Open Recommendations

We recommend that Millennium Challenge Corporation determine the allowability of the $151,268 ($62,146 ineligible and $89,122 unsupported questioned costs) detailed on pages 58, 62, 78, and 116 of the audit report and recover any amount that is unallowable.

We recommend that the Millennium Challenge Corporation verify that MCA-Nepal corrects the material instance in internal control that is also an instance of material noncompliance detailed on page 116 of the audit
report.

We recommend that the Millennium Challenge Corporation verify that MCA-Nepal corrects the twelve instances of material noncompliance detailed on pages 58 to 64, 78, 81, 85 to 95, 103, 105, and 112 of the audit
report.

Determine whether to seek legislation to amend the Internal Revenue Code to permit the Internal Revenue Service to share with SSA non-covered pension data for all Old-Age, Survivors, and Disability Insurance beneficiaries.

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Determine whether Bechtel is compliant with CAS 401, Consistency in Estimating, Accumulating and Reporting Costs.

Develop a policy that prescribes cost estimating system requirements, similar to those in Appendix 4, Estimating System Criteria, for inclusion in Department contracts.

"We recommend that the Manager, River Protection, direct the Department Contracting Officers
to: 1. Ensure all Hanford Site contractors have an adequate estimating system, including:
• Establish specific local policies and procedures that address estimating techniques such as Monte Carlo, CERs, and unit rate development.
• Require personnel to have sufficient training, experience, and guidance with regards to the contractor’s established estimating procedures.
• Identify and document the sources of data and the estimating methods and rationale used in developing cost estimates. (Verify that contractors submit proposals that allow for detection and correction of errors in a timely manner.)
•…

Include the requirement for an adequate estimating system and associated estimating system criteria (see Appendix 4, Estimating System Criteria, for suggestion) in Bechtel’s contract as part of any future modification negotiations.

We recommend that CPB management require KDNA-FM to fully comply with Act requirements for advance notice for open meetings and for making the reasons for a closed meeting available to the public within 10 days following the closed meeting date.

We recommend that CPB management require KDNA-FM to identify the corrective actions and controls it will implement to ensure future compliance with Act requirements for open and closed meetings, as well as making financial information available to the public.

We recommend that CPB require KDNA-FM to update its Diversity Statement to fully address the CPB diversity requirements and have its LCSR available to the public.

We recommend that CPB require KDNA-FM to identify the corrective actions it will implement to ensure compliance with CPB General Provisions for diversity and transparency, including documenting its review of the updated Diversity Statement with the governing board or licensee official.

Develop and consistently maintain comprehensive Orderly Liquidation Authority policies and procedures for systemically important financial companies, to include:a. Tier I policies and procedures for framework-level activities.b. Tier II policies and procedures for operational process-level activities.c. Tier III policies and procedures for institution-specific planning activities.d. Other operational program policies and procedures for Orderly Liquidation Authority resolution planning activities.

Develop and consistently maintain comprehensive Orderly Liquidation Authority policies and procedures for systemically important financial companies, to include:a. Tier I policies and procedures for framework-level activities.b. Tier II policies and procedures for operational process-level activities.c. Tier III policies and procedures for institution-specific planning activities.d. Other operational program policies and procedures for Orderly Liquidation Authority resolution planning activities.

Establish a process for identifying and preparing staff who would be responsible for key Orderly Liquidation Authority resolution governance roles, such as the Executive Advisory and Oversight Group, the Tactical Project Manager, and the Onsite Liaison, to include:a. Completing planned guidance and/or preparing a charter that will define in more detail the key resolution governance roles and responsibilities.b. Maintaining a roster of potential staff for key resolution governance roles.c. Informing potential staff for the key resolution governance roles of their respective Orderly Liquidation Authority resolution responsibilities.

Ensure the completed Tier I and II policies, procedures, and related guidance documents fully define the applicable Orderly Liquidation Authority roles and responsibilities of each FDIC Division and Office.

Ensure the FDIC establishes a timeframe to obtain, and then obtains, the staff resources needed to mature the Orderly Liquidation Authority resolution planning program.