Open Recommendations

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to obtain supporting documentation that all nonpublic schools that received EANS-funded services and assistance have a nonprofit status.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to return the $21,312 in CRRSA EANS funds that were expended improperly for services and assistance for a nonpublic school.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to require the contractor to provide sufficient support for the $297,477 of unsupported CRRSA and ARP EANS-funded expenditures or return funds to the Department.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to conduct a full review of the contractor’s vendor service fees to determine reasonableness. Return EANS funds for any vendor service fees deemed to be unreasonable.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require the Governor of Wisconsin and Wisconsin’s State Superintendent of Public Instruction to ensure that assets purchased with EANS funds are tracked in accordance with Federal requirements.

FHFA's DBR Deputy Director should ensure that ORAM evaluates its current internal model risk management practices in line with FHFA’s model risk management supervisory expectations (defined in AB 2013-07 and AB 2022-03) and design controls to (1) periodically review and maintain its model risk inventory (to include a risk-based validation schedule), (2) engage external resources to perform independent model validations in accordance with the validation schedule, and (3) conduct model performance tracking. Further, ORAM should update and finalize its policies and procedures to reflect the internal model risk management practices adopted.

FHFA's DBR Deputy Director should ensure that ORAM evaluates its current practices for maintaining documentation of the review and approval of inputs and outputs and implements policies and procedures to communicate requirements for maintaining this documentation.

FHFA's DBR Deputy Director should ensure that ORAM evaluates its current tracking mechanism for FHLBank requests for approval of market risk model changes and implement policies and procedures to ensure that the date that a complete model change approval request is received is tracked.

Rec 1.a: The DoD recommended that the Under Secretary of Defense for Research and Engineering develop or revise their existing procedures to require that implementation plans be developed based on industry best practices and include, at a minimum, timelines with specific milestones, roles and responsibilities, and metrics for evaluating and monitoring progress.

Rec 1.b: The DoD recommended that include in the procedures developed in accordance with Recommendation 1.a, a requirement to review and update implementation plans, at a minimum of once each year.

Rec. 2.a: The DoD recommended that the DoD Chief Information Officer review and update the 5G Implementation Plan to include timelines with specific milestones, roles and responsibilities, and metrics for evaluating and monitoring the DoD's progress toward implementing 5G.

Rec. 2.b: The DoD recommended that the DoD Chief Information Officer periodically reassess and update the 5G Implementation Plan, as needed.

Revise and implement SE's Document Retention Policies for Smithsonian Enterprise stores to:
a) require retail directors to periodically communicate the contents of this document to store management, and
b) require retail directors to perform periodic checks and document their review to ensure that financial document retention complies with SE policy.

Revise and implement the Retail Green Bag Audit, Store Register Audit, and Retail Safe Fund procedures to:
a) assign specific positions with the responsibility to conduct audits and daily safe counts,
b) require retail directors and group managers to document their review of monthly audits, and
c) require retail directors to document their quarterly review of daily safe count sheets.

Update and implement SE's Separation/Termination Checklist to include a step to block separated employees’ POS system access on their last day of employment.

Revise and implement the Discounts procedure to:
a) reflect only valid discounts,
b) require that the procedure be reviewed and updated periodically, and
c) require that the discount codes programmed in the POS system be reviewed and updated periodically so only authorized and valid discount codes are applied to transactions.

EXIM’s Office of the Chairman, in coordination with the Office of Policy Analysis and International Relations, the Office of Board Authorized Finance, and Office of General Counsel, should propose updated Environmental and Social Due Diligence Procedures and Guidelines for Board review and approval that incorporates, as necessary, revisions of applicable international standards.

EXIM’s Office of the Chairman, in coordination with the Office of Policy Analysis and International Relations, the Office of Board Authorized Finance, and the Office of General Counsel, should produce updated Environmental and Social Due Diligence Procedures and Guidelines for Board review and approval that clarify whether and, if so, how the ESPG relates to domestic transactions.

The Office of General Counsel should produce a written opinion on the circumstances under which Board members may withhold or approve transaction based upon environmental effects.

EXIM’s Office of Board Authorized Finance should establish policies and procedures establishing clear milestones for required environmental and social due diligence documentation.

EXIM’s Office of Board Authorized Finance should develop a plan to ensure the Engineering & Environment Division is properly resourced to conduct the required technical reviews and environmental assessments.

EXIM’s Office of Board Authorized Finance should develop a written policy or procedure that outlines the process for addressing when a project’s implementation does not align with EXIM’s Environmental and Social Due Diligence Procedures and Guidelines after the Board has approved the transaction.

EXIM’s Office of Board Authorized Finance should develop a written policy or procedure that defines when an environmental and/or social due diligence review is necessary for any restructuring or modifications requiring Board re-approval.

Develop and implement a contingency plan to address potential future staffing challenges that may arise, to mitigate delays in implementing necessary improvements across the applicable FISMA domains.

Establish and execute a monitoring plan to make sure that all information technology policies and procedures, including referenced standards and guidance, are reviewed and updated in accordance with the timeliness requirements defined by EAC policy.