Open Recommendations

The Commissioner, Small Business/Self-Employed Division, should ensure that the 923 entities we identified receive a disallowance letter to prevent erroneous ERC claims from being paid.

Establish a plan to ensure robust oversight of the National Cemetery Administrations personnel suitability program that includes verifying background investigations are initiated and adjudicated within prescribed timelines and that documentation is filed as required.

Evaluate resource requirements for the personnel suitability program to ensure that all personnel suitability requirements are being met.

District leaders and the Corona, Temecula, Kauai, and Western Oahu Vet Center Directors determine reasons for noncompliance with completing four hours of external clinical consultation for clinically complex cases per month, ensure a process is implemented, and monitor compliance.

District leaders and Western Oahu Vet Center Director determine reasons for noncompliance with fire or safety annual inspection, ensure completion, and monitor compliance.

District leaders and the Corona, Temecula, and Western Oahu Vet Center Directors determine reasons for noncompliance with having an annual risk and vulnerability assessment completed by VA police or local law enforcement, ensure completion, and monitor compliance.

District leaders and the Corona, Temecula, and Kauai Vet Center Directors determine reasons for noncompliance with having an automated external defibrillator located on-site and ensure compliance with the requirement.

Develop a formal work planning process that incorporatesthe selection criteria from the Handbook and requires thatACO teams clearly document the criteria used to selecteach agency in the inspection plans and reports.

Revise Standard Operating Procedure 2.2, section 12, toexplicitly require the inspection teams to document theanalyses they conduct to support their findings andrecommendations.

Develop a standard documentation template that ACOstaff can use to clearly document the deficienciesidentified during an inspection.

Migrate the existing program data from CARS to asupported in-house tool to better manage the data whilethe team completes the market research for a newprogram management information system.

Develop relevant internal controls (policies, procedures,and/or guidance) to ensure data entry is integrated intoACO’s daily workflow.

Complete the enterprise-wide data inventory.

Document and implement a standard operating procedureto maintain the enterprise-wide data inventory as new datacollections are created and old data collections are retired.

Collaborate with NARA’s Chief Information Officer todocument and implement a standardized process tomonitor service level agreements with cloud-based serviceproviders. The process should include the monitoringresponsibilities of the Contracting Officer’sRepresentatives and actions NARA should take if acontractor does not meet the defined service levels.

Document and implement a process to incorporate theCloud Service Provider's Quality Assurance SurveillancePlan as part of future cloud service contracts. Whereincorporation of a Cloud Service Provider QualityAssurance Surveillance Plan is not anticipated, NARAshould incorporate its own Quality Assurance SurveillancePlan and service level agreements at the solicitationphase, these should align with commercial best practices.

Implement a documented process requiring the assignment of aQuality Assurance Evaluator for future relocation of records project(s).

Ensure a Quality Assurance Surveillance Plan is developed andimplemented requiring onsite supervision to provide proper oversight and compliancewith the PWS.

In collaboration with applicable parties, ensure PWS requirementsare developed to reflect the procedures necessary to protect and account for therelocation of archival records that should include:a. Implementing a documented process requiring the assignment of a QualityAssurance Evaluator for future relocation of records project(s).

In collaboration with applicable parties, ensure PWS requirementsare developed to reflect the procedures necessary to protect and account for therelocation of archival records that should include:Ensuring a Quality Assurance Surveillance Plan is developed, approved, andimplemented requiring onsite supervision to provide proper oversight andcompliance with the PWS.

Develop and implement standard operating procedures to ensurethat Research Services personnel comply with the PWS requirements.

Develop and implement standard operating procedures tocommunicate final PWS requirements to all responsible parties before the contract isawarded.

We recommend that the FAS Commissioner establish an oversight process for CSP-based contracts undergoing consolidation to ensure contracting personnel: (a) comply with General Services Acquisition Regulation 538.270-1, Evaluation of offers without access to transactional data, and FAS Policy and Procedure 2021- 05, Evaluation of FSS Program Pricing; and gather supporting documentation to determine a contractor’s most favored customer pricing for use in negotiation objectives; and (b) evaluate supporting documentation to verify a clear and relevant relationship between supporting documentation and each of the proposed prices it is meant to substantiate.

We recommend that the FAS Commissioner establish an oversight process for TDR pilot contracts undergoing consolidation to ensure contracting personnel do not rely solely on contract-level pricing tools; and, if prices paid data is not available, prioritize obtaining recent invoices or other than certified cost or pricing data from the contractor before relying on non-prices paid information.

We recommend that the FAS Commissioner re-evaluate previously consolidated MAS contracts to ensure that added products or services were evaluated to meet federal regulations and GSA policy requirements.