Open Recommendations

Ensure a NARA executive oversees and monitors the periodic review and update of the policies and SOPs.

Update the travel policy and continue efforts to ensure that all written policies and procedures are reviewed and revised in a timely manner.

We recommend that FWS require the Department to resolve the $36,588 ($27,443 Federal share) in questioned costs related to inequitably allocated leave charges billed to the Wildlife and Sport Fish Restoration Program.

We recommend that FWS require the Department to develop an internal mechanism to ensure that all subawards over $30,000 are reported through SAM.gov, as required under 2 C.F.R. 170, Appendix A(a)

We recommend that FWS require the Department to develop and implement a written policy for leave allocation consistent with 2 C.F.R. 200.405(d) and 200.431(b).

We recommend that FWS require the Department to provide training to ensure employees charging to the Wildlife and Sport Fish Restoration Program understand the Federal requirements for allocating leave across multiple projects and activities.

We recommend that FWS require the Department to provide training on public reporting requirements to all employees responsible for the administration of subawards.

We recommend that ONRR update its policies and procedures to establish conditions that warrant or require a referral to ONRR Enforcement, such as the maximum number of informal compliance attempts or maximum number of days since an effort to obtain compliance was initiated, to provide sufficient time to resolve the case before expiration of the statute of limitations.

We recommend that ONRR update policies and procedures with clear instructions on the steps necessary to ensure that companies have achieved full compliance, including searching for collateral violations and coordination with other ONRR divisions for verification that there are no other related violations prior to closing the case.

We recommend that ONRR establish a process to periodically evaluate identified cases of noncompliance that have not been referred to enforcement to determine whether open cases may require additional actions, such as an enforcement referral or escalation.

We recommend that ONRR update its policies and procedures to prioritize referring cases related to unpaid royalties to the Office of Enforcement based on defined conditions, to include dollar thresholds, material significance, or when companies are repeat offenders.

We recommend that ONRR establish procedures to identify unpaid royalties related to missing reporting cases and issue Immediate Liability Civil Penalties unless an exception is warranted and adequately documented.

We recommend that ONRR provide training on updated procedures to ensure all investigators consistently pursue issuing penalties when warranted or document any exceptions.

We recommend that ONRR evaluate and report on the compliance of the responsible parties associated with the 25 cases of insufficient enforcement actions to determine if the entities corrected the identified violations.

We recommend that ONRR evaluate and report on the compliance of the responsible parties associated with the six closed reporting cases to ensure each company submitted all the required reports and payments or pursue appropriate enforcement actions.

The Commissioner, Small Business/Self-Employed Division, should take the necessary steps to provide FTP penalty relief to the 2,138 eligible taxpayers we identified, including but not limited to abating FTP penalties.

Implement standardized, written procedures to verify that applicable contract award and closeout contract file documentation requirements are met for each GLS contract.

Implement standardized, written procedures to verify that applicable Federal and Department independent government cost estimates and fair and reasonable price determination requirements are met prior to awarding a GLS contract. Implementing this recommendation could put up to $18.7 million in Federal funds to better use by improving GLS's ability to establish fair, reasonable, and realistic contract pricing.

Conduct an assessment of acquisition staff levels and needs, and based on this assessment, develop a plan to address shortages of critical acquisition personnel needed to carry out the Agency's contracting needs.

Review and take corrective action to address the approximately $11.5 million in questioned costs related to contracting officers awarding contracts without evidence that they had the proper warrant authority to do so.

It is recommended that GPO strengthen the controls related to the review and approval of employee separation personnel actions and reinforce the requirements in OPM's Guide to Processing Personnel Actions, specifically as it relates to the timeliness of review and approval.

GPO strengthens controls related to the review and certification of printing vendor invoices and reinforce the requirements in SOP 12-0023, Examination of Printing Invoices, specifically as it relates to supporting documentation requirements for vendor invoices.

