Open Recommendations

Perform ongoing monitoring of anticipated accounting changes and communicate potential updates to relevant stakeholders.

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We recommend that EXIM design, document, and implement controls to ensure [language withheld based on applicable Freedom of Information Act exemptions] that logical access is restricted to only authorized users.

Update its annual retrospective review through a grant recipient survey, review of invoice documentation, and/or other means for a lookback period greater than 4 months to analyze the results of the prior year accrual and determine if the 4-month lookback period remains sufficient to validate the grant accrual methodology in subsequent periods.

Analyze the reasons for the changes in the calculated average billing cycle and grant recipient billing patterns in recent periods and document the impact on its grant accrual methodology as part of its annual retrospective review prior to year-end.

Design and implement procedures to document the analysis performed to support any future changes to the grant accrual methodology prior to implementing such changes.

Implement a procedure, as part of its process for recording SF-132 activity, to reconcile the SF-132 line number to the applicable United States Standard General Ledger account to verify that the transaction is recorded accurately and in accordance with OMB Circular No. A-11.

Implement processes to perform administrative functions without the use of shared accounts.

Design and implement controls over privileged developer access to certain systems, including periodic recertification of accounts and enforcing segregation of duties.

Design, implement, and re-enforce requirements for controls to consistently approve and document recertification requests as required by internal policy and standards for effective internal control systems.