Open Recommendations

We recommend that the Office of the Chief Information Officer query bureaus and offices for all current systems with publicly available interfaces and develop a DOI?wide inventory that maintains IP addressing and service ports, system ownership, and point of contact information.

We recommend that the Office of the Chief Information Officer develop a process whereby all changes to publicly available systems and newly deployed systems are updated in a DOI-wide inventory and included in any security assessments and monitoring.

We recommend that the Office of the Chief Information Officer require bureaus and offices use updated guidance and resources provided by the Office of the Chief Information Officer, in response to Recommendation 4 of this report, to evaluate and prioritize remediation of vulnerabilities persisting beyond approved timelines.

Direct Georgetown to provide documentation supporting that it has repaid or otherwise credited the
$13,904 in questioned salary, travel, materials and supplies, consultants, and subaward expenses for
which it has agreed to reimburse NSF

Direct Georgetown to implement stronger pre-award cost controls and system checks to prevent
charges incurred before an award’s start date from being incorrectly applied to federal awards.

Direct Georgetown to strengthen its review procedures for travel-related expenses to ensure that
catering and meal costs are reasonable, appropriately documented, and align with federal per diem
limits and attendance records.

Direct Georgetown to enhance its documentation and retention procedures for all award-related
expenditures to ensure that costs are fully supported, clearly justified as allowable under federal
regulations, and remain verifiable regardless of personnel changes.

Direct Georgetown to strengthen its review and approval processes for consultant expenses to ensure
that all costs charged to federal awards are properly allocable, directly benefit the award, and are
supported by appropriate documentation prior to payment

Direct Georgetown to strengthen its subaward monitoring and compliance procedures to ensure that
all subrecipients adhere to federal travel regulations, including the Fly America Act, before travel
expenses are charged to federal awards.

Direct Georgetown to provide documentation supporting that it has repaid or otherwise credited the
$22,120 in questioned subaward and other direct cost expenses for which it has agreed to reimburse
NSF.

Direct Georgetown to strengthen its policies, procedures, and internal controls for ensuring costs
claimed on federal awards include adequate documentation to support the allocability, allowability,
and reasonableness in accordance with federal regulations.

Direct Georgetown to provide documentation supporting that it has repaid or otherwise credited the
$32,083 in questioned indirect expenses for which it has agreed to reimburse NSF.

Direct Georgetown to strengthen its standardized policies, system-enabled validations, or
comprehensive oversight mechanisms to ensure consistent and accurate application of indirect costs
in alignment with NSF guidelines and the Uniform Guidance. These updated procedures could
include:
• Requiring personnel responsible for approving invoices to perform a documented review to
ensure Participant Support Costs do not have applied indirect costs.
• Developing guidance on accurately classifying all costs included within the Modified Total Direct
Cost base and on applying the indirect cost rate to those accounts.

Direct Georgetown to provide documentation supporting that it has repaid or otherwise credited the
$19,150 in questioned publication and materials and supplies expenses for which it has agreed to
reimburse NSF.

Direct Georgetown to produce formal written guidance and provide training on how to assess and
document the methodology used to allocate costs consistent with the benefits received by
acknowledged funding sources and materials and supplies

Direct Georgetown to provide documentation supporting that it has repaid or otherwise credited the
$18,034 in questioned indirect expenses for which it has agreed to reimburse NSF.

Direct Georgetown to develop and disseminate clear policies and procedures for identifying and
classifying costs incurred. Policies could explicitly define categories in alignment with NSF and
Uniform Guidance requirements.

Direct Georgetown to provide targeted training to staff involved in proposal budgeting, award setup,
post-award financial management, and general ledger accounting. Training could include the
distinction between cost categories and the implications of misclassification.

Direct Georgetown to establish routine compliance checks and periodic reviews of cost classifications
to ensure that misclassified transactions are detected and corrected prior to financial reporting or
drawdown of federal funds.

Direct Georgetown to review prior cost transactions on open NSF-funded awards to determine if
additional misclassifications exist. Where necessary, make appropriate adjustments and maintain
documentation of all corrective actions.

Direct Georgetown to implement enhanced procedures and internal controls to ensure compliance
with its own policies for NSF award oversight, including verifying competitive bidding
documentation, required reviews and approvals, accurate equipment records, timely effort
certification, and correct subrecipient indirect rates.

Develop a mechanism to identify all applicable charges when calculating postage due to incorporate into its automated calculations.

Incorporate large and oversized package charges into postage due calculations for return-to-sender packages.

Electronically link the payment of postage due to the specific packages for which the payments are based.

Further automate the postage due calculation and collection process for undeliverable packages, using weights and dimensions captured by mail processing equipment.