Open Recommendations

We recommend that the Acting Assistant Secretary of the Office of Management require the Privacy Office to revise processes for resolving FERPA complaints to ensure effective and appropriate communication with the complainant, to include providing dismissal notifications, updates, and responses to inquiries in a timely manner and recording all communication in the tracking system.

We recommend that the Acting Assistant Secretary of the Office of Management require the Privacy Office to design and implement a risk-based approach to processing and resolving FERPA complaints, where complaints deemed highest risk are prioritized. Risk can be evaluated based on the subject matter of the complaint, the severity of risk to student privacy, the number of students affected, or other relevant factors.

We recommend that the Acting Assistant Secretary of the Office of Management require the Privacy Office to review and evaluate its current policies and procedures for processing FERPA complaints to ensure they are complete and appropriate.

The process to determine and document CNCS’s balance fluctuation expectations should be based on a combination of internal and external operating factors, and program and financial relevant information available.Pending since FY 2017

The materiality threshold used to determine significant balance fluctuations that require further research should be more conservative than that used by external auditors and consistent with the materiality thresholds used by the OCRO (as part of the OCRO’s OMB Circular No. A‐123 assessment) to ensure integration and consistency between AFMS and OCRO.Pending since FY 2017

Detailed process to research significant balance fluctuations. CNCS should research and explain all significant balance fluctuations at the account and transaction level. Maintain and have the supporting documentation readily available.Pending since FY 2017

Address fatal and non‐fatal Government wide Treasury Account Symbol Trial Balance (GTAS) edit failures.Pending since FY 2017

Address all balance differences and retain supporting documentation of related research.Pending since FY 2017

Develop a plan to upgrade its financial system to include OC codes which should be associated with USSGL in accordance with OMB Circular No. A‐11.Pending since FY 2017

Provide mandatory training to CNCS accounting staff on the proper use of OC, sub general ledger accounts, and document/transaction types on all obligation and expense transactions.

tracking the sequence of SVs for completeness;

appropriate use of SVs;

determining and maintaining relevant documentation to support each SV;

use of specific and accurate SV descriptions;

review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation) and age are accurately reflected in the status of the obligation to confirm their validity;Pending since FY 2017

ensure obligations are sufficiently supported (i.e., by documentary evidence);Pending since FY 2017

perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved.Pending since FY 2017

Develop a succession plan to ensure the required expertise is available in the event of employee turnover. Such succession planning is key to helping CNCS continue achieving its internal and external reporting objectives. CNCS needs to:Pending since FY 2017

Train, mentor, and work to retain qualified employees;Pending since FY 2017

Institute continued cross‐training so that knowledge of the model will reside with multiple staff rather than with one person; andPending since FY 2017

Implement a peer review process to carry out the necessary quality control reviews of the TSAL model.Pending since FY 2017

Strengthen controls to ensure the TSAL modelling is performed by trained personnel to:

Conduct detailed analysis and validation of data sources;

Review and ensure the reasonableness of assumptions used and document the rationale behind these assumptions;

Consider changes in conditions or programs that require further research and analysis. Update the assumptions when necessary;