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    Federal Agency: "American Battle Monuments Commission"

    5 publications with a total of 15 open recommendations
    Director: Clark, Cheryl E
    Phone: (202) 512-9377

    3 open recommendations
    Recommendation: The Commission should direct the appropriate officials to establish and implement written policies and procedures requiring timely and continuous supervisory review of all financial transactions.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: In the Commission's fiscal year 2016 Independent Auditor's Report, the auditor reported that the Commission resolved the material weakness related to not effectively reviewing financial transactions to ensure that they were accurate, valid, complete, and recorded in the appropriate accounting period. We contacted the agency to ask for further information on the policy and process for supervisory review of financial transactions, but no response was received within the established deadline for us to conduct our follow up. Therefore, because we were not able to verify that related policies and procedures were established and implemented, we will follow up on this open recommendation at a later date.
    Recommendation: To improve its monitoring of internal control, the Commission should direct the appropriate officials to establish and implement written policies and procedures for planning and conducting the Commission's annual assessment of internal control over financial reporting as required by OMB A-123. The policies and procedures should include; (1) documenting an understanding of its internal control environment, which entails such elements as the tone at the top, ethical standards, and personnel management, which can have a significant effect on how the organization functions and the integrity of its financial accounting and reporting; (2) documenting its assessment of the risk of material misstatement to its financial statements; (3) establishing and documenting its internal control objectives and related internal control activities in place to meet those objectives; (4) documenting the tests to be performed and the results of each test, clearly identifying exceptions and resulting deficiencies; and (5) establishing a corrective action plan for all identified deficiencies that specifies how and when each deficiency will be corrected, and assigning responsibility for its effective and timely resolution.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: In the Commission's fiscal year 2016 Independent Auditor's Report, the auditor continued to report that the Commission did not have an adequate process for monitoring the design and operating effectiveness of its internal control to identify, evaluate, and correct internal control deficiencies. For example, the Commission did not document its OMB A-123 approach for assessing its internal control, or provide sufficient, appropriate evidence to support its conclusions on the effectiveness of its internal control activities. The Commission responded that it will continue to implement an enterprise-wide system of controls and monitor and report on those controls in compliance with FMFIA. During fiscal year 2017, the Commission informed us that they issued a related policy, however, their independent auditor continues to identify this area as a material weakness. Therefore, we will follow up on this open recommendation at a later date.
    Recommendation: To improve its monitoring of internal control, the Commission should direct the appropriate officials to establish and implement written policies and procedures for monitoring the activities of the external service organizations that perform significant aspects of the Commission's financial transaction processing and reporting, including implementing relevant complementary user entity controls identified by the service auditors.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: In the Commission's fiscal year 2015 Independent Auditor's Report, the auditor continued to report that the Commission did not adequately document and monitor the effectiveness of internal controls at the service organizations that performed significant aspects of its financial transaction processing and reporting, including processing its federal employee payroll transactions, reconciling its fund balance with Treasury, and preparing its annual financial statements. Specifically, ABMC did not evaluate the service organizations' service auditor reports that contained information on the service organizations' controls and the effectiveness of those controls, and did not consider the impact of the findings and conclusions contained in the service auditor reports on the effectiveness of its internal control. Further, ABMC did not design and implement appropriate complementary user entity controls that were identified by the service auditors. The Commission stated that it will continue to implement an enterprise-wide system of controls and monitor and report on those controls in compliance with FMFIA during fiscal year 2017. Therefore, we will follow up on this open recommendation at a later date.
    Director: Clark, Cheryl E
    Phone: (202)512-3000

