Open Recommendations

We recommend that the Orphaned Wells Program Office establish milestones for the Osage Nation's execution of the implementation grants and ensure it has made progress in plugging orphaned wells before awarding phase 3 funds.

Apply population change factors, such as projected growth and trends of sorting and delivery center locations, as part of its Financial Rigor Tests for the investments.

Perform inspections and complete route adjustments where needed as part of the required annual process within the year prior to estimating the Financial Rigor Tests related to sorting and delivery center investments.

Require tracking, reconciling, and reporting of operating costs throughout the Sorting & Delivery Center project, with adjustments to investment calculations for significant changes; and delegate responsibility for the oversight of financial performance over routes related to the project.

Completely implement monitoring activities over the effectiveness of existing controls to ensure expenses, including accruals, are recorded accurately. Such activities should include, at a minimum:
a. Coordinating with the participating agencies to monitor the design and effectiveness of accrual controls.
b. Responding to the results of such monitoring with appropriate revisions to process-level activities and controls as necessary.

Enhance existing risk assessment processes to identify and respond to potential areas of increased risk in key process areas, including consideration of materiality and aggregation risk across the participating agencies and types of business events.

Enhance existing financial statement preparation controls to identify and correct presentation errors in the financial statements and related note disclosures.

Update and reissue its Asset Forfeiture Financial Management and Administrative Guide to more clearly define the investigative action that should be used as the seizure date for purposes of actual or constructive custody and valuation of seized property. Specifically, this should include consideration of digital assets that are direct transferred. Additionally, establish the accounting requirements for AFP participants to adhere to timely and accurate data input to the AFP's asset tracking system, including the definition of the date of seizure of assets and the timeline to obtain a professional appraisal, to enforce accountability.

Develop new and/or enhance existing process controls for participating agencies and monitoring controls within the Asset Forfeiture Management Staff to ensure participating agencies accurately and timely record seizure transactions in the AFP asset system-with a supported appraisal-to enforce accountability for internal control responsibilities of responsible parties.

Establish a materiality amount for non-financial measures in the financial statements and perform existing controls over valued property or design new controls specific to the presentation of firearm counts.

Assess reconciliation, review, and other monitoring controls; implement more consistent processes across components and improve data for analysis and reporting, to enhance the design of period end financial reporting controls, including the identification and investigation of events and transactions impacting all financial statements.

Update the Facility Security Risk Management Program Internal Operating Procedure (IOP) to include.
• Additional guidance on how to implement the Interagency Security Committee’s (ISC) Standard’s Facility Security Level (FSL) criteria.
• A process for documenting the Chief, Physical Security’s approval of the FSL.
• A requirement for supporting documentation and justification for each assigned score, including source references or observed conditions that could impact certain criteria.
• A requirement for documented justifications for any deviations from the Design Basis Threat (DBT) baseline scores identified by ISC.
• A requirement that security incident data be reviewed, analyzed, and attached as…

Develop and implement policies and procedures for centrally obtaining, tracking, and analyzing security incident reports agency-wide.

Develop and implement standard operating procedures (SOPs) that instruct CORs on the invoice approval process, to include a requirement that CORs document their reconciliation of invoices with detailed timesheets before security guard contract invoices are paid.

Recover or otherwise resolve the $158,880.29 in questioned costs from security guard vendors as a result of insufficient documentation.

Provide training on the new documentation requirements to any COR responsible for security guard contracts.

Recover or otherwise resolve the $9,093.65 in questioned costs from the security guard vendor at the Truman Presidential Library related to unallowable supply and material charges.

Provide specific guidance to CORs responsible for security guard contracts or, as appropriate, issue a contract modification which further clarifies the allowable uses for the “Additional Services” Contract Line Item Numbers (CLINs), and processes required to use available funds for other purposes.

Develop and implement a plan for restricting user access for Large Institution Supervision Coordinating Committee and Large and Foreign Banking Organization users in OASIS consistent with the need-to-know requirement in Board policy and the Federal Reserve Administrative Manual and National Institute of Standards and Technology’s least privilege principle.

Define an access approach for the eventual transition of the Community Banking Organization and Regional Banking Organization portfolios into OASIS appropriate for the Community Banking Organization and Regional Banking Organization supervisory framework and based on users’ need to know.

Update existing OASIS guidance to clarify how examiners should use sensitive file folders, including expectations for the types of files that should be stored in the folders and who should have access to the folders.

Develop guidance that
a. defines the need-to-know principle and how it should be applied when granting user access to confidential supervisory information in OASIS.
b. describes the expectations for performing the Board’s annual access review process for OASIS, including designating responsibility for performing the attestation to individuals with knowledge of the user’s roles and responsibilities, such as the user’s supervisor or other possible alternatives.

The Assistant Director ensures staff maintain a consistently clean environment throughout the facility to prevent repeat environment of care findings.

Executive leaders review the change in laboratory scheduling practices and minimize its effect on clinic efficiency.

The Assistant Director ensures staff maintain a consistently clean environment throughout the facility to prevent repeat environment of care findings.