Open Recommendations

The LB&I Division, SB/SE Division Examination, Criminal Investigation, RAAS, and the Digital Assets Initiative Project Office develop a compliance plan that includes the use of Form 1099-DA data, case identification, and case selection of digital asset cases.

Resolve key Integrated Financial and Acquisition Management System challenges and ongoing concerns identified by officials from the Office of Acquisition, Logistics, and Construction and the Office of Acquisition and Logistics before further deployment of the acquisition module.

Take immediate action to review 1,818 SVOG awards that we identified as high-risk of potential ineligibility and recover any funds from recipients who did not meet the requirements.

Finalize and implement updated guidance dated April 18, 2024, to terminate the award for unresponsive recipients and initiate actions to recover funds within the stated timeline.

Assess staffing and procedures to ensure post-award reviews are conducted in a prompt manner. Use the results of the assessment to improve processing times to ensure reviews are completed in time to accommodate relevant statute of limitations.

Determine the allowability of $3,098,895 in questioned direct labor costs on pages 6-7 of the audit report and recover any amount that is unallowable.

Require World Vision to develop and implement policies and procedures to periodically record and review time worked and any proportional allocation of the costs for greater accuracy.

Require World Vision to develop and implement policies and procedures to establish a requirement to document the basis of the allocation percentages.

Require World Vision to develop and implement policies and procedures to ensure that management is verifying and documenting the percentage of labor hours that employees charged to awards.

Require World Vision to develop processes and establish controls to ensure each of World Vision offices are submitting the Value-Added-Tax reports by April 16 of the preceding year.

Require World Vision to establish controls to ensure each of its offices submit a separate annual report for each of its reporting responsibilities by the established deadline or obtain concurrence from USAID to utilize reports for multiple reporting requirements.

Determine the allowability of $144,372 in questioned direct costs on page 12 of the audit report and recover any amount that is unallowable.

Require World Vision to develop and implement policies and procedures to ensure adequate documentation (e.g., invoices, itemized receipts, and basis) is created and/or maintained to adequately support direct costs claimed.

Require World Vision to execute a record retention and audit response policy where documents are maintained and readily available in a timely manner to adequately support direct costs claimed, specifically considering the requirements of Code of Federal Regulations.

Ensure that there is a process for employees to file a retaliation claim with the OIG when a security clearance review or suspension lasts longer than 1 year

Analyze whether and under what circumstances its policies permit identifying and removing sensitive items from a crime scene, whether the crime scene is managed by the FBI or another law enforcement agency, particularly following an agent- or officer-involved shooting;

Develop guidelines for identifying and removing sensitive items, including appropriate documentation requirements and standards for involvement by agents involved in or witnesses to a shooting

Conduct training of FBI HRT and SWAT units to ensure that these standards are consistently implemented and followed.

Review charged-off PPP loans to ensure all eligible loans are reported to commercial credit reporting agencies, as required.

Require personnel to conduct periodic monitoring and reviews of SBA’s automated processes for PPP and future stimulus loan programs to ensure all eligible loans are reported to commercial credit reporting agencies, as required.

Identify the credit reporting agencies to whom SBA must report current and delinquent loans for PPP and future stimulus loan programs.

Review charged-off PPP loans to ensure that all eligible loans are referred to Treasury, as required.

Require personnel to conduct periodic reviews of its automated Treasury referral process for PPP and future stimulus loan programs to ensure all eligible loans are referred to Treasury, as required.

Conduct lender reviews to ensure lenders complied with their communication, servicing, and debt collection activity requirements. If not, require the lender to bring the loan into compliance or seek recovery of the guaranty paid by SBA as appropriate.

Require lenders to submit evidence of communication, servicing, and debt collection activities with the borrower prior to guaranty purchase for PPP and future similar programs to foster and maintain program integrity.

Develop an allocation methodology that will ensure that all attorneys’ fees are proportionately allocated to the fund in which the LSC grant is recorded in the same proportion that the amount of LSC funds were spent on a case or representation.

Review all LSLRA reimbursements within the audit period (January 1, 2022 to May 31, 2023) to verify that the employees reimbursed were at the experience level 24 and below, per the CBA. Document the results and any deviations from the policy, including review and approval.

We recommend that the Executive Director notify and obtain approval from LSC for the purchase of 50 laptops exceeding $25,000.

We recommend that the Executive Director develop and implement a process for tagging capitalized property and equipment.

We recommend that the Executive Director conduct a physical inventory of capitalized property and equipment as soon as possible, document the results, and do so at least every two years.

