Open Recommendations

We recommend that the Director of the U.S. Census Bureau reevaluate and update the design of the reinterview operation to meet the bureau’s goal of detecting and deterring falsification, considering (1) staffing and funding constraints, (2) FR behavior and experience, and (3) respondents’ reluctance to respond to reinterviews.

We recommend that the Director of the U.S. Census Bureau evaluate and determine the extent to which FR data falsification occurs during resident-level GQ interviews and revise the reinterview operation to include GQ residents, as appropriate.

We recommend that the Director of the U.S. Census Bureau develop and implement controls to ensure that reinterviews are conducted for remote Alaska cases in a timely manner.

We recommend that the Director of the U.S. Census Bureau develop and implement FR Data Tool policies and procedures that require supervisors to respond within 2 weeks of the initial inquiry.

We recommend that the Director of the U.S. Census Bureau update policies and procedures to ensure that field supervisors and regional survey managers are notified of response deadlines for inquiries developed through the FR Data Tool and implement controls to ensure that they respond within 2 weeks.

Resolve the $25,036 in questioned travel, fringe benefit, long-term visa, participant
payment, and summer salary expenses for which Cornell has not agreed to
reimburse NSF and direct Cornell to repay or otherwise remove the sustained
questioned costs from its NSF awards. Additionally, based on Cornell’s formal response to the audit report, we alsosuggest that NSF consider whether Cornell appropriately tracked and used all
funds awarded for participant support when resolving the $809 in questioned costs for REDACTED.

Direct Cornell to provide documentation supporting that it has repaid or otherwise
credited the $39,608 in questioned publication, travel, fringe benefit, and
promotional material expenses for which it has agreed to reimburse NSF

Direct Cornell to strengthen its procedures for ensuring that it only charges
allowable costs to NSF awards. Cornell’s updated procedures should:
Require Cornell to verify that research publications acknowledge the NSF
funding source(s) to be charged before charging the publication expenses to the
NSF award(s). Address how to properly review travel, participant, and promotional material
expenses to identify unallowable costs

Direct Cornell to update its policies to no longer permit personnel to charge
unallowable costs to NSF awards. These updated policies should not permit Cornell
to: Apply fringe benefits to stipend payments when paying stipends to Cornell
employees. Charge H-1B long-term immigration visa costs to NSF awards. Charge summer salaries at amounts that exceed the employee’s IBS at the time
the employee earned the summer salary

Resolve the $24,584 in questioned inadequately supported service, participant,
health insurance, travel, and salary expenses and direct Cornell to repay or
otherwise remove the sustained questioned costs from its NSF awards

Direct Cornell to provide documentation supporting that it has repaid or otherwise
credited the $7,544 in questioned service and participant expenses for which it has
agreed to reimburse NSF.

Direct Cornell to strengthen its procedures or other internal controls for obtaining
and maintaining documentation to support costs charged to NSF awards. The
updated procedures or controls should ensure:
Vendors submit service invoices that contain sufficient detail to support that the
costs invoiced are: (i) allowable per applicable federal, NSF, and Cornell policies;
and (ii) consistent with the approved quotation or purchase order.

Principal Investigators, or other appropriate personnel, capture all participant
payment information required per the Human Research Participant Payment
policy in Cornell’s Buying Manual.

Travelers submit airfare receipts that identify the airfare class purchased.
Charges for salary paid…

Resolve the $17,330 in questioned inappropriately allocated publication expenses
for which Cornell has not agreed to reimburse NSF and direct Cornell to repay or
otherwise remove the sustained questioned costs from its NSF awards.

Direct Cornell to provide documentation supporting that it has repaid or otherwise
credited the $4,991 in questioned publication, travel, and recruitment expenses for
which it has agreed to reimburse NSF

Direct Cornell to strengthen its policies and procedures and internal controls
related to allocating expenses to sponsored projects. The updated procedures
should ensure Cornell allocates:
Publication expenses to NSF awards consistent with the benefits received by the
acknowledged funding and appropriately documents its allocation methodology.

Travel that benefits multiple projects in a manner that is consistent with agreed upon allocation methodologies.

