Open Recommendations

Implement a mechanism for the accountable officer to routinely monitor and ensure service'line staff who conduct physical inventory are designated in writing by the custodial officers and receive the appropriate nonexpendable inventory training annually.

Require the accountable officer and supply chain staff to verify and update the information in the Maximo system and create procedures to ensure all nonexpendable equipment is received through the warehouse, recorded in Maximo, delivered in a timely manner to the requesting service, and accepted by the custodial officer.

Address the physical security issues identified and provide recurring training on proper physical security controls and procedures to individuals with authorized access to the primary inventory point and warehouse.

Ensure all biological and nonbiological implants are recorded in the approved inventory management system and are routinely reconciled with other systems used to manage implant expiration dates.

Develop controls to ensure implant program staff identify and create local agreements for existing consignment implants and establish agreements for future consignment implants in accordance with national guidance.

Officially designate a facility implant coordinator and establish a monitoring mechanism to ensure compliance with implant coordinator roles and responsibilities.

Update the local implant management policy to clarify roles and responsibilities and to train staff in these roles about their implant management responsibilities.

USAID/Pakistan determine the allowability of $94,863 in ineligible questioned costs detailed on pages 32 to 38 of the audit report and recover any amount that is unallowable.

We recommend that the Centers for Medicare & Medicaid Services provide MACs with a thorough explanation of the QASP results.

We recommend that the Centers for Medicare & Medicaid Services update the audit program to incorporate revised change requests and TDLs so MACs can obtain a better understanding of CMS expectations and be evaluated on current requirements.

We recommend that the Centers for Medicare & Medicaid Services offer MACs additional training and guidance, based on the results of their QASP, and include best practices used by MACs.

OIG recommends that the Office of Global Partnerships revise 2 Foreign Affairs Manual (FAM) 970, "Public-Private Partnerships," to include a standardized action memorandum template for public-private partnerships. This template should outline all required elements from 2 FAM 970, which was updated in March 2024, to ensure completeness and consistency. The template should also include instructions for users to provide an explanation if any required element does not apply.

OIG recommends that the Office of Global Partnerships revise 2 Foreign Affairs Manual (FAM) 970, "Public-Private Partnerships," to specify the conditions in which memoranda of understanding (MOU) are mandatory or optional for public-private partnerships. Given the critical role of MOUs in establishing clear partnership arrangements, responsibilities, and expectations, this revision should also clarify the specific information responsible officials must include in the action memorandum if an MOU is not prepared.

OIG recommends that the Office of Global Partnerships update and clarify the criteria for what constitutes a partnership requiring approval under 2 Foreign Affairs Manual 970, "Public-Private Partnerships."

OIG recommends that the Office of Global Partnerships enhance existing training related to public-private partnerships (PPP) to include specific examples of Department of State (Department) partnerships that model the differing structures and governance that partnerships can have. At a minimum, the training should clearly explain that the requirements included in 2 Foreign Affairs Manual (FAM) 970, "Public-Private Partnerships," apply to all PPPs, including those for which a Department grantee is an intermediary or a grantee is acting on behalf of the Department in forming the partnership.

OIG recommends that the Office of Global Partnerships (GP) develop and implement a process to ensure that organizations responsible for public-private partnerships (PPP) approved prior to the 2013 establishment of 2 Foreign Affairs Manual 970, "Public-Private Partnerships," update documentation to comply with current oversight requirements. Specifically, GP should coordinate with relevant bureaus and offices as appropriate to ensure these PPPs are updated to incorporate all required elements, including due diligence and legal clearances.

OIG recommends that the Office of Global Partnerships update 2 Foreign Affairs Manual 970, "Public-Private Partnerships," to include specific requirements for the ongoing management, monitoring, and evaluation of public-private partnerships (PPP). The revision should clearly articulate that monitoring and assessing PPPs is required and outline minimum documentation expectations.

OIG recommends that the Office of Global Partnerships develop and implement a communication strategy to ensure that relevant bureau personnel are aware of the Foreign Service Institute training-PP440 - Public-Private Partnerships.