It is recommended that GPO design and implement effective monitoring controls related to the review and approval for the processing of new hire employee actions and reinforce the requirements in OPM's Guide to Processing Personnel Actions, specifically as it relates to the timeliness of supervisor authorizations.

It is recommended that GPO design and implement monitoring controls related to the review and certification of employee timesheets and reinforce the requirements in GPO Directive 440.12C, specifically as it relates to the separation of duties between the timekeeper and certifying official roles.

It is recommended that GPO establish procedures within its review control for the OWCP liability adjustment to independently assess the reliability of data received from DOL. This may include performing reasonableness checks such as detailed trend/variance analysis, reconciliations, or reviewing supporting documentation.

Strengthen RD’s continuous review and monitoring controls to identify and timely deobligate ULOs that are not properly authorized and supported by appropriate documentation; that have been completed and not closed out; and under which no future expenditures are expected.

Determine whether the identified undocumented grant is valid, and properly document review and approval thereof.

Deobligate the identified invalid ULOs that are outstanding.

Identify key balances, such as high-risk balances or high dollar value items and ensure that supporting schedules agree with stated balances

Develop a plan for completing the FY 2026 internal controls assessment and resulting assurance statements, including the timing and who is responsible for completing the assessment

Perform the FY 2026 internal controls assessment and prepare the resulting assurance statements in accordance with Federal requirements and within the required due date

Establish and implement a financial reporting process to ensure timely preparation of an OMB Circular A-136-compliant AMR that is appropriate for its current size, staffing levels, and mission

Develop procedures to analyze systems, controls, and legal compliance to the extent necessary to prepare management's assurances related to FMFIA

For material transactions that sample support cannot be located, obtain alternative evidence such as confirmations from vendors, grantees or banks

Develop and document retention controls that take into consideration USADF's current structure

Establish and implement a financial reporting process to ensure timely preparation of quarterly and annual financial statements in compliance with OMB Circular A-136 that is appropriate for its current size, staffing levels, and mission

Determine personnel gaps in its financial reporting function and determine whether these roles can be filled by existing USADF personnel

Implement monitoring mechanisms to ensure adherence to federal financial management requirements and timely corrective action for deficiencies

Consider implementing alternative solutions, to provide internal control support, including FMFIA/A-123 testing and documentation updates

Develop and implement a streamlined internal control and risk assessment plan focused on the drawdown of operations, prioritizing high-risk areas such as disbursements, funds held outside of treasury (FHOT), grants, and closeout procedures to maintain compliance and financial integrity

Strengthen communication and accountability by issuing clear written guidance on roles and responsibilities for remaining personnel and establishing a simple escalation process for unresolved control issues

Strengthen their risk assessment process by considering the gap period between the last SOC 1 reports and PBGC’s fiscal year end to determine the sufficiency of internal controls relevant to PBGC’s financial reporting processed by the service organizations. Such considerations should be documented.

Design and implement additional controls based on the results of PBGC’s risk assessment process.

Due to the sensitive nature of the findings and recommendations in this report, its disclosure has been restricted.

Due to the sensitive nature of the findings and recommendations in this report, its disclosure has been restricted.

Due to the sensitive nature of the findings and recommendations in this report, its disclosure has been restricted.

Due to the sensitive nature of the findings and recommendations in this report, its disclosure has been restricted.

Due to the sensitive nature of the findings and recommendations in this report, its disclosure has been restricted.

We recommend that the Chief Operating Officer for Federal Student Aid (FSA), in conjunction with the Commissioner for NCES, require SNHU to update its existing policies and procedures for identifying full-time undergraduate students who were seeking their first postsecondary certificate or degree for the IPEDS SFA survey to ensure student cohorts are identified consistent with the Keyholder Handbook and survey instructions.

We also recommend that the Chief Operating Officer for FSA consider taking appropriate action pursuant to subpart G of 34 C.F.R. 668 because the school reported inaccurate and incorrect information to IPEDS through the SFA survey for the 2021–2022 reporting period.