Recruitment expenses to NSF awards in a manner that is consistent with
recruited employees’ certified effort reports

Resolve the $593 in questioned indirect costs for which Cornell has not agreed to
reimburse NSF and direct Cornell to repay or otherwise remove the sustained
questioned costs from its NSF awards.

Direct Cornell to provide documentation supporting that it has repaid or otherwise
credited the $2,295 in questioned indirect costs for which it has agreed to
reimburse NSF.

Direct Cornell to strengthen its policies, procedures, and internal control processes
for applying its indirect cost rates to ensure it applies appropriate indirect cost
rates, including rates established in NSF budgets, to only those direct costs that it
should include in its Modified Total Direct Cost base per its applicable Negotiated
Indirect Cost Rate Agreement(s).

Direct Cornell to implement additional procedures to ensure that it performs—and
appropriately documents its performance of—risk assessments in compliance with
federal requirements for pass-through entities and Cornell’s internal policies

Direct Cornell to develop additional resources for subawardees that provide
guidance on how to ensure they appropriately account for and invoice expenses on a
cost-reimbursement basis consistent with subaward terms and conditions.

Direct Cornell to implement additional policies or procedures to ensure that
subawardees complete and submit—and that Cornell reviews and maintains—any
progress, technical, or other reports that Cornell requires per the subaward terms
and conditions.

Direct Cornell to implement additional procedures and/or internal controls, as
necessary, to ensure it complies with its internal policies when overseeing costs
charged to NSF awards. The updated controls should ensure Cornell verifies that it
and its personnel:
Use the correct procurement method and collect and approve all necessary
documentation prior to payment.

Submit expense reports and claim per diem at the lodging location rate prior to
approving travel expenses for reimbursement.

Appropriately tag all equipment charged to NSF awards for inclusion in Cornell’s
biennial physical inventory account.

The Farm Credit Administration conduct a cost-benefit analysis that addresses whether to maintain the current Emergency Operations Center given the improvements needed, alternatives available that would address long-term needs, and potential opportunities with ongoing modernization efforts for information technology equipment.

The Office of Agency Services, in coordination with the Office of Information Technology, develop Emergency Operations Center policies and procedures, that include:
• criteria for approving personnel working at the site,
• evacuation and drills,
• physical security controls, and
• coordination with the Farm Credit System Building Association and applicable Farm Credit Administration offices.

The Office of Agency Services coordinate with the Farm Credit System Building Association to complete the following at the Emergency Operations Center: [redacted] and determine if the current practices are efficient, effective, and meet the Agency’s needs.

The Office of Agency Services review and update the Continuity of Operations Plan, including appendices, and file it in a centralized location that is accessible to applicable Farm Credit Administration personnel.

The Office of Agency Services and Office of Information Technology develop a cohesive testing, training, and exercise plan that incorporates the Emergency Operations Center and includes a revised activation checklist for the Emergency Operations Center.

We recommend that the NOAA Deputy Under Secretary for Operations and the Assistant
Administrator for Satellite and Information Services consider monitoring and reporting the progress of the GOES-17 test to the joint agency program management council.

We recommend that the NOAA Deputy Under Secretary for Operations and the Assistant Administrator for Satellite and Information Services consider elevating the risk of a continuity gap in geostationary satellite data to the NESDIS Enterprise Risk Board.

We recommend that the NOAA Deputy Under Secretary for Operations and NESDIS consider developing off-ramps and contingency plans for the GeoXO program to reduce risk.

We recommend that the NOAA Deputy Under Secretary for Operations and NESDIS consider distinguishing between mitigation and contingency plans in the risk management database for the GeoXO program.

We recommend that the NOAA Deputy Under Secretary for Operations and NESDIS consider adding specific fields for triggers in the risk management database for the GeoXO program.

We recommend that the NOAA Deputy Under Secretary for Operations and the Assistant Administrator for Satellite and Information Services consider evaluating alternatives to the current life extension option to manage the risk of a continuity gap in geostationary satellite data.

Review and update VHA Directive 1660.07, “Medical Sharing/Affiliate National Program Office,” to delegate all required program office responsibilities for the community-based outpatient clinic contracts throughout the program’s life cycle to an appropriate headquarters-level office or collaboration of offices, as defined in VHA Directive 1217, “VHA Operating Units” and VA’s Acquisition Lifecycle Framework.

