U.S. Commission on Civil Rights:

Deficiencies Found in Financial Management and Internal Controls

GAO-05-68R: Published: Mar 7, 2005. Publicly Released: Apr 6, 2005.

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The United States Commission on Civil Rights (Commission) was first established in 1957 as the Commission on Civil Rights. The Commission's life was extended in 1983 and reestablished again in 1994 with its current name. The Commission's purpose is to collect and study information on discrimination or denials of equal protection of the laws because of race, color, religion, sex, age, disability, or national origin, or in the administration of justice in such areas as voting rights, enforcement of federal civil rights laws, and equal opportunity in education, employment, and housing. The Commission has been subject to long-standing congressional concerns over the adequacy of its management practices and procedures, concerns that were reinforced by several GAO reports. In July 1997, we issued a report in which we found broad management problems at the Commission, including limited awareness of how its resources were used. In more recent studies, we found that the Commission lacked good project management and transparency in its contracting procedures and needed improved strategic planning. As a result of these reports and other concerns, we conducted additional work at the Commission. Specifically, Congress asked us to determine whether (1) the Commission's financial transactions (receipts, obligations, and expenditures) for the fiscal year ended September 30, 2003, were properly authorized, approved, and supported and (2) the Commission had effective internal controls over financial transactions and reporting. Congress also asked us to review the manner in which the Commission addressed its budget priorities.

Our tests of the Commission's fiscal year 2003 financial transactions identified substantial deficiencies in the underlying support for a significant level of its expenditures. Specifically, while our tests of $5.3 million of payroll transactions found them to be substantially correct, our tests of $4.9 million of nonpayroll-related transactions, including travel and procurement, found serious deficiencies in the supporting documentation underlying these transactions. These deficiencies precluded us from being able to determine whether as much as 18 percent of the statistically tested nonpayroll-related transactions of the Commission for fiscal year 2003 were valid. Our review of the Commission's internal controls over nonpayroll financial transactions and financial reporting identified fundamental weaknesses in internal controls. We found that the Commission lacked a formal comprehensive set of policies and procedures governing its financial management practices. We also identified serious deficiencies in the Commission's maintenance of financial records, enforcement of travel regulations, adherence to the Federal Acquisition Regulation (FAR) regarding the ordering process for contracted services from commercial vendors, adherence to provisions of the Prompt Payment Act, monitoring of budgetary resources, and cost accumulation and reporting. These deficiencies stemmed from a weak overall control environment, which led to BPD's decision to discontinue providing accounting services for the Commission after fiscal year 2003, citing inadequate management oversight and control. This weak control environment increases the risk of abuse of the Commission's financial resources. Our review of the manner in which the Commission addressed its budget priorities found that the Commission was unable to provide evidence of how its fiscal year 2003 budgetary resources were used to fulfill its statutory duties and to achieve the six goals listed in its fiscal year 2003 annual performance plan. Further, we could not determine how the Commission planned, communicated, and prioritized its budgetary resources, which makes it difficult for the Office of Management and Budget (OMB) and the Congress to understand whether the Commission is using its financial resources to achieve its mission and goals. Given the long-standing congressional concerns over the Commission's management priorities, we believe the Commission could enhance the transparency of its budgetary, financial, and operational activities.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: The Commission, through its staff director, should instruct the Commission chief of budget and finance, or his designee, to use the Program Assessment Rating Tool to identify weaknesses in Commission programs and to assist in the planning process.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In our report GAO-05-68R, we recommended that the Commission, through its staff director, instruct the Commission Chief of Budget and Finance, or his designee, to use the Program Assessment Rating Tool to identify weaknesses in Commission programs and to assist in the planning process. In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission stated that it plans to hire a highly qualified Director of Budget and Finance in late FY 2005 or early FY 2006 that would consider OMB's Program Assessment Rating Tool (PART) to identify weaknesses in Commission programs. After considering the costs and benefits of conducting a program self-assessment, the Commission requested an OMB PART in November 2005. The Commission's PART is likely to commence during the Spring of 2006. In late August 2006, GAO sent a follow-up request to the staff director requesting the resolution of this recommendation. We were told that the Commission participated in OMB's 2006 PART assessment beginning March 2006. Currently, the Commission was awaiting decisions on certain remaining PART questions. Subsequently, on behalf of the Staff Director, the Commission stated it would send the PART decisions once they are received from OMB. In April 2007, GAO again contacted the Commission requesting the decisions on the PART review conducted by OMB. We were given the OMB link to the Commission's PART assessment and told that we could print out the PART assessment from there--which we did. We reviewed the weaknesses identified and concluded that this recommendation had been implemented. Therefore we consider this recommendation closed as of April 2007.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to ensure that travelers provide appropriate documentation to support airfare transactions, including a payment receipt or itinerary from the travel agency that shows the airfare paid and boarding passes to indicate that the trip was taken.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to ensure that travelers provide appropriate documentation to support airfare transactions. According to George Harbison, Budget and Finance Chief, appropriate documentation is now being retained to support airfare transactions.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to provide travel vouchers by travelers as evidence that the trips were taken and to support amounts claimed for reimbursement.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16 establishing procedures to have travelers provide travel vouchers. According to George Harbison, Budget and Finance Chief, travelers must now prepare and submit travel vouchers after completion of official travel.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to document and retain for review travel transactions including travel authorizations prepared and signed by the Commission, as well as Commission-approved travel vouchers.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to document travel transactions including travel authorizations and approved travel vouchers. According to George Harbison, Budget and Finance Chief, travel authorizations and approved travel vouchers are now retained.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to maintain written justification for any cases where the Commission approved travel costs for reimbursement although the traveler could not provide appropriate documentation.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to maintain written justification for any cases where the Commission approved travel costs for reimbursement although the traveler could not provide appropriate documentation. According to George Harbison, Budget and Finance Chief, travelers are now required to submit documentation for travel costs and Commission justification might be needed in only a few cases.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to ensure that travel-related overcharges and traveler reimbursements are timely collected or offset against amounts due.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to ensure that travel-related overcharges and traveler reimbursements are timely collected or offset against amounts due. According to George Harbison, Budget and Finance Chief, the Commission is now timely collecting any travel overcharges and traveler reimbursements due.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to document in writing policies on travel accommodation practices for commissioners.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to document policies on travel accommodation practices for commissioners. According to George Harbison, Budget and Finance Chief, commissioners are now aware of the policies on travel accommodations.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to provide written travel policies to assist travelers in understanding the requirements and procedures to follow.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to provide written travel policies to travelers. According to George Harbison, Budget and Finance Chief, travelers are now aware of the Commission's travel policies.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to implement a travel policy requiring travelers to call to cancel a hotel reservation to avoid a no-show charge.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to implement a travel policy on hotel no-show charges. According to George Harbison, Budget and Finance Chief, travelers are now aware of the Commission's travel policy to cancel hotel reservations to avoid a no-show charge.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to charge the appropriate budget object code as evidenced by supporting documentation.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In GAO-05-068R, GAO recommended that the Commission on Civil Rights charge the appropriate budget object code as evidenced by supporting documentation. On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to charge the appropriate budget object code as evidenced by supporting documentation. According to George Harbison, Budget and Finance Chief, appropriate budget codes are now being charged.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to have evidence of the receipt of goods and services prior to approving transactions for payment and retain such evidence in the transaction files.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to have evidence of the receipt of goods and services prior to approving transactions for payment and retaining such evidence in the transaction files. According to George Harbison, Budget and Finance Chief, evidence of receipt of goods and services is now retained as part of the voucher package prior to payment approval.

