Open Recommendations

We recommend that USAID's Office of Acquisition and Assistance Cost, Audit and Support Division/Contract Audit Management Branch verify that Jefferson Consulting Group, LLC, corrects the one material weaknesses in internal control detailed on pages 9 and 10 of the audit report.

We recommend that the Acting GSA Administrator, for buildings where GSA employees access the roof, include a requirement to perform roof inspections during annual Occupational Safety and Health surveys conducted in accordance with GSA Order 5940.2, General Services Administration Occupational Safety and Health Program.

We recommend that the PBS Commissioner improve oversight of O&M contractors to ensure they develop and use safety and health plans that comply with the National O&M Specification and National Consolidated Maintenance Specification contract templates.

We recommend that the PBS Commissioner provide training to PBS contracting officer’s representatives and regional safety offices on their roles and responsibilities for accepting, reviewing, and approving compliant safety and health plans.

We recommend that the PBS Commissioner provide fall protection training to PBS facility managers that addresses roof fall hazards and fall protection requirements issued by OSHA and GSA.

We recommend that the PBS Commissioner resolve identified roof fall hazards in a timely manner by installing necessary OSHA- compliant fall protection on roofs with equipment located near unprotected roof edges. If no funding is available to do so, implement interim controls to protect against fall hazards and monitor the performance of those controls to ensure they remain effective.

We recommend that the PBS Commissioner require contractors to use OSHA-compliant fall protection.

We recommend that the PBS Commissioner implement a consistent process for ensuring facility managers are aware of all open risk conditions in the Inventory Reporting Information System, address open risk conditions in a timely manner, and periodically review open risk conditions until they are abated.

We recommend that the PBS Commissioner improve risk management surveys to ensure survey inspectors identify and record all applicable roof fall hazards under OSHA 1910.28, Duty to have fall protection and falling object protection, consistently.

We recommend that the PBS Commissioner review all ongoing and future roof replacement projects to ensure they comply with P100 roof replacement requirements for a review of existing fall protection by a qualified consultant; and, if the fall protection is deemed inadequate, design and install OSHA-compliant fall protection.

We recommend that the PBS Commissioner post appropriate signage at all roof access points to warn employees, contractors, and tenants of roof fall hazards.

We recommend the TSA Administrator evaluate the organizational placement of the Insider Threat Program within TSA to determine optimal alignment to achieve its goals and objectives.

We recommend the TSA Administrator update existing TSA management directives to clarify and align law enforcement roles and responsibilities with TSA’s current strategic intent and eliminate policy conflicts. In particular, TSA MD 100.0 must clearly distinguish roles and responsibilities of ITS and TSA Investigations.

We recommend the TSA Executive Assistant Administrator for LE/FAMS develop Insider Risk Mitigation Hub policies to standardize communication and deconfliction practices between TSA Investigations and ITS.

We recommend the TSA Executive Assistant Administrator for LE/FAMS formalize and implement ITS policies and procedures in an approved SOP, including criteria agreed upon with TSA Investigations for referring and deconflicting allegations of misconduct.

We recommend the TSA Executive Assistant Administrator for LE/FAMS develop and implement a formalized training plan to ensure ITS personnel: • follow internal referral and investigation processes outlined in its approved SOP; and • possess appropriate levels of insider threat-related training to meet DHS Insider Threat Program Minimum Standards.

We recommend the TSA Executive Assistant Administrator for LE/FAMS develop a mechanism to accurately track and maintain ITS personnel training records.

Follow up with AIPs that did not submit reports for the 148 required $200,000 Indemnity Reviews in CY 2022 and (1) determine whether the $61.9 million in questioned, unsupported indemnity cost were supported and allowable, and (2) recover any costs determined to be unsupported and unallowable.

Review CYs 2019 through 2023 and follow up with AIPs for unsubmitted reports for the required $200,000 Indemnity Reviews and, if adequate support is not provided, recover the unsupported indemnity amounts.

Develop and implement a process and procedures to regularly reconcile the required $200,000 Indemnity Reviews with the associated completion reports submitted by AIPs.

Evaluate whether VA should establish an enterprise-wide governance structure for Caseflow development, consistent with VA’s initial comprehensive plan to Congress.

Develop a well-defined roadmap for the future development and implementation of Caseflow.

Enforce contract requirements through improved oversight, ensuring violations are identified and remediated.

Direct the selected State agency to review the four sponsoring organizations that provided documentation and had meal count discrepancies, expand the review as appropriate, and determine whether the results warrant review of other sponsoring organizations as well.

Direct the selected State agency to provide further training to CACFP sponsoring organizations on point of service meal counts.