Millennium Challenge Corporation:

Review of Compact Records and Information Management Program

GAO-13-615: Published: Jun 20, 2013. Publicly Released: Jun 20, 2013.

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David B. Gootnick
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gootnickd@gao.gov

 

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What GAO Found

In 2006, the Millennium Challenge Corporation (MCC) established a records and information management program to maintain and preserve its federal records. The program includes policies related to compact management records--a subset of MCC's federal records. These policies also address the handling of other compact-related information generated by MCC partner governments' accountable entities, which typically manage compact implementation until the 5-year compacts close. MCC's policies require that the entities transfer their compact management records to MCC for storage before compact closure. MCC also requires that partner governments retain compact-related information not classified as records, such as survey data and data quality reviews, for at least 5 years after their compacts close, to facilitate audits and analysis of MCC assistance. However, MCC does not require, and has not conducted, periodic reviews to determine whether it has received all compact-management records from the accountable entities consistent with federal internal control standards. As a result, MCC cannot be sure that it is meeting the federal requirement that it preserve all records documenting its functions, activities, and other transactions.

In reviews of five closed compacts--Armenia's, Benin's, El Salvador's, Ghana's, and Mali's--GAO found variation in the accountable entities' implementation of MCC document retention requirements and the partner governments' ability to retrieve requested compact-related information after the compacts closed. As required by MCC's compact closure guidelines, all five program closure plans that we reviewed contained some discussion of retaining and storing documents, but each accountable entity addressed the guidelines' requirements differently. MCC's guidelines do not provide a list specifying standard types of compact-related information that most compacts should retain. Such variation in approaches to retaining and storing compact-related information will make it more difficult for MCC to verify that standard compact information is retained in all partner countries after the compacts close. In addition, in a test of MCC's ability to retrieve documents from the partner governments after compact closure, GAO found that four of the five governments provided all or most requested documents within 30 days, but Mali's, which is involved in political turmoil, provided no documents. Political turmoil in Madagascar, another compact-recipient country, has also impeded MCC's ability to obtain compact information that may be needed to conduct future audits, evaluate project impact, or inform future compact designs.

Why GAO Did This Study

MCC has approved 26 bilateral compact agreements, providing a total of about $9.3 billion to help eligible developing countries reduce poverty and stimulate economic growth. MCC is subject to the Federal Records Act, which requires that agencies preserve all records documenting its functions and other important transactions.

GAO was asked to review MCC's management of records and information. This report (1) examines MCC's records and information management program and practices and (2) assesses partner governments' implementation of MCC's information retention guidelines. GAO analyzed MCC documents, interviewed MCC officials, and tested MCC's ability to retrieve compact-related information from five closed compacts. GAO selected these compacts because they closed after May 2011, when MCC's Program Closure Guidelines went into effect.

What GAO Recommends

To strengthen MCC's records and information management program, MCC's Chief Executive Officer should (1) develop a policy requiring--and conduct--periodic reviews of MCC's compact-management records to ensure they are complete, (2) revise guidelines to include a sample document retention schedule specifying standard types of compact-related information compacts should retain, and (3) review MCC's policy of delegating storage of most compact-related information to partner governments. MCC agreed with all three recommendations and stated that they have already taken steps to implement them.

For more information, contact David Gootnick at (202) 512-3149 or gootnickd@gao.gov.

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: To strengthen MCC's records and information management program, the Chief Executive Officer (CEO) should develop a policy requiring--and conduct--periodic reviews of each set of compact management records that MCC receives from partner governments, to ensure that the records are complete.

    Agency Affected: Millennium Challenge Corporation

    Status: Open

    Comments: In response to GAO's report, MCC stated in a letter dated August 2013 that it was considering a revision to is Policy and Procedures for Compact-Related Federal Record Keeping to include a bi-annual review of the Federal Records Management Repository for each Compact country.

    Recommendation: To strengthen MCC's records and information management program, the CEO should revise program closure guidelines to include a sample document retention schedule, specifying standard types of compact-related information that most compacts would need to retain.

    Agency Affected: Millennium Challenge Corporation

    Status: Open

    Comments: In response to our report, MCC reported in a letter dated August 2013, that it is developing a sample document retantion schedule to share with its partner coutnries, specifying standard types of compact-related documents that need to be retained upon closure of its compact.

    Recommendation: To strengthen MCC's records and information management program, the CEO should review MCC's policy of delegating the storage of compact-related information to partner governments, weighing the costs and benefits of storing more of this information at MCC headquarters.

    Agency Affected: Millennium Challenge Corporation

    Status: Open

    Comments: In it official comments to GAO's report, MCC stated that it agreed with all 3 recommendations and was taking steps to implement them. However, in a letter dated August 2013, MCC stated that it no longer agreed with our third recommendation to review MCC's policy of delegating the storage of compact-related information to partner goverments. GAO continues to believe the recommendation is valid and will monitor MCC efforts to implement it.

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