Open Recommendations

Work with ARC to resolve the questioned cost totaling $19,040 of ARC funded equipment cost.

Revise policies and procedures to reflect the updated process for progress report tracking to ensure the timely submission of progress reports.

Evaluate NIJ's process for overseeing cooperative agreements, including the outcomes and lessons learned from this award, and develop and implement formalized guidance or a framework for NIJ award managers and scientists to follow for meeting its responsibility to have substantial involvement in cooperative agreements.

Remedy the $33,667 in unallowable questioned costs associated with the excess inventory.

Remedy $91,263 in funds to be put to better use.

Request Purdue to provide a breakdown of how funds were used for each performance area, as specified in the award special condition, including those funds expended on the human subjects work that was terminated; and, following the submission of that report, assess the reasonability of the $1.9 million spent by Purdue and its subrecipients on the goals that were not completed.

Evaluate NIJ's implementation of the special condition requirement to ensure that awardees provide appropriately detailed information about how award funds were used by purpose area to allow NIJ to monitor award accomplishments and assess the reasonability of how funds were used to support award outcomes.

Develop and distribute policies and procedures that incorporate controls to identify, report, and mitigate risks and challenges associated with DOJ-funded research that includes providing technology to offenders at various stages of the criminal justice process.

Ensure Purdue develops and implements appropriate internal controls to submit Grant Award Modifications, as required, and verify compliance with award requirements that are assigned to and executed by subrecipients.

Ensure Purdue develops and implements policies and procedures related to requirements to maintain documentation in support of performance achievements and metrics contained in federal award performance reporting.

Ensure Purdue develops and implements comprehensive policies and procedures to ensure appropriate subrecipient oversight, including defined Principal Investigators roles and responsibilities.

Remedy the $49,398 in unallowable questioned costs related to conducting human subject work during periods where such work was not allowed.

Remedy the $13,700 in unallowable questioned costs related to unapproved subrecipient budget categories.

Identify alternative methods for calculating the average cost to process Old-Age, Survivors, and Disability Insurance (OASDI) and/or Supplemental Security Income overpayments to ensure consistency across both programs.

Terminate collection activities for the 15 low-dollar overpayments we identified that had not been terminated or collected.

Review the remaining population of 3,733 low-dollar OASDI overpayments and terminate collection activities where appropriate.

Determine the criteria for when the cost of collection is not cost-beneficial and update policy to specify when collection actions should be terminated or suspended.

We recommend the Senior Vice President, Generation Projects and Fleet Services, to update the project management procedure to define rework and provide guidance for documenting and tracking rework.

The Chief Information Officer should ensure that requests are submitted timely to turn off monitoring as required.

The Chief Information Officer should develop enterprise-wide performance metrics to track incident resolution timeliness.

The Chief Information Officer should ensure that data quality reviews are performed for P1 and P2 tickets in accordance with the established procedures.

The Chief Information Officer should reevaluate the corrective action regarding incident ticket handling requirements and take additional steps to ensure that service providers are following incident ticket handling requirements.

Update policy to include the Vulnerability Risk Assessment Tool survey completion requirements for Tier 1 and Tier 2 postal facilities.

Develop a process to identify postal facilities that did not complete a Vulnerability Risk Assessment Tool survey and ensure that those facilities meet survey completion requirements.

Establish a process to monitor unresolved Vulnerability Risk Assessment Tool survey deficiencies across all tier levels to ensure timely resolution and verify accurate status and prioritization.

Revise policies and procedures related to the Vulnerability Risk Assessment Tool process to require facility management to update deficiency statuses, upon resolution, and communicate these changes to the field, once finalized.

1) Verify and track that all personnel involved in Vulnerability Risk Assessment Tool surveys have completed the most updated, required training, and 2) update applicable Vulnerability Risk Assessment Tool guidance and provide it to all postal personnel responsible for completing the surveys.