    2 open recommendations
    Recommendation: The Commission should direct the appropriate officials to establish and implement written procedures for conducting all physical inventory counts of equipment. These procedures, at a minimum, should outline the processes for (1) planning and executing the physical inventory count and (2) analyzing and documenting the results.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: During our audit of the American Battle Monuments Commission's (Commission) fiscal year 2011 financial statements, we found that the Commission had not performed independent physical inventory of equipment owned by the Commission at the various cemeteries across the world. We found that although the Commission had a policy to perform biennial physical inventory counts of all equipment over $500, this policy was not adhered to during fiscal year 2011. Further, the policy does not explain how to plan, execute, and analyze the results of an inventory count. As a result of this finding, we recommended that the Secretary of the Commission instruct the appropriate officials to establish and implement written procedures for conducting all physical inventory counts of equipment. These procedures, at a minimum, should outline the processes for (1) planning and executing the physical inventory count and (2) analyzing and documenting the results. During our fiscal year 2012 audit, we noted that the Commission did not have policies and procedures for performing an inventory of physical assets. During our fiscal year 2017 follow-up, the Commission informed us that they plan to implement procedures to address our recommendation. We will follow up on this open recommendation at a later date.
    Recommendation: The Commission should direct the appropriate officials to establish a mechanism to monitor implementation of existing Commission policy to perform biennial physical inventory counts of all items of equipment with an obligated balance of $500 or more.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: During our audit of the American Battle Monuments Commission's (Commission) fiscal year 2011 financial statements, we found that the Commission had not performed independent physical inventory of equipment owned by the Commission at the various cemeteries across the world. We found that although the Commission had a policy to perform biennial physical inventory counts of all equipment over $500, this policy was not adhered to during fiscal year 2011. As a result of this finding, we recommended that the Secretary of the Commission direct the appropriate officials to establish a mechanism to monitor implementation of existing Commission policy to perform biennial physical inventory counts of all items of equipment with an obligated balance of $500 or more. During our fiscal year 2012 audit, we found that although the Commission had performed a comparison of the equipment on hand to the data recorded in SharePoint (document management web application to share documents internally), an independent physical inventory was not performed. We determined that the Commission had not established a mechanism for performing an inventory of assets. During our fiscal year 2017 follow-up, the Commission informed us that they plan to implement procedures to address our recommendation. We will follow up on this open recommendation at a later date.
    Director: Clark, Cheryl E
    Phone: (202)512-3000

