Open Recommendations

Provide documentation to show that payroll costs totaling $2,019,496 and any payroll costs incurred outside our audit period, including fiscal year 2017, were reasonable and necessary expenses for the operation of the project or repay the project from nonproject funds for any amount that it cannot support.

Provide documentation to show that other direct costs totaling $56,021 and any direct costs incurred outside our audit period, including fiscal year 2017, were reasonable and necessary expenses for the operation of the project or repay the project from nonproject funds for any amount that it cannot support.

Rec. 1.a: The DoD OIG recommended that the Under Secretary of Defense for Acquisition, Technology, and Logistics review the current implementation and execution of the Acquisition and Cross-Servicing Agreement program and update DoD Directive 2010.9, "Acquisition and Cross-Servicing Agreements," November 24, 2003.

Rec. 1.a.1: The DoD OIG recommended that the Under Secretary of Defense for Acquisition, Technology, and Logistics review the current implementation and execution of the Acquisition and Cross-Servicing Agreement program and update DoD Directive 2010.9, "Acquisition and Cross-Servicing Agreements," November 24, 2003. The updated guidance should clearly define Office of the Secretary of Defense, Military Department, Defense Agency, Joint Staff, and Combatant Command oversight responsibilities.

Rec. 1.a.2: The DoD OIG recommended that the Under Secretary of Defense for Acquisition, Technology, and Logistics review the current implementation and execution of the Acquisition and Cross-Servicing Agreement program and update DoD Directive 2010.9, "Acquisition and Cross-Servicing Agreements," November 24, 2003. The updated guidance should require the use of a DoD system of record for maintaining all Acquisition and Cross-Servicing Agreement transactions and supporting documentation.

Rec. 1.a.3: The DoD OIG recommended that the Under Secretary of Defense for Acquisition, Technology, and Logistics review the current implementation and execution of the Acquisition and Cross-Servicing Agreement program and update DoD Directive 2010.9, "Acquisition and Cross-Servicing Agreements," November 24, 2003. The updated guidance should clearly define roles and responsibilities of Acquisition and Cross-Servicing Agreement order and billing officials (financial management staff), including appointment requirements.

Rec. 1.a.4: The DoD OIG recommended that the Under Secretary of Defense for Acquisition, Technology, and Logistics review the current implementation and execution of the Acquisition and Cross-Servicing Agreement program and update DoD Directive 2010.9, "Acquisition and Cross-Servicing Agreements," November 24, 2003. The updated guidance should clarify requirements for an implementing arrangement and what is acceptable for establishing parameters under Acquisition and Cross-Servicing Agreement authorities.

Rec. 1.c: The DoD OIG recommended that the Under Secretary of Defense for Acquisition, Technology, and Logistics develop a training program or training program requirements for the implementation of the Acquisition and Cross-Servicing Agreement program and execution of Acquisition and Cross-Servicing Agreement authorities.

Rec. 2: The DoD OIG recommended that the Assistant Secretary of the Navy (Research, Development, and Acquisition) designate a Chief of Naval Operations and Headquarters Marine Corps Office of Prime Responsibility to oversee the execution of the Acquisition and Cross-Servicing Agreement program for their respective Service Components.

Require indemnification for the 26 loans that had significant servicing deficiencies. In these cases, the loss to HUD was $1,673,117 (appendixes A and D).

Require that the servicers with significant and other deficiencies revise and update their policies and procedures, as necessary, to ensure that they comply with HUD requirements and guidance on loss mitigation evaluation.

Recovers $438,118 from the State, if applicable.

Ensures that the Authority complies with equipment and real property management requirements.

Ensures that the Government complies with equipment and real property management requirements.

Ensures that the Tribe complies with activities allowed or unallowed and allowable costs/cost principles requirements.

Determine an amount of questioned costs and recover from the Tribe, if applicable.

Update the Financial Assistance Guidance Manual and other policies to reflect current authorities and oversight needs for OTAs, and clarify which provisions of the manual and other policies apply to these agreements.

Direct responsible field offices to require the grantees identified by the audit to either provide documentation to support $227,260 in unsupported payments or reimburse their programs from non-Federal funds for costs they cannot support.

Provide guidance to field office staff to clarify the statutory requirements in 42 U.S.C. 5305(a)(24) regarding a principal reduction and a downpayment for direct home-ownership assistance activities.

Rec. 1.g: The DoD OIG recommended that the Assistant Secretary of the Army (Financial Management and Comptroller) develop a process to maintain credit values given for returns for credit and unserviceable credit transactions.

Develop a policy to reduce balances of available program income of Brownfields Revolving Loan Funds being held by recipients. The policy should establish a time frame for recipients to use or return the funds tothe EPA.

Develop and implement required training for all regional Brownfields Revolving Loan Fund staff. Have the training include all program policyand guidance relating to maintaining a Brownfields Revolving Loan Fund after the cooperative agreement is closed if program income exists.