Open Recommendations

The CPSC develop and maintain adequate documentation of EXHR’s determinations regarding applicants who did not pass the prescreen waiver process.

We recommend that the Assistant Secretary for Elementary and Secondary Education require OESE to review the work of program officers to ensure that for future SBMH grant competitions they screen all grant applications for all application requirements before entering them into the peer review process and ensure that review of requirements checklists are completed before making new awards.

We recommend that the Assistant Secretary for Elementary and Secondary Education require OESE to review the work of program officers to ensure that for future SBMH grant competitions they consult with their program attorney, create a written justification, and obtain the principal officer’s approval before deviating from or changing the ATRP.

We recommend that the Assistant Secretary for Elementary and Secondary Education require OESE to review the work of program officers to ensure that for future SBMH grant competitions they consistently follow records retention policies for official grant files as described in the Handbook.

We recommend that the Assistant Secretary for Elementary and Secondary Education verify that OESE developed, finalized, and implemented a program monitoring plan for the fiscal year 2022 SBMH Grant Program cohort. The plan should consider the use of desk reviews for a sample of grantees.

We recommend that the Assistant Secretary for Elementary and Secondary Education verify that OESE retains records of all SBMH Grant Program monitoring activities, including but not limited to email and telephone communications, grantee performance-related calls, and reviews of drawdown reports and APRs, in official grant files.

We recommend that the Assistant Secretary require OESE to develop, finalize, and implement procedures for reviewing grantees’ APRs and documenting the reviews of those APRs. At a minimum, the review procedures should cover (a) the quality of Government Performance and Results Act of 1993 data, (b) how to assess a grantee’s progress toward achieving approved goals, and (c) follow up with grantees when the information they provide is inaccurate or incomplete.

We recommend that the Assistant Secretary require OESE to implement the risk mitigation strategies as designed in the grant funding slates for new SBMH Grant Program awards and noncompeting continuation awards.

(U) Rec. A.1: This recommendation is Controlled Unclassified Information

(U) Rec. A.2.a: This recommendation is Controlled Unclassified Information

(U) Rec. A.2.b: This recommendation is Controlled Unclassified Information

(U) Rec. A.2.c: This recommendation is Controlled Unclassified Information

(U) Rec. A.2.d: This recommendation is Controlled Unclassified Information

(U) Rec. A.3: This recommendation is Controlled Unclassified Information

(U) Rec B.2: This recommendation is Controlled Unclassified Information

(U) Rec. B.2: This recommendation is Controlled Unclassified Information

(U) Rec B.3.a: This recommendation is Controlled Unclassified Information

(U) Rec B.3.b: This recommendation is Controlled Unclassified Information

We recommend that the Acting Assistant Secretary for the Office of Elementary and Secondary Education require the Nevada Department of Education to require Douglas to return to the U.S. Department of Education the $5,416 that Douglas improperly charged to the ARP ESSER grant for its LEA marketing project or reallocate the funds to other allowable costs. Identify any additional improper charges to the ARP ESSER grant for the LEA marketing project, including those made during periods not covered by our review, and if applicable, return the funds to the U.S. Department of Education or reallocate them to other allowable costs.

NIH should clarify for NIH-funded institutions which monetary donations they must report to NIH as other support.

We recommend that Region III management conduct a physical asset inventory to reflect the current information technology assets located at Region III.

The Office of the General Counsel (OGC) should issue and communicate guidance to the agency on ensuring and documenting how EXIM will comply with Section 2(k) of EXIM’s Charter throughout the transaction process, including timeline adjustments and delays.

The Office of Board Authorized Finance (OBAF) should develop and implement a formalized system for electronically tracking pending transactions and documenting the rationale behind timeline changes and delays for pending transactions. This process should include structured reporting mechanisms to provide non-sensitive, public-facing updates on major transactions, strengthening stakeholder engagement, increasing transparency, and ensuring compliance with EXIM’s statutory obligations under Section 2(b)(1)(J) of the EXIM Charter. Additionally, EXIM should consider establishing performance benchmarks for different transaction types to help manage processing expectations while accounting for necessary due diligence and risk assessments.

The Chair should coordinate with the Board to implement a process for advancing transactions for a vote that includes criteria that are objective, transparent, and compliant with Section 2(k) of EXIM’s Charter.

Recommendation withheld based on applicable Freedom of Information Act exemptions.