Open Recommendations

Provide oversight of cardboard mail transport equipment inventory to ensure processing facilities only maintain a seven-day supply, and document facilities with exceptions to the policy.

Require processing facility management to annually certify proper cardboard mail transport equipment recycling and reuse business practices are in place and employees are aware of and following these practices.

Direct Plant Managers to enforce proper cardboard mail transport equipment recycling and reuse practices.

1) Perform a cost benefit analysis for baling cardboard at all processing facilities, 2) provide balers for facilities identified to have a positive benefit, and 3) for the facilities that cannot accommodate a baler, document the approved deviations.

We recommend that USAID/Kenya and East Africa determine the allowability of $86,105 in questioned costs ($54,080 ineligible, $32,025 unsupported) on pages 20 and 26 of the audit report and recover any amount that is unallowable.

We recommend that USAID/Kenya and East Africa verify that TradeMark Africa Limited corrects the four material weaknesses in internal control detailed on pages 30 to 37 of the audit report.

We recommend that USAID/Kenya and East Africa verify that TradeMark Africa Limited corrects the one instance of material noncompliance detailed on pages 50 and 51 of the audit report.

We recommend that DRP management update policies and internal guidance to (a) require that staff document the reasons and relevant risk factors for conducting elective annual report reviews, (b) provide clear direction for scoping annual report reviews, and (c) require that staff document scoping decisions.

We recommend that DRP management coordinate with the SEC Office of the General Counsel to finalize the Sarbanes-Oxley Act of 2002 section 408(b) guidance, including a description of all six factors to be considered when selecting issuer filings for elective reviews, and finalize its interpretation of the minimum review period mandate from section 408(c) of the Act.

We recommend that DRP management consider developing a plan that prioritizes Disclosure Review Program goals and requirements in the event of significant staffing decreases and/or significant workload increases.

The OIG recommends that the Executive Director for Operations establish an assessment process to periodically assess the Reactor OpE Program.

The OIG recommends that the Executive Director for Operations update LIC-401 to include a description of the current process by which staff assess the significance of OpE information.

The OIG recommends that the Executive Director for Operations update the Staff Handbook to provide step-by-step guidance for implementing the requirements stated in the updated LIC-401.

The OIG recommends that the Executive Director for Operations include within the updated LIC-401 and Staff Handbook guidance a description of the purpose of “Instruction Sheets” as interim guidance and indicate where they are located, as needed.

The OIG recommends that the Executive Director for Operations develop, communicate, and implement policies and procedures for the EDG TRGs.

The OIG recommends that the Executive Director for Operations systematically inform EDG TRG members about their membership, update the OpE SharePoint site to show the current membership of TRGs, and record TRG evaluations in a centralized location.

The OIG recommends that the Executive Director for Operations provide and promote EDG TRG training to current members on all SharePoint sites.

Issue and distribute to all employees, and prominently post an annual anti-harassment policy statement signed by the Chairman
reinforcing:
• Harassment will not be tolerated,
• Certain conduct is prohibited,
• How to report harassment, and
• Consequences of engaging in harassment and retaliation.

Develop a plan to ensure a culture of accountability and commitment to the CFTC anti-harassment effort. The plan should:
• Include a schedule for training employees and supervisors and a consistent and repeatable mechanism to monitor
attendance.
• Create a reporting mechanism to receive harassment complaints that ensures confidentiality.
o Notify the workforce of this reporting mechanism.
• Develop procedures to ensure consistency in tracking complaints and documenting delays to EEOC-mandated timelines for
sexual and non-sexual harassment claims.

Devote sufficient independent support to harassment prevention efforts to reinforce the credibility of leadership’s commitment to creating a workplace free of harassment.

Ensure CDSS corrected the miscoding error of the $282,665 claimed as SNAP administrative expenses. Ensure the funds that were previously reimbursed by FNS were adequately returned, and CDSS appropriately claimed and was reimbursed for the Pandemic EBT administrative expense through proper funding.

Review whether Pandemic Electronic Benefit Transfer administrative expenses were properly claimed and reported in the next FMR of CDSS.

We recommend that USAID/Kenya and East Africa verify that Centre for Health Solutions corrects one instance of material noncompliance detailed on page 39 of the audit report.

Verify that Tsofen High Technology Centers corrects the material weaknesses in internal control detailed on pages 21 and 22 of the audit report.

Verify that Tsofen High Technology Centers corrects the three instances of material noncompliance detailed on pages 25 to 29 of the audit report.