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    Subject Term: "Nonprofit organizations"

    8 publications with a total of 25 open recommendations including 2 priority recommendations
    Director: J. Lawrence Malenich
    Phone: (202) 512-3406

    1 open recommendations
    Recommendation: CCI's Chief Financial Officer should update its existing Procurement and Accounts Payable Policy to fully document CCI's management approval controls over payments made by check, including exemptions to regular procedures. This should include approval procedures to be followed during periods when only one authorized manager is available to sign checks for payment.

    Agency: Capital Concerts, Inc.
    Status: Open

    Comments: We provided a draft of this report to Capital Concerts, Inc. (CCI) for comment. In its written comments, CCI stated that its Board of Directors will take appropriate action to address this recommendation.
    Director: Beryl H. Davis
    Phone: (202) 512-2623

    11 open recommendations
    Recommendation: To improve the design of internal controls over the indirect cost rate-setting process, the Director of CAS should develop a standardized checklist and document procedures in its internal guidance instructing negotiators to use the checklist during negotiation.

    Agency: Department of Health and Human Services: Division of Cost Allocation
    Status: Open

    Comments: HHS concurred with this recommendation. In response, HHS stated that its Cost Allocation Services (CAS) will update and complete standardized checklists and that staff will be instructed to use these checklists by December 31, 2016. We are currently reviewing support received from HHS to determine if we can close the recommendation.
    Recommendation: To improve the design of internal controls over the indirect cost rate-setting process, the Director of CAS should develop detailed internal guidance for the completion and documentation of supervisory review of the indirect cost rate negotiation process to provide reasonable assurance that key control activities have been performed by the negotiators.

    Agency: Department of Health and Human Services: Division of Cost Allocation
    Status: Open

    Comments: HHS concurred with this recommendation. In response, HHS stated that by December 31, 2016, its Cost Allocation Services (CAS) will establish a document outlining standardized review procedures for supervisory review of workpapers and rate agreements. We are currently reviewing support received from HHS to determine if we can close the recommendation.
    Recommendation: To improve the design of internal controls over the indirect cost rate-setting process, the Director of CAS should develop internal guidance for negotiating indirect cost rates with all types of research organizations, including hospitals, as well as universities using the simplified method.

    Agency: Department of Health and Human Services: Division of Cost Allocation
    Status: Open

    Comments: HHS concurred with this recommendation. In response, HHS stated that its Cost Allocation Services (CAS) will update internal guidance for negotiating indirect cost rates with universities using the simplified method by December 31, 2016. This guidance will include an example under the two types of direct cost bases, a salary and wage base and a modified total direct cost base. CAS will develop internal guidance for negotiating with hospitals as soon as possible. We are currently reviewing support received from HHS to determine if we can close the recommendation.
    Recommendation: As NIH-DFAS begins formalizing its internal guidance, the Director of NIH-DFAS should update internal guidance to include key characteristics, such as policy number, purpose of the policy, effective date, and approving official, that are normally included in formal policy and procedures.

    Agency: Department of Health and Human Services: Public Health Service: National Institutes of Health: Office of Management: Office of Acquisition and Logistics Management: Office of Acquisition Management and Policy: Division of Financial Advisory Services
    Status: Open

    Comments: HHS concurred with this recommendation. In response, HHS stated that by December 31, 2016, National Institute of Health's Division of Financial Advisory Services (DFAS) will update internal guidance to include key characteristics that are normally included in formal policy and procedures. NIH-DFAS has finalized three of the five polices, which are effective as of July 1, 2017. The remaining two policies will be finalized by August 31st, 2017. We will continue to monitor the status of this recommendation.
    Recommendation: As NIH-DFAS begins formalizing its internal guidance, the Director of NIH-DFAS should develop detailed procedures for the completion and documentation of supervisory review of the indirect cost rate negotiation process to provide reasonable assurance that key control activities have been performed by the negotiator.