Update and implement contracting policies to include the following: • requirements for sole source justification;• discouragement of automatically renewing contracts, when possible and if terms allow. If automatically renewing contracts are unavoidable, consider setting up automated reminders to periodically reevaluate contracts;• requirements for periodic re-competition of contracts, when appropriate; and• requirements for full documentation for each contract action, including the request for proposals, vendor selection and approval.

We recommend that the Executive Director implement a control to ensure only authorized cardholders have access to card information. In the event another staff member needs to use a credit card and the cardholder cannot make the purchase for them, adequate documentation should be maintained to show that the cardholder authorized the purchase and access to the card was limited.

We recommend the Executive Director update NJP’s written policies for credit cards to include, at a minimum, the following:• guidelines on personal use and disallowed charges;• guidelines on properly documenting any deviations from policy;• restrictions on cash advances and ATM withdrawals;• deadlines for providing supporting documentation;• procedures for cardholders to review and acknowledge credit and purchase card policies.

We recommend that the Executive Director document the complete cost allocation process including the adjustments made to arrive at the final allocations for indirect costs.

We recommend that the Executive Director enable distinct user access roles for the NJP accounting staff that are commensurate with their responsibilities to ensure adequate segregation of duties is maintained in the accounting software.

We recommend that the Executive Director implement a process requiring dated approvals prior to expenses being incurred.

We recommend the Executive Director establish a process to document advance approval for employee travel, and, if appropriate, set a threshold above which such approval must be documented and not only given verbally.

We recommend that the Executive Director develop policies to ensure the timely disposition of outstanding checks.

We recommend that the Executive Director ensure NJP’s Accounting Manual (and, if applicable, Personnel Manual) is updated to include the grantee’s processes surrounding the referenced criteria. This includes:• payroll procedure details,• roles/responsibilities,• frequency,• documentation requirements, and• review/approval requirements (including changes/adjustments).

OIG recommends that the Department of State’s Executive Secretary, or another official with delegated authority, finalize and sign the updated memorandum of agreement with the Department of Defense that governs noncombatant evacuations (previously titled “Memorandum of Agreement Between the Departments of State and Defense on the Protection and Evacuation of U.S. Citizens and Nationals and Designated Other Persons from Threatened Areas Overseas,” dated July 14, 1998) to memorialize the agencies’ arrangements for the collection, tracking, analysis, and sharing of evacuee data.

OIG recommends that the Department of State's Executive Secretary, or another official with delegated authority, finalize the "Memorandum of Understanding Between Defense Manpower Data Center (DMDC) and Department of State (State) for Non-Combatant Evacuation Operation Tracking System (NTS) Agreement Number: M2330" to improve noncombatant evacuation operation (NEO) data collection and sharing before, during, and after a NEO.

OIG recommends that the Department of States Executive Secretary, or another official with delegated authority, finalize and sign the updated memorandum of agreement with the Department of Defense that governs noncombatant evacuations (previously titled Memorandum of Agreement Between the Departments of State and Defense on the Protection and Evacuation of U.S. Citizens and Nationals and Designated Other Persons from Threatened Areas Overseas, dated July 14, 1998) to memorialize the agencies arrangements for the collection, tracking, analysis, and sharing of evacuee data.

OIG recommends that the Department of State's Executive Secretary, or another official with delegated authority, finalize the "Memorandum of Understanding Between Defense Manpower Data Center (DMDC) and Department of State (State) for Non-Combatant Evacuation Operation Tracking System (NTS) Agreement Number: M2330" to improve noncombatant evacuation operation (NEO) data collection and sharing before, during, and after a NEO.

Require International Rescue Committee to develop and implement procedures to include complete environmental information in its program reports or obtain Agency approval to exempt recipients from the reporting requirements.

OCIO to follow OFM policies and procedures for collecting advance payments prior to providing products or services and review the $29.5 million in questioned costs identified in this report after implementing recommendation 7.

OCIO to update and publish billing rates to approximate cost recovery in accordance with 49 U.S. Code (U.S.C.) 327. Implementing this recommendation could put up to $194 million in funds for better use.

OFM to develop procedures to prevent future overbillings such as the $16,949.05 overbilled and identified in this report as a questioned cost.

OCIO to develop and implement a review process to validate the charges in its Financial Management System are accurate prior to providing OFM documentation used to bill customers.

OCIO to follow the procedures for reporting WCF transactions to OFM, including the $14.7 million identified in this report in accordance with DOT Order 2300.3B.

OFM to develop and implement written procedures for determining if the WCF is recovering costs and identifying advances and excess funds that should be returned to Treasury.