    Recommendation: To address the issue we identified with respect to payroll transactions, the Commission, through its staff director or his designee, should instruct commissioners to submit time sheets biweekly or at least monthly so that the Commission recognizes expenses in the proper period for accounting purposes.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-15 concerning procedures for the submission of timesheets by Commissioners by the second Thursday of each biweekly pay period, or at least monthly. Commissioner timesheets will be submitted to the Office of the Staff Director for review and signature by the Staff Director to authorize payment. The timesheet will then be sent to the Human Resources Division for payroll processing. If Commissioner timesheets are not timely received, the Commissioner or their assistant will be called to inform them that timesheets are due.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to review account balances on a periodic and regular basis to identify unusual account balances.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16 establishing procedures to review account balances on a periodic and regular basis to identify unusual account balances. According to George Harbison, Budget and Finance Chief, account balances are being reviewed monthly.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to create and retain appropriate documentation in transaction files to support accounting entries made to adjust or write off assets and liabilities.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16 establishing procedures to create and retain appropriate documentation in transaction files to support accounting entries. According to George Harbison, Budget and Finance Chief, accounting entries are now supported by appropriate documentation.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to respond, and document the response, to the accounting service provider before any accounting entries are made on behalf of the Commission.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16 establishing procedures to respond to its service provider before accounting entries are made. In its June 6, 2005, response to the Congress required by 31 U.S.C. 720, the Commission stated that it is collaborating weekly with its existing service provider on policies and procedures that would include responding to accounting entries.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to retain sufficient evidence in transaction files to show that all transactions have been properly approved for payment.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to retain evidence in transaction files to show that all transactions have been properly approved for payment. According to George Harbison, Budget and Finance Chief, transaction approvals are now maintained as part of the voucher package.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to include evidence of transaction authorization, such as a purchase order, in each voucher package prior to approval for payment by the staff director or his designee.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to include evidence of transaction authorization, such as a purchase order, in each voucher package prior to approval for payment. According to George Harbison, Budget and Finance Chief, transaction authorizations are now maintained as part of the voucher package.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to prepare purchase authorizations in advance of the expenditure or provide documentation for any exceptions to be properly approved.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to prepare purchase authorizations in advance of the expenditure or provide documentation for any exceptions to be properly approved. According to George Harbison, Budget and Finance Chief, purchase authorizations are now prepared in advance of the expenditure.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to monitor the prompt processing of vendor invoices upon receipt so that vendors can be timely and accurately paid.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to monitor the prompt processing of vendor invoices upon receipt so that vendors can be timely and accurately paid. According to George Harbison, Budget and Finance Chief, vendor invoices are now being monitored for timely and accurate payment.

