Open Recommendations

Ensure that there is a process for employees to file a retaliation claim with the OIG when a security clearance review or suspension lasts longer than 1 year

Analyze whether and under what circumstances its policies permit identifying and removing sensitive items from a crime scene, whether the crime scene is managed by the FBI or another law enforcement agency, particularly following an agent- or officer-involved shooting;

Develop guidelines for identifying and removing sensitive items, including appropriate documentation requirements and standards for involvement by agents involved in or witnesses to a shooting

Conduct training of FBI HRT and SWAT units to ensure that these standards are consistently implemented and followed.

Review charged-off PPP loans to ensure all eligible loans are reported to commercial credit reporting agencies, as required.

Require personnel to conduct periodic monitoring and reviews of SBA’s automated processes for PPP and future stimulus loan programs to ensure all eligible loans are reported to commercial credit reporting agencies, as required.

Identify the credit reporting agencies to whom SBA must report current and delinquent loans for PPP and future stimulus loan programs.

Review charged-off PPP loans to ensure that all eligible loans are referred to Treasury, as required.

Require personnel to conduct periodic reviews of its automated Treasury referral process for PPP and future stimulus loan programs to ensure all eligible loans are referred to Treasury, as required.

Conduct lender reviews to ensure lenders complied with their communication, servicing, and debt collection activity requirements. If not, require the lender to bring the loan into compliance or seek recovery of the guaranty paid by SBA as appropriate.

Require lenders to submit evidence of communication, servicing, and debt collection activities with the borrower prior to guaranty purchase for PPP and future similar programs to foster and maintain program integrity.

Develop an allocation methodology that will ensure that all attorneys’ fees are proportionately allocated to the fund in which the LSC grant is recorded in the same proportion that the amount of LSC funds were spent on a case or representation.

Review all LSLRA reimbursements within the audit period (January 1, 2022 to May 31, 2023) to verify that the employees reimbursed were at the experience level 24 and below, per the CBA. Document the results and any deviations from the policy, including review and approval.

We recommend that the Executive Director notify and obtain approval from LSC for the purchase of 50 laptops exceeding $25,000.

We recommend that the Executive Director develop and implement a process for tagging capitalized property and equipment.

We recommend that the Executive Director conduct a physical inventory of capitalized property and equipment as soon as possible, document the results, and do so at least every two years.

Update and implement contracting policies to include the following: • requirements for sole source justification;• discouragement of automatically renewing contracts, when possible and if terms allow. If automatically renewing contracts are unavoidable, consider setting up automated reminders to periodically reevaluate contracts;• requirements for periodic re-competition of contracts, when appropriate; and• requirements for full documentation for each contract action, including the request for proposals, vendor selection and approval.

We recommend that the Executive Director implement a control to ensure only authorized cardholders have access to card information. In the event another staff member needs to use a credit card and the cardholder cannot make the purchase for them, adequate documentation should be maintained to show that the cardholder authorized the purchase and access to the card was limited.

We recommend the Executive Director update NJP’s written policies for credit cards to include, at a minimum, the following:• guidelines on personal use and disallowed charges;• guidelines on properly documenting any deviations from policy;• restrictions on cash advances and ATM withdrawals;• deadlines for providing supporting documentation;• procedures for cardholders to review and acknowledge credit and purchase card policies.

We recommend that the Executive Director document the complete cost allocation process including the adjustments made to arrive at the final allocations for indirect costs.

We recommend that the Executive Director enable distinct user access roles for the NJP accounting staff that are commensurate with their responsibilities to ensure adequate segregation of duties is maintained in the accounting software.

We recommend that the Executive Director implement a process requiring dated approvals prior to expenses being incurred.

We recommend the Executive Director establish a process to document advance approval for employee travel, and, if appropriate, set a threshold above which such approval must be documented and not only given verbally.

We recommend that the Executive Director develop policies to ensure the timely disposition of outstanding checks.

We recommend that the Executive Director ensure NJP’s Accounting Manual (and, if applicable, Personnel Manual) is updated to include the grantee’s processes surrounding the referenced criteria. This includes:• payroll procedure details,• roles/responsibilities,• frequency,• documentation requirements, and• review/approval requirements (including changes/adjustments).