Open Recommendations

We recommend that USAID/Pakistan:
Collaborate with the Sindh government to develop a plan with milestones to address the financial and human resource challenges hindering the availability of potable water and maintenance of schools constructed under the Sindh Basic Education Program.

We recommend that USAID/Pakistan:
Establish controls to ensure continuous risk assessment-especially
monitoring and adaptation of responses-of a recipient's capacity to fund and sustain the operation and maintenance of a USAID-funded capital project throughout the life cycle of the construction activity.

We recommend that USAID/Pakistan:
Develop and issue guidance clarifying when it is appropriate to aggregate or disaggregate construction activities to determine when the Foreign Assistance Act 611(e) certification is required and which entity should be subject to it.

We recommend the CEO perform a review of the Incurred Costs Grant budget application and timekeeping records related to the disasters from 2020 and 2021 to identify the actual hours worked and corresponding costs for case time and administrative leave hours for office closures. The review should clearly distinguish between distinct categories of hours, including actual case/matter/supporting activity hours and leave.

We recommend the CEO implement a procedure to ensure that all relevant information, including the dates of office closures, offices impacted or closed, and staff on administrative leave due to disasters Hurricane Laura and Winter Storm Uri are adequately documented; and do so each time such actions are taken in response to future disasters.

We recommend that the CEO revise LSLA’s contracting policy to require recompeting recurring purchases and long-standing contracts every three to five years.

We recommend that the CEO implement a process to ensure LSLA follows its procurement policy. This includes documenting bids for all applicable purchases. Additionally, sole-source justifications should be documented and approved.

We recommend that the CEO implement a process to ensure unauthorized personnel do not enter into contracts on behalf of LSLA. Alternatively, if LSLA decides that it would be beneficial to allow more flexibility in contract approval authority, this should be formalized in the written policies and any deviations from the written policies should be adequately documented and approved.

We recommend that the CEO update LSLA’s cost allocation methodology to ensure unrestricted funds are equitably included as a source to pay for indirect costs.

We recommend that the CEO ensure LSLA allocates the maximum allowable indirect costs to all funding sources, as per LSC guidance.

We recommend the CEO update the LSLA Accounting Manual to include policies and procedures surrounding card usage, statement reviews, payment processes and the credit card reconciliation process.

We recommend the CEO establish explicit written policies and procedures for board travel reimbursement policies. In addition, the policies should stipulate when per diem allowance limits can be overridden as well as the required documentation of review and approval.

We recommend that the CEO revise LSLA's written policies to include the following details:
• Timeline for preparing management reports
• Identification of known commitments
• Contents of the income and expense report
• Support of projections by schedules that document assumptions used to arrive at final projected amounts
• Budget constructions from cost centers
• Format of management reports
• Preparation of a budget to actual report or similar report containing the required information

We recommend that the CEO implement a process to document management's review of monthly reports. This should include a signature and date to denote the review and ensure compliance with LSC’s Financial Guide.

We recommend that the CEO ensure LSLA's written policies reflect the actual practices in place and comply with the applicable legal requirements for unclaimed client funds.

We identified questioned costs of $438,032 due to improper documentation and non-compliance with disaster grant requirements.QC further broken down as follows:
• LADRC – Leave & Holiday Hours totaling $39,983 in Questioned Costs.
• Incurred Costs Grant – Unallowable Expenses Totaling $287,624 in Questioned Costs.
• Incurred Costs Grant – Leave Hours Totaling $110,425 in Questioned Costs.

The Chief, Taxpayer Service should develop a strategic approach that includes the assessment of available data, such as the volume and geographic location of taxpayers receiving Letter 5747C, lack of appointment availability, etc., to proactively anticipate the potential demand for Saturday Help events at various TAC locations.

The Chief, Taxpayer Service should evaluate additional actions that can be taken to better assist taxpayers and reduce the demand on the TAC from individuals required to verify their identity, such as having dedicated Saturday Help events to conduct in-person identity verification.

The Chief, Taxpayer Services should provide explicit notifications on the IRS website of closed sites that were previously listed and scheduled to be open.

Develop training for examination staff that
(a) provides an overview of the Bank Exams Tailored to Risk model risk metrics, adjustment factors, and bump-up rules.
(b) provides an overview of the process for using Bank Exams Tailored to Risk to scope an examination.
(c) reinforces the resources and guidance materials available to help examination staff understand these topics.

We recommend that the Bureau for Global Health take the following actions:
Establish procedures to facilitate the deployment of staff to the field when needed during a health emergency.

We recommend that the Bureau for Global Health take the following actions:
Develop a timeline for finalizing all aspects of its Global Health Emergency Management System, including provisions for periodic testing of plans and for documenting and incorporating bureau-specific lessons learned.

We recommend that the Bureau for Management take the following actions:
Develop a plan for the identification, recruitment and retention of skilled personnel to task forces in the event of a global health emergency, including contingency planning for a lack of available staff.

We recommend that the Bureau for Management take the following actions:
Develop a plan to periodically test procedures in Automated Directives System, Chapter 112 through proactive exercises and evaluation activities and integrate lessons learned into the chapter.

We recommend that the North Carolina Department of Health and Human Services, Division of Health Benefits develop mitigating controls and strategies to lower risk within the high- and moderate-rated risk areas we identified.