    Recommendation: To address the issues we identified with respect to nonsalary transactions, the Commission, through its staff director, should instruct the Commission chief of budget and finance to inform travelers via written communication that reimbursement will be made only for costs directly related to business purposes for government travel and not for personal charges.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to inform travelers that reimbursement will be made only for costs directly related to business purposes for government travel. According to George Harbison, Budget and Finance Chief, travelers are now aware of the Commission's travel policy on reimbursement for only official business purposes.

    Recommendation: To address the issues we identified with respect to procurement of goods and services, the Commission, through its staff director, should instruct the Commission chief of administrative services to prepare and maintain contract files, including contract award and contract administration, to document the basis for Commission decisions in acquiring goods and services from commercial vendors, to document each step in the acquisition process, and to document information for an outside review of the procurement process.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 4-21, establishing procedures to prepare and maintain contract files and document steps in the acquisition process to facilitate an outside review of the procurement process. According to Pam Duniston, Procurement Officer, procurement files now contain all documents and steps taken related to the procurement to enable external review.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should report required fiscal year 2003 procurement data to the Federal Procurement Data Center.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 4-21, establishing procedures to require reporting fiscal year 2003 procurement data to the Federal Procurement Data Center. In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission stated that it had cleared its backlog of FY 2003 procurement data by reporting this information to the Federal Procurement Data Center in May 2005.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should implement procedures for reporting future years' procurement data to the Federal Procurement Data Center on an annual basis.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 4-21, establishing procedures to require reporting future year procurement data to the Federal Procurement Data Center. In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission stated that it had reported more than 75 percent of its backlog of FY 2004 procurement data to the Federal Procurement Data Center in May 2005 and planned to continue compliance for FY 2005.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should require that payments to commercial vendors be properly processed and timely made in accordance with the requirements of the Prompt Payment Act.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures to require that payments to commercial vendors be properly processed and timely made in accordance with the requirements of the Prompt Payment Act. According to George Harbison, Budget and Finance Chief, vendor payments are now being timely processed to comply with the Prompt Payment Act.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should establish controls to timely monitor and reconcile budgetary transactions between Commission cuff records and its service provider reports.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In its June 6, 2005, response to the Congress, under 31 U.S.C. 720, the Commission stated that starting in May 2005, agency management has had weekly meetings with its current accounting services provider. One proposal at these meetings has been to monitor and reconcile budgetary transactions between Commission cuff records and its accounting service provider reports weekly. During FY 2005, the Commission entered into an agreement with the General Services Administration (GSA) for accounting services. With GSA, the Commission no longer uses informal agency "cuff records" to determine its account balances for agency decision-making but, instead, uses systems generated information to track the processing of financial transactions by GSA and works with GSA to reconcile accounts to supporting detail periodically. Therefore, we consider this recommendation closed as implemented.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should accumulate and report complete and adequate cost information by project.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission stated that it plans to require periodic review and revision of its budget object class codes to increase the accuracy of budget reporting by project. During FY 2005, the Commission revised outdated policies and concepts for apportioning and allotting the Commission's budget, and the operation of its financial systems (budget and accounting) and controls. As revised, Administrative Instruction 1-6 provides increased product cost information to Commissioners during and after the project planning process, and requires dates and deliverables sufficient to monitor and track the progress of projects. This was implemented in FY 2006 and we now consider this recommendation closed as implemented.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should strengthen the Commission's internal control environment by documenting management's commitment and attitude in implementing and maintaining an effective internal control structure, including audits and the adequate segregation of duties.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission stated that it is working with its current accounting services provider to develop new policies and procedures to improve internal controls that will be maintained in an internal manual with a first version planned by July 2005. During FY 2005, the Commission reported numerous agency reforms including strengthening overall agency external reporting procedures and monitoring agency compliance, creating a staff position to assist the Staff Director in developing, coordinating, and implementing the agency's reforms, and selecting an experienced financial manager to head the agency's Budget and Finance Division, segregate accounting duties, and work closely with GSA. The Commission also contracted out for FY 2004 and 2005 audits of its financial statements to independent CPA firms. In addition, during the first quarter of FY 2006, the Commission continued to move aggressively to reform its management and operations by providing management with monthly project cost information necessary to support decision-making, and foster budget and fiscal accountability. These actions demonstrate Commission management's efforts to strengthen its internal control structure. Therefore, we consider this recommendation closed as implemented.