OIG recommends that the Office of Global Partnerships require Foreign Service Institute training-PP440 - Public-Private Partnerships-for all personnel involved with public-private partnerships and update 2 Foreign Affairs Manual 970, "Public-Private Partnerships," to include the requirement.

OIG recommends that the Office of Global Partnerships assess its data entry practices for the Public-Private Partnerships (PPP) database to determine whether the existing processes ensure that all required fields-such as start date, end date, and key information-are consistently completed during data entry. At a minimum, this review should consider procedural and relevant technical aspects of the PPP database that may affect data completeness.

Following the implementation of Recommendation 9, OIG recommends that the Office of Global Partnerships enhance the Public-Private Partnerships database data entry practices as needed. Enhancements may include introducing additional checks or prompts during data entry to help prevent omissions, improving the overall quality and reliability of the data.

OIG recommends that the Office of Global Partnerships develop and implement procedures for creating initial records for public-private partnerships (PPP) in the PPP database based on approved action memoranda. This procedure should outline specific steps and responsibilities to ensure the consistent entry of new records to the PPP database.

OIG recommends that the Office of Global Partnerships develop and implement guidance making all key fields in the Public-Private Partnerships database mandatory, including "Indicators," "Expected/Actual Results," and "Lessons Learned," to help ensure that critical information is consistently captured.

OIG recommends that the Office of Global Partnerships (GP) develop and implement guidance requiring the inclusion of short-term public-private partnerships (PPP) in the PPP database. At a minimum, GP should revise reporting guidance and update the PPP database to support accurate classification and tracking of these partnerships.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, update the Foreign Affairs Handbook (14 FAH-2 H-535) to include guidance on how to avoid improper technical direction that could initiate a constructive change for construction contracts. At a minimum, the update should include guidance on reviewing requests for information and other methods of communication to contractors.

OIG recommends that the Bureau of Overseas Buildings Operations develop and communicate a Construction Alert reminding Project Directors and Construction Executives to review and follow the guidelines detailed in the Foreign Affairs Handbook (14 FAH-2 H-535) regarding preventing constructive changes to contracts.

OIG recommends that the Bureau of Overseas Buildings Operations (OBO), in coordination with the Bureau of Administration, develop and implement a process for management to review and monitor documents referenced in contractor requests for equitable adjustment, such as requests for information and requests for design clarification, to identify improper technical direction initiated by Project Directors or other OBO personnel.

OIG recommends that the Bureau of Administration develop and implement a communications strategy to direct Contracting Officers to review requests for equitable adjustment for unauthorized commitments and to resolve unauthorized commitments in accordance with the ratification process.

OIG recommends that the Bureau of Overseas Buildings Operations (OBO) develop and communicate a Construction Alert to remind Project Directors and Construction Executives to review and follow the guidelines and steps developed in OBO's Construction Management Guidebook pertaining to requests for equitable adjustment, including documenting contract references and providing backup documentation to link changes to the contract.

OIG recommends that the Bureau of Overseas Buildings Operations, in coordination with the Bureau of Administration, develop and implement a process to periodically assess activities related to evaluating, resolving, and monitoring requests for equitable adjustment to ensure Project Directors and Contracting Officers adhere to federal and Department of State requirements.

OIG recommends that the Bureau of Administration develop, implement, and communicate policies and procedures directing Contracting Officers to obtain from the responsible Project Director all required documentation related to requests for equitable adjustment for construction contracts and to document their review of all findings of fact, written request for equitable adjustment analyses, and prenegotiation memoranda provided by Project Directors to assist Contracting Officers in making merit determinations.

OIG recommends that the Bureau of Administration develop, implement, and communicate policies and procedures for resolving requests for equitable adjustment.

OIG recommends that the Bureau of Overseas Buildings Operations, in coordination with the Bureau of Administration, develop, implement, and communicate a process for Project Directors and Contracting Officers to evaluate all cost elements submitted by contractors to determine necessity, reasonableness, and allowability. Additionally, the process should require that cost element evaluations be included in the independent government cost estimate and prenegotiation memoranda.

