Open Recommendations

We recommend MSAC establish and implement controls that ensure Federal and Arts Endowment subawarding notification (2 CFR 200.332(b), General Terms 1 & 22), cost allowability (General Terms 13 & 2 CFR 200 Subpart E), and acknowledgment requirements (General Terms 3) are included in its grant contract documents.

We recommend MSAC strengthen its controls over subaward closeout to ensure all subawards are closed
before submitting the Federal financial report (General Terms 23).

We recommend MSAC establish procedures to evaluate and monitor its compliance with Federal and Arts
Endowment award requirements (2 CFR 200.303(c)).

We recommend MSAC establish controls that ensure compliance evaluations are conducted and gaps are
addressed (2 CFR 200.303(a)).

We recommend the NEA disallow $674,750 in unsupported Federal financial report costs from the 2019 Award.

We recommend the NEA disallow $16,761 of unsupported payroll costs - $4,507 from the 2020 Award; $7,281 from the 2021 Award; and $4,973 from the 2022 Award.

We recommend the NEA disallow $105,000 in honorifics from reported costs- $10,000 from the 2019 Award, $20,000 from the 2020 Award, $15,000 from the 2021 Award, and $60,000 from the 2022 Award.

We recommend the NEA disallow $194,315 in questioned or unallowable subrecipient costs - $41,211 from the 2019 Award FFR; $42,348 from the 2020 Award FFR; $76,387 from the 2021 Award FFR; and $34,369 from the 2022 Award FFR.

We recommend the NEA disallow the $50,000 unallowable ARP cost from the 2020 Award.

We recommend the NEA determine whether a refund is due for costs questioned in recommendation NEA 5.

EXIM's Office of Board Authorized Finance should develop and implement a policy to address changes in exposure fees following Board approval, including in co-financing transactions.

EXIM's Office of Board Authorized Finance should define the approval responsibility for changes in exposure fees.

EXIM's Office of Board Authorized Finance in coordination with Office of General Counsel should develop and implement guidelines or a checklist requiring management to verify that appropriate legal and policy guidance is in place prior to initiating direct loan transactions.

EXIM's Office of Board Authorized Finance should update procedures and checklists to ensure the SAM debt offset check is completed and reviewed by management prior to loan authorization.

The OIG recommends that the Executive Director for Operations establish thresholds for special act awards based on award value and frequency.

The OIG recommends that the Executive Director for Operations enforce documentation requirements for special act awards to ensure the awards are properly justified and comply with agency policy.

The OIG recommends that the Executive Director for Operations enforce retention guidelines for award justifications to support third-party reviews and for reconstruction purposes.

The OIG recommends that the Executive Director for Operations develop a formal process to prevent the duplication of awards for the same contribution or achievement.

The OIG recommends that the Executive Director for Operations establish procedures to validate the accuracy of award processing and ensure compliance with the OPM Operating Manual.

The OIG recommends that the Executive Director for Operations implement reconciliation and validation procedures for any office not using the performance award tool to prevent duplicate awards or overlapping appraisal periods.

The OIG recommends that the Executive Director for Operations provide guidance for prorating awards based on an employee’s work schedule and duration of employment during the appraisal period.

The OIG recommends that the Executive Director for Operations implement validation controls within the performance award tool to ensure that cash awards fall within the policy-defined limits for each performance rating.

The OIG recommends that the Executive Director for Operations track time-off awards to maintain compliance with the leave year limit and monitor their impact on productivity.

Distribute the 658 PII losses in Sampling Frame 1 to the appropriate component(s) for review to determine whether any losses are moderate, high, or major and, if so, identify and take the proper actions to mitigate those losses.

To prevent future employee errors related to reporting, assessing, and closing PII losses, evaluate the effectiveness of the processes and controls implemented by the Office of Privacy and Disclosure and implement changes as needed.