, responsibilities, and reporting lines in its efforts to achieve national anti-corruption goals and objectives.

1. We recommend that the Chief Financial Officer and Assistant Secretary for Administration implement internal controls to ensure that changes in duty stations are initiated and processed timely.

2. We recommend that the Chief Financial Officer and Assistant Secretary for Administration review duty station changes processed since the return to office to determine whether untimely initiation or processing resulted in incorrect employee locality pay. Recover any excess salary amounts paid to employees in accordance with Departmental policy.

3. We recommend that the Chief Financial Officer and Assistant Secretary for Administration regularly track and determine whether all teleworking Department employees are meeting the schedule requirement for 2 days in the office per pay period. For employees failing to meet this requirement take action to ensure that the agency has assigned the proper locality pay and telework or remote work status to the employees and prevent or address any overpayment of salary amounts paid to the employees in accordance with Departmental policy.

4. We recommend that the Chief Financial Officer and Assistant Secretary for Administration implement internal controls to ensure employees are following the requirements of their telework or remote work agreements and temporary exceptions are properly documented.

Review and take appropriate action (for example, verify the beneficiaries’ vital status, input death information, terminate payment records, initiate recovery of improper payments) on the remaining cases in our population of 1,596 beneficiaries reported as deceased in State Department records.

Work with State Department officials and develop an electronic method to timely report death information for U.S. citizens who die abroad.

Work with State Department officials to timely forward reports of death abroad when State Department obtains a first-party report of death.

Ensure vulnerabilities are remediated within the Office of Information and Technologys established time frames. (This is a repeat recommendation from the prior site inspection.)

We recommend that USAID's Deputy Administrator for Policy and Programming: Direct the Bureau for Latin America and the Caribbean to develop and implement an action plan to ensure missions' compliance with Automated Directives System Chapter 206 and 303 requirements for pre-award risk management procedures that includes steps to make sure (a) overseas leadership at posts designated as covered countries are aware of their responsibility to implement and document compliance with Automated Directives System Chapter 206, including the determination process (i.e., post advance review), and (b) all signed certification and assurance statements required by Automated Directives System Chapter 303 Section 3.8…

We recommend that USAID's Assistant Administrator for the Bureau for Management: Direct the Office of Acquisition and Assistance to incorporate reference to USAID's Risk Appetite Statement and enterprise risk management guidance, including the seven-step risk management process found in Automated Directives System 596, into the agency's pre-award risk management procedures in Automated Directives System Chapter 303.

1. We recommended that the Department's Senior Procurement Executive and Director of Acquisition Management conduct an acquisition management review to assess the FirstNet Authority acquisition functions and determine if adequate contract files exist to properly support decisions.

2. We recommended that the Department's Senior Procurement Executive and Director of Acquisition Management review the actions taken to execute the contract and task order modifications identified in this report and determine whether, under law, Federal Acquisition Regulation (FAR) and/or Department policy, actions should be taken to review, revoke, or revise the warrants used to execute the modifications.

3. We recommended that the Department's Senior Procurement Executive and Director of Acquisition Management determine whether, in order to comply with applicable federal and Department regulations, FirstNet Authority should be required to submit all future contract awards and modifications to the Department for review prior to award.

4. We recommended that the Assistant Secretary of Commerce for Communications and Information and NTIA Administrator direct FirstNet Authority's Chief Executive Officer to ensure the required justification and pricing analysis are conducted and documented for all contract modifications to ensure compliance with FAR section 43.1.

5. We recommended that the Assistant Secretary of Commerce for Communications and Information and NTIA Administrator direct FirstNet Authority's Chief Executive Officer to ensure compliance with FAR section 32.104 by determining if (1) AT&T will not be able to bill for the first delivery of products for a substantial time after work must begin (normally 6 months) and (2) the expenses for contract performance during the predelivery period will have a significant impact on AT&T's working capital when using contract financing.

6. We recommended that the Assistant Secretary of Commerce for Communications and Information and NTIA Administrator direct FirstNet Authority's Chief Executive Officer to ensure compliance with Commerce Acquisition Manual 1301.71 and obtain legal reviews from the Department's Contract Law Division for all contract modifications when the services are materially changing.

7. We recommended that the Assistant Secretary of Commerce for Communications and Information and NTIA Administrator direct FirstNet Authority's Chief Executive Officer to leverage the remediation options in the contract to hold AT&T accountable and take the necessary actions to address deficiencies when AT&T is either not on track to meet or not meeting contract terms.

8. We recommended that the Assistant Secretary of Commerce for Communications and Information and NTIA Administrator direct FirstNet Authority's Chief Executive Officer to revise FirstNet Authority's Acquisition Review Board Review Process and Procedures to define what is considered a "significant modification" and to ensure results of ARB meetings are documented in compliance with FAR section 4.803.

9. We recommended that the Assistant Secretary of Commerce for Communications and Information and NTIA Administrator direct FirstNet Authority's Chief Executive Officer to ensure the Chief Procurement Officer provides oversight to verfy that contract modifications are sufficiently supported, justified, in compliance with the FAR, and in the best interests of the government and first responders.

Update the Bank Secrecy Act scope tasks and questions within the Modern Examination and Risk Identification Tool to ensure examiners complete and document all necessary steps during Bank Secrecy Act examinations and direct examiners to use additional external guidance such as the National Supervision Policy Manual, Examiner’s Guide, and Federal Financial Institutions Examination Council BSA/AML Manual, as needed.

Meet with the Financial Crime Enforcement Network (FinCEN), no less often than annually, to discuss the operation of the Memorandum of Understanding and to identify any issues or adjustments that may be required. Document any revised agreements and update the agency’s policies to communicate the FinCEN reporting requirements and information needed from the regions and the Office of National Examinations and Supervision.

Develop and implement an efficient process that ensures the completeness, accuracy, timeliness, and validity of information obtained from the agency’s Modern Examination and Risk Identification Tool, such as establishing reports, to meet the agency’s Bank Secrecy Act reporting objectives, including communicating information in accordance with the Memorandum of Understanding and other agreement(s) with the Financial Crimes Enforcement Network.

Revise the content of the NCUA’s Enforcement Manual to include current policies, procedures, and responsibilities for the NCUA’s formal enforcement actions and ensure its content is consistent with other agency policies. Regularly review this guidance for continued relevance and effectiveness in achieving the agency’s objectives.

We recommend that OPM issue an improper payment estimate for the Federal Employees Health Benefits Program's that will allow them to be in compliance with the four PIIA requirements for future reporting years.