Open Recommendations

Ensure the life-cycle cost and schedule estimates properly incorporate MSR Program complexity and performance as factors and do not only focus on external cost growth impacts and ongoing design issues.

Ensure the Agency Program Management Council is provided with a set of potential launch scenarios by KDP-C, including life-cycle cost and schedule estimates and an associated Joint Cost and Schedule Confidence Level for each.

Require freight auction brokers to report subcontractor authorization and vetting and develop a system of record to maintain the reported results.

Communicate and create a mechanism to validate the use of team drivers for trips that exceed 500 miles, update freight auction statements of work, and terminate contractors who are non-compliant.

Define freight auction applicability to Management Instruction PO-530-2009-4, Section 19 - Special Circumstances.

Update and enforce freight auction guidance and include at minimum a process to verify driver history.

Rec. A.1.b: The DoD OIG recommended that the Principal Director, Defense Pricing and Contracting implement additional controls for contracting personnel that may include incorporating greater supervisory oversight and more frequent training on compliance with Federal Acquisition Regulation and Defense Federal Acquisition Regulation Supplement contract closeout requirements for all contracts.

Rec. A.1.c: The DoD OIG recommended that the Principal Director, Defense Pricing and Contracting reinforce existing closeout requirements and implement additional controls to ensure better communication between contracting personnel and administrative contracting personnel throughout the contract closeout process and develop procedures to ensure continuity of contracting operations in the event of personnel turnover or changes in responsibility for contract oversight.

CMS should implement and expand upon its policies and programs to strengthen the nursing home workforce.

CMS should reassess nurse aide training and certification requirements .

CMS should update the nursing home requirements for infection control to incorporate lessons learned from the pandemic.

CMS should provide effective guidance and assistance to nursing homes on how to comply with updated infection control requirements.

CMS should facilitate sharing of strategies and information to help nursing homes overcome challenges and improve care.

Develop and document strategic goals and metrics for inventory management that align with the company’s broader goals. Options might include measuring how frequently an MoE inventory shortage causes a train to be delayed and the extent to which MoE inventory shortages impact the company’s service capacity.

Assess the costs and benefits of updating inventory item information in the company’s inventory management system. At a minimum, assess the costs and benefits of updating, clarifying, and standardizing item names, descriptions, units of measure, and accompanying photographs, as well as options for doing so. Based on this assessment, determine what actions, if any, to take.

Develop and begin implementing a risk-based plan to secure inventory facilities across the company.

Update AMS to include limitations on how long contracts can be extended.

Provide evidence to support that the Authority corrected the 11 unit deficiencies for the 5 units and 7 building deficiencies for 4 buildings with outstanding deficiencies.

Determine the frequency of its quality control reviews of its inspections and work orders and update its quality control policy, training materials, and other resources as appropriate to ensure that its quality control process is consistently implemented.

Support that it has implemented its quality control policy for (1) monitoring the effectiveness of its unit and building inspections to ensure compliance with HUD's and its own requirements and (2) reviewing work orders to ensure that cited deficiencies are corrected in accordance with HUD's and its own requirements.

Provide evidence to support that the Authority corrected the four non-life-threatening deficiencies for the three units with outstanding deficiencies.

Implement adequate procedures and controls to ensure that the deficiencies identified during annual self-inspections are properly categorized and corrected in a timely manner.

Develop and implement a plan to manage and reduce its backlog of work orders. This plan should include but not be limited to (1) assessing and addressing staffing needs; (2) creating a timeline for completion of the work orders to ensure that its properties are maintained in decent, safe, and sanitary condition and in good repair; and (3) providing documentation showing that it is on track to meet the completion timeframe.

Implement adequate procedures and controls to ensure that inspection reports are uploaded to the Authority's electronic filing system and work orders are created in a timely manner. This process should include but not be limited to providing training to its staff on the Authority's systems, establishing timeframes for the creation of work orders, and monitoring the work order process.

Provide evidence to support that the Authority corrected the 3 non-life-threatening health and safety, and 19 non-health and safety deficiencies.

Develop and implement adequate procedures and controls to ensure that (1) the deficiencies identified during REAC inspections are corrected in a timely manner and (2) documentation is maintained to support that repairs were made.

Implement adequate controls to ensure that the Authority's information system properly tracks the completion of work orders.

Implement adequate controls to ensure that the correction of life-threatening deficiencies is reported to HUD accurately and in a timely manner.

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; CSOSA has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

[Description omitted; DOJ has determined that this recommendation contains information that is limited official use or classified.]

Review the 1,799 PPP loans totaling over $89 million that matched a DNP data source to ensure eligibility requirements were met and seek remedy or repayment of all loans deemed ineligible.

Review the 49 PPP loans totaling approximately $3.5 million and the 43 loans totaling approximately $7.2 million to ensure borrowers met eligibility requirements and seek remedy or repayment of loans deemed ineligible.

Review PPP loans in which the DNP hold codes were cleared to 1) identify those cleared using pre-decisional memos and 2) those cleared without sufficient evidence to support the reviewer’s loan decision and seek remedy or repayment of loans deemed ineligible.

Develop and implement controls, such as supervisory reviews, to ensure PPP loans and loans for future stimulus programs with DNP matches receive manual reviews, as required. The reviews should ensure that pre-decisional memos are not used to clear DNP hold codes and that loan files contain relevant and appropriate documentary evidence to support the loan review decisions.

Develop and implement clear guidance requiring responsible officials to maintain documentary evidence used to support loan decisions in the loan files.

Review the 59,893 PPP applications that matched a DNP data source to ensure borrowers met eligibility requirements and seek remedy or repayment of loans deemed ineligible.

Review the additional 47,940 PPP loans totaling over $1.7 billion, identified through the DNP data match, to ensure borrowers met the eligibility requirements and seek remedy or repayment of loans deemed ineligible.

(U) Rec. 1.a: Report is Classified.

(U) Rec. 1.c: Report is Classified.

1. We recommend that the Deputy Secretary of Commerce ensure the development and ongoing maintenance of a lifecycle cost estimate and schedule for the program in accordance with the Department's Acquisition Project Management Policy (DAO-208-16) and the U.S. Government Accountability Office's (GAO) Cost Estimating and Assessment Guide and Schedule Assessment Guide.

2. We recommend that the Deputy Secretary of Commerce ensure that the BAS Executive Board reviews the program's cost, schedule, and scope performance against baselines, as well as risk management and additional metrics needed to support adequate investment oversight.