    Recommendation: The Commission, through its staff director, should instruct the Commission chief of budget and finance, or his designee, to work with OMB within the apportionment process to identify meaningful program reporting categories that the Commission can use to report its obligations against in its SF-133, Reports on Budget Execution and Budgetary Resources, and other external reports.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission stated that it plans to hire a highly qualified Director of Budget and Finance in late FY 2005 or early FY 2006 that would work with OMB to develop meaningful budgetary reporting. Consistent with AI 3-2, during the apportionment process for FY 2006, the Commission worked with OMB to identify meaningful program reporting categories that could be used to report Commission obligations against its SF-133 report on the use of budgetary resources. This collaboration did, in fact, result in changes to the Commission's apportionment reporting categories. Unlike previous apportionment schedules, the FY 2006 apportionment schedule includes a budget breakdown by approved national office projects. Therefore, we consider this recommendation closed as implemented.

    Recommendation: The Commission, through its staff director, should instruct the Commission chief of budget and finance, or his designee, to consider the costs and benefits of doing program self-assessments and evaluate programs in terms of outcomes, outputs, and inputs.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission stated that it plans to hire a highly qualified Director of Budget and Finance in late FY 2005 or early FY 2006 that would consider program self-assessments and evaluate program outcomes, outputs, and inputs. During FY 2005, the Commission submitted its first Performance and Accountability Report (PAR). This report integrates the Commission's program and financial performance during FY 2005 and presents an assessment of the relative effectiveness of agency operations during a transitional year that saw a change in agency leadership late in the first fiscal quarter. As a whole, the Commission's PAR demonstrates an increasing capacity to report program costs, to evaluate actual and target performance, and to identify obstacles to achieving planned performance goals in comparison to previous Government Performance and Results Act (GPRA) reports submitted by the agency.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should require that all aspects of the Commission's procurement of goods and services be properly documented, including the method of solicitation, competition, and selection, in accordance with the FAR.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 4-21, establishing procedures to require that the Commission's procurement of goods and services be properly documented in accordance with the FAR. According to Pam Duniston, Procurement Officer, the procurement of goods and services is now documented in accordance with the FAR.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should require that travel transactions be timely submitted for reimbursement in accordance with the Federal Travel Regulation and be processed promptly.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures that require travel transactions be timely submitted for reimbursement in accordance with the FTR and be processed promptly. According to George Harbison, Budget and Finance Chief, Commission travelers are now aware that travel vouchers must be submitted within five working days as required by the FTR.

    Recommendation: To address the issues we identified with respect to procurement of goods and services, the Commission, through its staff director, should instruct the Commission chief of administrative services to document review of catalogs or price lists for at least three contractors or a review of information on GSA's on-line shopping service about the supply or service offered under the schedule before making a selection when procuring goods or services off the Federal Supply Schedule.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 4-21, establishing procedures to document its review of catalogs, price lists, or information on GSA's online shopping service when procuring goods or services off the Federal Supply Schedule. According to Pam Duniston, Procurement Officer, procurement files now contain evidence of review when procuring goods or services off the Federal Supply Schedule.

    Recommendation: To address the issues we identified with respect to procurement of goods and services, the Commission, through its staff director, should instruct the Commission chief of administrative services to ensure that all statements of work contain a provision on organizational conflict of interest and that contract files contain signed assurances that contractors have no organizational conflict of interest.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 4-21, establishing procedures requiring that all statements of work contain a provision on organizational conflict of interest and that contract files contain signed assurances that contractors have no organizational conflict of interest. According to Pam Duniston, Procurement Officer, statements of work now contain a provision on organizational conflict of interest and contract files now contain signed assurances that contractors have no organizational conflict of interest.