Update guidance for Tier 1 and Tier 2 facilities to require Postal Service personnel to perform Tier 3 Vulnerability Risk Assessment Tool surveys only in the off years that the Postal Inspection Service performs the Tier 1 and Tier 2 Vulnerability Risk Assessment Tool surveys.

We recommend LAN implement a process to allocate indirect costs to funding sources with sufficient documentation to allow for third party review.

We recommend LAN update its written policies to comply with LSC requirements and reflect current cost allocation practices.

We recommend LAN establish a review process requiring verification of PTO coding before submission to their Finance Department. Staff should be trained in the correct use of timekeeping codes, and all LAN employees should timely provide the Finance Department with complete timekeeping records, including category codes.

We recommend LAN develop a comprehensive standard operating procedure that outlines the current wage allocation and reconciliation process, including clear guidelines on documenting adjustments or changes to the process, personnel responsibilities, and timelines.

We recommend LAN review and revise system access controls to limit administrative rights to essential personnel, aligning user rights with specific roles. At a minimum, we recommend that LAN designate one individual as primary administrator to ensure that payroll staff cannot modify or approve their own pay.

We recommend LAN implement controls to ensure all disbursements are properly coded in the accounting system with grant codes and are supported by source documentation clearly indicating the funding source.

We recommend LAN implement a process to ensure only allowable expenses are allocated to LSC in accordance with applicable LSC requirements and guidance.

We recommend LAN strengthen controls to ensure invoices are paid timely by routinely reviewing outstanding payables and prioritizing payment of those approaching, or past, their deadline.

We recommend LAN ensure all invoices are clearly marked as “paid” following disbursement.

"We recommend LAN work with their Board to determine whether check request forms should remain a requirement for all disbursements.
• If they are required, ensure all disbursement packages include a completed form.
• If they are no longer required, update the Accounting Manual to establish disbursement procedures that ensure source documentation is modified to prevent duplicate payments."

We recommend LAN ensure all credit card charges are supported by the required documentation, per LAN’s policies and procedures, along with contemporaneous records that clearly state the business purpose and demonstrate compliance with LSC requirements.

We recommend LAN implement controls to ensure that all transactions are assigned a grant code in the accounting system and have supporting documentation that clearly identifies the funding source.

We recommend LAN document and enforce credit card spending limits, ensuring any deviations or temporary increases are approved by the appropriate individual with the reason documented.

We recommend LAN implement controls to ensure that only authorized cardholders can access credit card information. If a non-cardholder must make a purchase, prior written authorization (such as an email or memo) should be required and the transaction documented accordingly.

We recommend LAN update their Accounting Manual to include transaction and account limits and deadlines for submitting supporting documentation, as required by the LSC Financial Guide.

We recommend LAN implement procedures for adequate review of case timekeeping to ensure accurate and proper allocation of attorneys’ fees.

We recommend LAN implement procedures to ensure that the source and allocation of all investment income are adequately documented in sufficient detail and retained in accordance with applicable document retention requirements to support accurate financial reporting and compliance with LSC requirements.

We recommend LAN ensure consistency between their Fee Generating Cases Policy and the LAN Accounting Manual regarding the allocation of attorneys’ fees.

We recommend LAN document all asset movements, regularly replace damaged or missing tags and record inventory discrepancies in both the inventory records and the general ledger.

We recommend LAN promptly decommission outdated equipment and reinforce LAN’s Device Replacement Policy. Devices no longer under warranty or running unsupported systems should be retired or isolated with appropriate risk mitigation. Exceptions should be supported by documented business rationale.

We recommend LAN revise its Accounting Manual to include written procedures for inventory and disposal of IT and other sensitive equipment. The policy should require documentation of disposal method, date, approval, and valuation (if sold), and include controls to ensure protection of sensitive information on retired devices.

We recommend LAN require that complete, funding source budget-to-actual reports are prepared monthly, showing revenue and expenses by funding source. This requirement should be reflected in LAN’s written policies