Open Recommendations

Work with the Chief Information Officer Officer to perform a risk assessment to determine which aspects of an insider threat program are applicable to other types of sensitive Board information and develop and implement an agency-wide insider threat strategy for sensitive but unclassified Board information, as appropriate.

Take action to work with FAA, FHWA, FMCSA, FTA, MARAD, NHTSA, and OST to develop risk acceptance memos for the expired systems identified in this report.

The Deputy Secretary, or his designee, take action to work with OST COE, FTA, and FAA, the common control providers, to report and update risk acceptance for shared controls that are not implemented in DOT's Repository (e.g., CSAM) per FISMA, OMB, and DOT requirements.

The Deputy Secretary, or his designee, take action to identify and document OST COE compensating controls when used to address security weaknesses in CSAM and system authorizations.

The Archivist implement or upgrade current internal control software or utilize other mechanisms to enhance and improve the agency’s ability to track and report on internal controls.

The Archivist address outstanding recommendations from OIG Audit Report No. 13-01, including:  Revisiting his decision on the placement and role in the organization of the Chief Risk Officer.

NARA Executives ensure:  Monitoring and testing plans are sufficiently reported in the ICP Tool.

NARA Executives ensure:  Results of monitoring and testing plans are achievable within the reporting timeframe.

NARA Executives ensure:  All information is up-to-date and reflects the current control environment.

NARA Executives identify, develop, and include in ICP reports measurable indicators to evaluate functions.

The ICP Official develop and implement a consistent risk assessment process and format for risk ranking, analysis of effect or impact, and risk reporting.

The ICP Official review the ICP reports and make and document  any revisions necessary to the format to ensure all necessary information is obtained in the reports.

We recommend that HUD's Acting Deputy Assistant Secretary for Grant Programs instruct City officials to repay the Program from non-Federal funds $32,107 in overpaid grants to homeowners whose grant amounts (1) were not revised to show recalculated duplication of benefits and (2) exceeded the Program's 60 percent reimbursement rate.

We recommend that HUD's Acting Deputy Assistant Secretary for Grant Programs instruct City officials to reimburse $101,398 in additional grants owed to the 11 homeowners whose grant amounts should have been materially increased as a result of recalculated duplication of benefits.

We recommend that HUD's Acting Deputy Assistant Secretary for Grant Programs coordinate with the Office of Healthy Homes and Lead Hazard Control to provide technical assistance and instruct City officials to provide supporting documentation that lead-based paint testing was performed, identified hazards were removed, and clearance was achieved for the 41 properties for which homeowners received $833,199 in CDBG-DR assistance. If supporting documentation is not provided, City officials should repay the $833,199 from non-Federal funds.

We recommend that HUD's Acting Deputy Assistant Secretary for Grant Programs coordinate with the Office of Healthy Homes and Lead Hazard Control to provide technical assistance and instruct City officials to advise homeowners of their obligation under the terms of the reimbursement grant agreement to allow the Program to perform lead-based paint testing or hazard removal. Homeowners who refuse to allow the Program to complete lead hazard work or provide evidence that the property achieved clearance must repay the grant.

We recommend that the Chief Operating Officer\Chief Risk Officer fully implement all components of NARA 160, including developing, documenting, and fully implementing NARA 162, NARA’s Enterprise Risk Management Program.  Within NARA 162, roles and responsibilities for ERM activities should be clearly identified.

We recommend that the Chief Operating Officer\Chief Risk Officer fully implement all components of NARA 160, including Developing, documenting, and fully implementing NARA 163, NARA’s Issues Management.

We recommend that the Chief Operating Officer\Chief Risk Officer develop, document, and implement a formal process to identify and prioritize risks within the organization. Risks should be tied directly to NARA’s strategic plan and mission and prioritized based on their overall importance to the agency.

We recommend that the Chief Operating Officer\Chief Risk Officer develop, document, and implement a formal process to prioritize risk management activities including the use of limited resources based on key risks within the organization. Management’s prioritization should be clearly documented and include formal steps to ensure risks are maintained at an appropriate level.

We recommend that the Chief Operating Officer\Chief Risk Officer Provide additional resources to the Office of Accountability to ensure ICP activities are effectively carried out.