Open Recommendations

the correct use of the Business Event Transaction Codes (BETC) when submitting transactions to Treasury.

Develop and implement financial reporting internal controls to analyze and address the root causes of the need for journal entries and the corrective actions in financial management systems to reduce the necessity of future journal entries.

Verify and validate the underlying input data to the TOLM.

After the verification and validation, reassess its assumptions and consider expanding the subjective elements of the calculation (i.e., those based on changes to the economy and the job market) to include changes in the way awards are utilized.

Resolve the $5,000 in questioned inadequately supported service expenses for which UM has not agreed to reimburse NSF and direct UM to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct UM to strengthen its policies and procedures related to creating and retaining documentation, including introducing additional internal controls to help ensure that it appropriately creates and maintains all documentation necessary to support the allowability of expenses charged to sponsored programs. These additional internal controls could include: - Updating its current external service provider procedures to require that UM establishes formal agreements with external service providers which identify the period of performance, scope of work, compensation rate(s), and applicable terms and conditions when providing services that are greater than $5,000. - Updating its current purchasing policies and procedures to ensure…

Direct UM to strengthen its administrative and management controls and processes for supporting the allocation of expenses to sponsored projects. Updated processes could include: Requiring Principal Investigators or other designated staff to both document and justify the allocation methodologies used when charging expenses to sponsored projects near their grant expiration dates. - Implementing a standard documentation andretention process to support the allocation of costs that benefit multiple awards.

Direct UM to provide training on how to assess and document the methodology used to allocate publication costs across each sponsored award acknowledged in the publication.

Resolve the $8,750 in questioned materials and supplies and lodging expenses for which UM has not agreed to reimburse NSF and direct UM to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct UM to implement additional controls or procedures that ensure costs incurred after an award’s period of performance has expired are not charged to NSF awards.

Direct UM to strengthen its administrative and management processes and procedures surrounding lodging reservations. Specifically, UM should implement additional pre-travel requirements that ensure travelers are reserving rooms at lodging rates that are at or below the General Services Administration rates, as required by UM’s Lodging Travel Policy.

Direct UM to establish clear guidance regarding the allowability of publication expenses on sponsored projects, including the requirement to acknowledge NSF funding sources.

Direct UM to update its grant close out procedures to require that appropriate personnel verify all participant support cost funds were used to cover participant support cost expenses.

Direct UM to strengthen its administrative and management procedures regarding its equipment purchase process to ensure personnel verify, and document that they verified, that equipment is not otherwise available on-campus prior to purchasing new equipment.

Direct UM to provide annual training for employees on travel requirements and compliance to ensure travelers timely complete any applicable Waiver Request Forms reconcile travel advances as appropriate.

Direct UM to require annual trainings for Principal Investigators who execute and monitor subawardees to ensure that UM appropriately completes the Request to Issue Subcontract Form prior to charging subawardee costs to NSF awards and, at the end of the subaward’s period of performance, appropriately completes and certifies to close-out of active subawards.

Direct UM to implement internal controls to flag invoices submitted by consultants with expired agreements post-expiration of the executed agreement.

We recommend that the Puerto Rico Department of Health remediate the vulnerabilities related to the five security control findings identified by properly implementing and regularly assessing the associated NIST SP 800-53 controls

We recommend that the Puerto Rico Department of Health assess and adjust, if necessary, at least annually, the cryptographic configurations of public servers.

The Under Secretary for Health ensures compliance with suicide risk and lethal means safety training requirements.

We recommend that Blue Cross & Blue Shield of Rhode Island refund to the Federal Government the $4,894,595 of estimated net overpayments.

We recommend that Blue Cross & Blue Shield of Rhode Island identify, for the high-risk diagnoses included in this report, similar instances of noncompliance that occurred before or after our audit period and refund any resulting overpayments to the Federal Government.

We recommend that Blue Cross & Blue Shield of Rhode Island continue its examination of existing compliance procedures to identify areas where improvements can be made to ensure that diagnosis codes that are at high risk for being miscoded comply with Federal requirements (when submitted to CMS for use in CMS's risk adjustment program) and take the necessary steps to enhance those procedures.

The Railroad Retirement Board Bureau of Fiscal Operations should establish and maintain relationships with key business process owners, including sub-processes, across the Railroad Retirement Board to obtain documentation relevant to the support of all aspects of financial management practices in a timely manner.

The Railroad Retirement Board Bureau of Fiscal Operations should develop communication or “knowledge sharing” training to ensure Railroad Retirement Board stakeholders understand the requirements of financial management and the importance of providing sufficient and appropriate supporting documentation in a timely manner.