OIG recommends that the Bureau of Overseas Buildings Operations, in coordination with the Bureau of Administration, develop, implement, and communicate policies and procedures for Project Directors and Contracting Officers to comply with the cost principle requirements for construction contracts in Federal Acquisition Regulation 31.203.

Once Recommendation 10 has been implemented, OIG recommends that the Bureau of Overseas Buildings Operations (OBO), in coordination with the Bureau of Administration, develop and implement training for OBO staff and Contracting Officers on the policies and procedures related to cost principles.

OIG recommends that the Bureau of Overseas Buildings Operations (OBO) develop and implement a process to identify delays in responding to contractors' requests for equitable adjustment. At a minimum, the process should include controls that would trigger OBO management action after a specified period of time without resolution.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, take the following actions: (1) determine whether the questioned costs of $80,113, which were considered unsupported, for three requests for equitable adjustment for the New Embassy Compound Asuncion, Paraguay, construction contract (SAQMMA17C0082) were supported and (2) recover any costs determined to be unsupported, as shown in Table B.1.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations (OBO), take the following actions: (1) determine whether the questioned costs of $5,887, which were considered unsupported, for seven requests for equitable adjustment for the New Embassy Compound Beirut, Lebanon, construction contract (SAQMMA17C0079) were supported and (2) recover any costs determined to be unsupported, as shown in Table B.2.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations (OBO), take the following actions: (1) determine whether the questioned costs of $25,663, which were considered unsupported, for six requests for equitable adjustment for the New Embassy Compound Tegucigalpa, Honduras, construction contract (19AQMM19C0223) were supported and (2) recover any costs determined to be unsupported, as shown in Table B.3.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, take the following actions: (1) determine whether the questioned costs of $3,078,171, which were considered unallowable, for two requests for equitable adjustment for the New Embassy Compound Beirut, Lebanon, construction contract (SAQMMA17C0079) were allowable and (2) recover any costs determined to be unallowable, as shown in Table B.4.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, take the following actions: (1) determine whether the questioned costs of $173,720, which were considered unallowable, for six requests for equitable adjustment for the New Embassy Compound Tegucigalpa, Honduras, construction contract (19AQMM19C0223) were allowable and (2) recover any costs determined to be unallowable, as shown in Table B.5.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, (1) review all contract modifications for the New Embassy Compound Tegucigalpa, Honduras, construction contract (19AQMM19C0223) to identify all costs associated with violations of the cost principle requirements in Federal Acquisition Regulation 31.203, which govern the selection of a distribution base for allocating indirect costs, and (2) recover any costs determined to be unallowable.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations, (1) review all contract modifications for the New Embassy Compound Beirut, Lebanon, construction contract (SAQMMA17C0079) to identify all costs associated with violations of the cost principle requirements in Federal Acquisition Regulation 31.203, which govern the selection of a distribution base for allocating indirect costs, and (2) recover any costs determined to be unallowable.

OIG recommends that the Bureau of Administration, in coordination with the Bureau of Overseas Buildings Operations (OBO), take the following actions: (1) determine whether the questioned costs of $725,509, which were considered to be unsupported, for request for equitable adjustment 003 for the New Consulate Compound Hyderabad, India, construction contract (SAQMMA16C0274), were supported and (2) recover any costs determined to be unsupported, as shown in Table B.6.

Record correct death information on the Numident, terminate payments, and initiate collection of the overpayments or release the underpayments for the deceased beneficiaries in our populations.

Add death information to the Numident for the identified deceased non-beneficiaries.

Make improvements to the Death Information Processing System, such as adding a Numident match to assess Online Verification System discrepancies and resolving minor Social Security number discrepancies before rejecting a state death report.

We recommend the Vice President and Controller, Corporate Accounting, include specific training for expense approvers (managers and delegates) as a part of annual TVA One Card training or as a separate module to be completed periodically.

We recommend the Vice President and Controller, Corporate Accounting, consider creating a report in the expense management system that Expense Administration personnel can use to periodically test for split transactions.

We recommend the Vice President and Controller, Corporate Accounting, for exceptions identified during the audit, contact the approving managers and reinforce their responsibilities for ensuring TVA One Card expenses are appropriate.