    7 open recommendations
    Recommendation: The Secretary of the Commission should instruct the Director of Finance at Commission headquarters to monitor monthly cash reconciliations for all Fund Balance with Treasury accounts Commissionwide to ensure their completeness and accuracy.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: During fiscal year 2012, the Commission contracted with the Interior Business Center (IBC) to perform its monthly cash reconciliations with Treasury. During our testing, we found that IBC effectively reconciled cash on hand to Treasury records. However, we found that ABMC did not effectively monitor IBC's reconciliations. Specifically, ABMC did not document its review of the FMS-224 and Fund Balance with Treasury reconciliations performed by IBC. To fully address this recommendation, ABMC needs to document its review of the IBC prepared reconciliations to ensure they are accurate and complete. During fiscal year 2017, the Commission informed us that they plan to develop and implement corrective actions to address our recommendation. Therefore, we will follow up on this open recommendation at a later date.
    Recommendation: The Secretary of the Commission should instruct the Director of Human Resources and Administration at Commission headquarters to maintain a consolidated Active Contracts List, or require the Paris Overseas Office to maintain a separate list, with information on each contract including the name of the contact person; the status of work completed; whether retainage amounts had been paid; and whether any amounts were pending due to disagreements on work performed.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: During our fiscal year 2012 audit, although the Commission provided GAO with active contract lists, we determined that these lists were not consolidated nor were they adequately maintained by the director of Engineering. We also continued to find instances where the Commission did not properly close contracts and deobligate funds. In addition, the Commission could not identify any specific actions taken to address this recommendation. During our fiscal year 2017 follow-up, the Commission informed us that they plan to implement an automated procurement system that will meet the intent of our recommendation. Therefore, we will follow up on this open recommendation at a later date.
    Recommendation: The Secretary of the Commission should instruct the Director of Human Resources and Administration at Commission headquarters to ensure that the Active Contracts List is reconciled to contracts on the undelivered orders report produced by the Commission's accounting system.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: During our fiscal year 2012 audit, we found that the Headquarters active contracts list had not been reconciled to the undelivered orders account. In addition, we concluded that these lists were not adequately maintained. We also continued to find instances where the Commission did not properly close contracts and deobligate funds. In addition, the Commission could not identify any specific actions taken to address this recommendation. During our fiscal year 2017 follow-up, the Commission informed us that they plan to develop and implement procurement-related standard operating procedures to address our recommendation. Therefore, we will follow-up on this recommendation at a later date.
    Recommendation: The Secretary of the Commission should instruct the Director of Finance at Commission headquarters to follow existing budgetary procedures to ensure that contracts are officially agreed to and executed as of or before the date of obligation.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: During our fiscal year 2011 audit of the American Battle Monuments Commission's financial statements, the Commission informed us that this recommendation was implemented with FMS and that ABMC now follows commitment accounting which prevents contracts from being signed before funds are reserved. During our 2012 testing we continued to monitor and we found no related issues. However, the Commission was unable to provide documentation or support for the corrective action instituted with FMS. During our fiscal year 2017 follow-up, the Commission informed us that they plan to implement an automated procurement system that will meet the intent of our recommendation. Therefore, we will follow up on this open recommendation at a later date.
    Recommendation: The Secretary of the Commission should instruct the Director of Human Resources at the Commission's Paris Overseas Office to follow existing policy to prepare, approve, and file current forms to support pay changes in foreign employee's official personnel file.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: During our fiscal year 2012 audit, we tested a sample of payroll transactions and found that not all personnel files contained accurate forms to support current payroll information. In one sample, the ABM-87 was not approved by a Director or designee. In another sample, the salary for the grade and step did not match that of the employee's local compensation plan. In a third sample, the employee's salary was not updated for a General Schedule step increase until almost a year later. During our fiscal year 2017 follow-up, the Commission informed us that they plan to implement an automated HR system that will meet the intent of our recommendation. Therefore, we will follow up on this open recommendation at a later date
    Recommendation: The Secretary of the Commission should instruct the Director of Human Resources at the Commission's Paris Overseas Office to establish a consistent policy for Paris and Rome offices to support changes in employee's official personnel files by using an SF-50, Notification of Personnel Action, for all employees.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: During fiscal year 2012, we determined that the Commission's policy is to use two forms for payroll actions. The headquarters office processes SF-50s for General Schedule (GS) employees and the Paris office uses SF-50s for GS employees and ABM-87s for foreign employees. We did not find any exception with this policy as the SF-50 is a required form for processing payroll actions for GS employees and the ABM 87 is a standard form for processing payroll actions for foreign employees. However, this policy is not documented. To clarify the intent of this recommendation, which is for the Commission to be consistent in processing payroll actions, we issued a subsequent recommendation that calls for the Commission to direct appropriate officials to establish written policies and procedures outlining the key tasks, roles, and responsibilities of both the Human Resources Directorate and the Finance Directorate, including a formal mechanism for communicating all decisions and actions related to processing payroll for foreign employees. This would include the processing of payroll actions. During our fiscal year 2017 follow-up, the Commission informed us that training was provided to employees in the proper production of personnel documentation, however, no policy was provided. Therefore, we will follow up on this open recommendation at a later date.
    Recommendation: The Secretary of the Commission should instruct the Finance Directorate's Finance Officer at the Commission's Paris Overseas Office to modify existing accounting procedures to instruct Finance Directorate personnel to enter the date on the invoice into the accounting system.

    Agency: American Battle Monuments Commission
    Status: Open

    Comments: During our audit of the American Battle Monuments Commission's (the Commission) fiscal year 2010 financial statements, we found that Commission controls were not always effective in ensuring that the receipt and acceptance of goods and services were properly authorized and that invoice dates were accounted for in a consistent manner. The Commission informed us that all Finance personnel were instructed to enter both the invoice receipt date and the invoice date when processing invoices for payment. However, during our fiscal year 2012 audit, we found that the date on the invoice was not consistently entered into the accounting system. For example, we found inconsistencies with the invoice receipt date being entered into the accounting system as either the date the goods were received, the date the invoice was received, or the date the invoice was being entered into the financial system. In addition, we could not verify whether current accounting procedures included this requirement. During our fiscal year 2017 follow-up, the Commission informed us that the invoice date entered in Oracle is taken directly from the invoice approval stamp, however, the Commission was not able to provide a policy, procedures, or statement of work supporting the actions taken. We contacted the agency to ask for further information but no response was received within the established deadline for us to conduct our follow up. Therefore, we will follow up on this recommendation at a later date.
    Director: Clark, Cheryl E
    Phone: (202)512-9377

    2 open recommendations
    Recommendation: The Director of Personnel and Administration at Commission headquarters should follow established policies and procedures in taking action to conduct a review of contracts and purchase orders outstanding for completeness, accuracy, and proper dates.