Develop and implement procedures for a headquarters-level office to monitor overall compliance with contract requirements and use the results to reassess program policies or contract requirements.

Develop a formal feedback process, such as a program life cycle review process, for contracting officers and contracting officer representatives, medical facilities, and contractors who work on community-based outpatient clinic contracts to provide lessons learned, issues encountered, and other feedback about establishing new clinics and the performance at the clinics.

Conduct an assessment of contractor compliance with all active community-based outpatient clinic contracts, then evaluate whether the community-based outpatient clinic contract performance metrics are measurable, reasonable, and attainable.

Coordinate with the Office of General Counsel to determine whether creating a separate contract line item from the operational costs for contracted community-based outpatient clinics to pay start-up costs, including construction costs, would assist in the administration of these contracts and increase competition among contractors; then update the community-based outpatient clinic performance work statement template to reflect any change made as a result of this consideration.

Assess how medical centers create and maintain the billable roster for community-based outpatient clinic contracts; based on the results, develop and implement efficient, accurate, and consistent procedures for developing and maintaining the billable rosters.

Coordinate with the VA medical centers that have VA-contracted community-based outpatient clinics to conduct a risk assessment to evaluate the responsibilities, time requirements, and qualifications of community-based outpatient clinic contracting officer representatives; then publish clear guidance or recommendations for facilities to make sure they have appropriately experienced, trained, and certified staff to oversee the performance of community-based outpatient clinic contracts.

Assess the certification levels of the CORs assigned to all CBOC contracts and make recommendations to the medical centers for assigning appropriately experienced CORs or to provide any additional training or assistance to existing CORs, if necessary.

Develop and implement procedures to require VA medical centers and contracting offices to verify that the Office of Information Technology can meet start-up requirements for new community-based outpatient clinic locations as part of the contract review process.

Review and evaluate how contracting offices rated community-based outpatient clinic contractors in the Contractor Performance Appraisal Reporting System, and if necessary, develop and disseminate additional guidance or training to contracting offices to help them appropriately rate community-based outpatient clinic contractors in accordance with the performance metrics and the broad categories in the Contractor Performance Appraisal Reporting System.

Determine whether positive and negative performance incentives should be used for community-based outpatient clinic contracts to motivate the contractors to provide high-quality health care, in accordance with FAR 37.6, FAR 16.202, and FAR 16.402-2.

a. If performance incentives are appropriate for community-based outpatient clinic contracts, ensure the Medical Sharing/Affiliate Office coordinates with the Office of General Counsel to develop and implement measurable, reasonable, and defensible positive and negative performance incentives.

b. If performance incentives are not appropriate for community-based outpatient clinic contracts, ensure the Medical Sharing/Affiliate Office and each network contracting office documents in the contract files the reasons why…

Develop and implement procedures to identify, evaluate, and incorporate commercial practices and contract types into the community-based outpatient clinic contract requirements templates before publishing updated versions, in accordance with 38 U.S.C. § 8153 and FAR part 10; the procedures should evaluate whether the contract payment structure for community-based outpatient clinic contracts is consistent with current commercial practices.

We recommend that the PBS Commissioner develop and implement a method to track and monitor building studies and ensure that PBS can retrieve all studies efficiently.

We recommend that the PBS Commissioner develop and implement policies and procedures to ensure that: PBS building study data is complete, accurate, and reliable; PBS is not wasting tax dollars on unnecessary or duplicative building studies; and building studies are preserved in accordance with the Federal Records Act of 1950 and GSA records-retention policies.

The Richard L. Roudebush VA Medical Center Director ensures that residents, fellows, and clinical service leaders understand and follow the requirement to document complete and pertinent information, including assessments and recommendations, in patients’ electronic health records.

The Richard L. Roudebush VA Medical Center Director educates providers on the requirements related to completing a clinical disclosure when an adverse event occurs, such as a delay in care.

The Richard L. Roudebush VA Medical Center Director ensures the episode of care related to the patient’s transfer is reviewed to determine whether an institutional disclosure is needed in accordance with Veterans Health Administration requirements, and takes action as warranted.