    Recommendation: To address the issues we identified with respect to procurement of goods and services, the Commission, through its staff director, should instruct the Commission chief of administrative services to provide for employees responsible for procurement activities to receive periodic training and updates on federal procurement rules, regulations, procedures, and issues.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 4-21, establishing procedures to provide periodic training and updates on federal procurement rules, regulations, procedures, and issues to employees responsible for procurement activities. In its June 6, 2005 response to the Congress under 31 U.S.C. 720, the Commission stated that it identified relevant training courses at a cost estimate of $8,000-$12,000 and has factored this cost into its FY 2006 operating plan and FY 2007 budget submittal.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should work with the Commission's current accounting service provider to develop specific policies and procedures for the Commission with respect to control activities and the processing, recording, and reporting of financial transactions.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission stated that beginning in May 2005, Commission management scheduled weekly meetings with its current accounting services provider to review GAO financial transactions recommendations, assess existing systems, identify weaknesses, and craft appropriate policies and procedures. Several proposed policies and practices have resulted from these meetings. During FY 2005, the Commission entered into an agreement with the General Services Administration (GSA) for accounting services. The Commission also revised outdated policies and concepts for apportioning and allotting the Commission's budget, and the operation of its financial systems (budget and accounting) and controls. Therefore, we consider this recommendation closed as implemented.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should require that all financial transactions be properly approved and supported before being processed and that documentation for transactions be readily available.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: On March 11, 2005, the Commission on Civil Rights issued Administrative Instruction 3-16, establishing procedures that require all financial transactions be properly approved and supported before being processed and that documentation for transactions be readily available. According to George Harbison, Budget and Finance Chief, all financial transactions are now approved and supported before processing and documents are properly filed.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should develop financial or operating plans and have periodic budget execution reviews of the status of obligations against these plans.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission stated that it plans to complete its strategic planning process in December 2005 with a plan that defines its mission, incorporates outcome oriented goals and objectives, and provides a foundation for developing annual goals. To implement the Strategic Plan, the Commission will have to develop financial and operating plans and then compare actual results against these plans. During FY 2005, the Commission revised outdated policies and concepts for apportioning and allotting the Commission's budget, and the operation of its financial systems (budget and accounting) and controls. Revised Administrative Instruction (AI) 3-2, Budget Execution, creates accountability and specificity regarding financial management and clarifies agency operating goals, principles, and processes. It also ensures the ability of the agency to accurately monitor and track its financial resources, including detecting violations of the Anti-Deficiency Act. Of particular interest in the updated AI is the requirement to develop budget-operating plans and conduct budget execution reviews. For FY 2006, the Commission has developed financial plans and is tracking budget obligations against these plans. Therefore, we consider this recommendation closed as implemented.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should establish an administrative fund control system to hold managers accountable for executing the budget against financial or operating plans.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission did not address an administrative fund control system to hold managers accountable for executing the budget against financial or operating plans. However, following the apportionment process for FY 2006, the Commission's budget office created budgetary allotments and spending plans for Commission offices and divisions to support their operations. The allotments and spending plans create accountability for managers for the operation of their offices/division within their resources to provide administrative funds control. The Commission's apportionment and allotment policies are contained in revised Administrative Instruction 3-2, Budget Execution. Therefore, we consider this recommendation closed as implemented.

    Recommendation: To strengthen the Commission's internal controls, the Commission, through its staff director or his designee, should require that the financial management system support the administrative fund control system.

    Agency Affected: Commission on Civil Rights

    Status: Closed - Implemented

    Comments: In its June 6, 2005, response to the Congress under 31 U.S.C. 720, the Commission did not address its financial management system or administrative fund control system. During the first quarter of FY 2006, the Commission continued to move aggressively to reform its management and operations by formulating and issuing specific apportionment and allotment procedures consistent with OMB Circular A-11. In addition, the Commission continued to establish agency goals, principles, and financial controls consistent with the requirements of OMB Circular A-11 on administrative control of funds, OMB Circular A-123 on management's internal control responsibilities, and OMB Circular 127 on financial management systems. These actions have moved the Commission's financial management system to support administrative funds control. Therefore, we consider this recommendation closed as implemented.

    Mar 27, 2014

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    Dec 23, 2013

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    Dec 11, 2013

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