    Agency: American Battle Monuments Commission: Human Resources and Administration Director
    Status: Open

    Comments: In response to this recommendation, the Commission stated that it completed such a review in fiscal year 2009 and made corrections as to how the Commission issues contracts and purchase orders. In addition, the Commission hired a consultant, a retired Federal Government Contracting Officer, to assist with contracting activities and to help draft and implement the Commission's policies and procedures. During our fiscal year 2010 audit, we found errors in relation to the Commission's contracts and found that Headquarter's Active Contracts List for contracts over $100,000 was not up to date. We found 3 out of 20 expenditures we tested that were obligated before there was a signed contract. During our fiscal year 2011 audit, we found that the Headquarter's Active Contracts List for contracts over $100,000 was not being kept up to date and reconciled to the undelivered orders account. During our fiscal year 2012 audit, we found there were no policies and procedures for processing engineering contracts. We were informed by the Commission that they were in the process of documenting policies and procedures for the entire contracting process. We also found there were no documented policies and procedures for reviewing year end open obligations and accounts payable to verify the accuracy and validity of year end balances. Additionally, there was no documented review of accounts payable or open obligations performed at year-end for all the open contracts. As a result, we found errors in year-end aged vendor liability reports and open purchase orders that no longer represented valid obligations and should have been deobligated. During our fiscal year 2017 follow-up, the Commission informed us that they plan to establish procurement-related policies and procedures to address our recommendation. We will follow up on this open recommendation at a later date.
    Recommendation: The Director of Personnel and Administration at Commission headquarters should follow established policies and procedures in taking action to coordinate procurement activity with finance personnel to ensure accurate and compliant obligation of funding of procurements, including proper application of multiyear contract terms.

    Agency: American Battle Monuments Commission: Human Resources and Administration Director
    Status: Open

    Comments: In response to this recommendation, the Commission stated that acquisition personnel would ensure coordination with finance personnel to be certain that accurate and compliant obligation of funding of procurements, including proper application of multi-year contract terms. During our fiscal year 2010 and 2011 audits, we found errors in relation to the Commission's contracts and determined improvements were still needed in the oversight of contracts. During our fiscal year 2012 audit, we found there were no policies and procedures for processing engineering contracts. We were informed by the Commission that they were in the process of documenting policies and procedures for the entire contracting process. We also found there were no documented policies and procedures for reviewing year end open obligations and accounts payable to verify the accuracy and validity of year end balances. Additionally, there was no documented review of accounts payable or open obligations performed at year-end for all the open contracts. As a result, we found errors in year-end aged vendor liability reports and open purchase orders that no longer represented valid obligations and should have been deobligated. During our fiscal year 2017 follow-up, the Commission informed us that they plan to establish procurement-related policies and procedures to address our recommendation. We will follow up on this open recommendation at a later date.
    Director: Clark, Cheryl E
    Phone: (202)512-9377

    1 open recommendations
    Recommendation: The Finance Officer at the Commission's European Regional (ER) office should instruct and monitor approving officials to ensure that expenditure transactions are dated when goods and services are received and approved before payments are processed.

    Agency: American Battle Monuments Commission: European Regional Office
    Status: Open

    Comments: During our fiscal years 2009, 2010, and 2011 financial statement audits, we continued to find expenditure transactions being processed prior to the goods or services being received and approved for payment. During our fiscal year 2012 audit, the Commission informed us that since the transition to a new financial management system in August 2011, all receiving is conducted in the iProcurement system (part of the Oracle accounting system) and must be complete before an invoice is processed for payment in Oracle. Although we found that invoices were approved before payment, we continued to find instances where the invoices were not dated and/or signed when goods or invoices were received. During fiscal year 2017, the Commission informed us that they developed a related policy to address our recommendation. However, the Commission has not provided documentation or an explanation of the controls used by management for monitoring (i.e. evaluating or reviewing) the effective implementation of the procedures established related to this recommendation. Therefore, we will continue to follow up on this open recommendation with the Commission at a later date.