    Agency: Department of Health and Human Services: Public Health Service: National Institutes of Health: Office of Management: Office of Acquisition and Logistics Management: Office of Acquisition Management and Policy: Division of Financial Advisory Services
    Status: Open

    Comments: HHS concurred with this recommendation. In response, HHS stated that the National Institute of Health's Division of Financial Advisory Services (DFAS), will develop detailed procedures for the completion and documentation of supervisory review of the indirect cost rate negotiations process. NIH-DFAS has developed draft internal guidance to address the supervisory review of the indirect cost negotiation process. NIH-DFAS plans to finalize these procedures by August 31, 2017. We will continue to monitor the status of this recommendation.
    Recommendation: As NIH-DFAS begins formalizing its internal guidance, the Director of NIH-DFAS should establish a mechanism for tracking key milestones in the indirect cost rate-setting process, such as when indirect cost rate proposals are due.

    Agency: Department of Health and Human Services: Public Health Service: National Institutes of Health: Office of Management: Office of Acquisition and Logistics Management: Office of Acquisition Management and Policy: Division of Financial Advisory Services
    Status: Open

    Comments: HHS concurred with this recommendations. In response, HHS stated that National Institute of Health's Division of Financial Advisory Services (DFAS) will establish a mechanism for tracking key milestones in the indirect cost rate-setting process. NIH-DFAS has initiatives underway that include moving from paper to electronic submissions of indirect cost proposals and developing a replacement to its Commercial Rate Agreement Distribution Services website. DFAS is looking into the feasibility of incorporating key milestones into these two major initiatives. NIH-DFAS is currently working with a contractor to develop a web based system that will establish a tracking system to account for when indirect cost proposal are due from organizations. The original initiative to enable the electronic submission of indirect cost proposals was modified to incorporate this new requirement. NIH-DFAS anticipates the planned date for implementation of this system to be October 1, 2017. We will continue to monitor the status of this recommendation.
    Recommendation: To improve the design of internal controls over the indirect cost rate-setting process, the Director of ONR should implement the May 2014 policy requiring an annual review of guidance so that internal guidance is updated when changes are made to applicable regulations and procedures to reasonably assure that the guidance reflects current requirements.

    Agency: Department of Defense: Department of the Navy: Office of Naval Research
    Status: Open

    Comments: DOD concurred with this recommendation. In response, DOD stated that the Office of Naval Research (ONR) will comply with its requirement for an annual review of its internal policy on negotiating indirect costs. As of June 15, 2017, no updated information has been provided by the Department of Defense. We will continue to monitor the status of this recommendation.
    Recommendation: To improve the design of internal controls over the indirect cost rate-setting process, the Director of ONR should include in its internal guidance acceptable Defense Contract Audit Agency (DCAA) audit completion time frames and identify supplemental procedures to be performed by negotiators if DCAA cannot perform its audits timely or if DCAA issues a qualified opinion or rescinds one of its previously issued audit opinions, to reasonably assure that the indirect cost rate proposal has been adequately reviewed and the negotiated rate complies with applicable regulations.

    Agency: Department of Defense: Department of the Navy: Office of Naval Research
    Status: Open

    Comments: DOD concurred with this recommendation. In response, DOD stated that the Office of Naval Research's (ONR) internal guidance will be updated to provide more realistic audit report due dates and will include general procedures to be performed by negotiators in the case of untimely audits, qualified opinions, or rescinded opinions. As of June 15, 2017, no updated information has been provided by the Department of Defense. We will continue to monitor the status of this recommendation.
    Recommendation: To improve the design of internal controls over the indirect cost rate-setting process, the Director of ONR should develop detailed procedures for the completion and documentation of supervisory review of the indirect cost rate negotiation process to provide reasonable assurance that required certifications and assurances are obtained and follow-up with the research organization is documented.

    Agency: Department of Defense: Department of the Navy: Office of Naval Research
    Status: Open

    Comments: DOD partially concurred with this recommendation. DOD did not agree that the Office of Naval Research (ONR) lacks procedures to ensure supervisors confirm that negotiators adequately performed and documented key controls. DOD noted that both the primary and secondary supervisors are required to review and approve the Business Clearance Memorandum, which records steps performed by the negotiator. While we agree that the Business Clearance Memorandum documents steps performed by the negotiator, these steps are documented at a high level and do not include detailed procedures for supervisors to follow to reasonably assure that the negotiator has performed and documented all key control activities, such as obtaining all required certifications and assurances. DOD agreed in its response that ONR's Business Clearance Memorandum can be improved and stated that ONR will update it to require the negotiator to cross-reference the review steps to the proposal to facilitate the supervisor's review process. However, it is not clear whether the planned Business Clearance Memorandum revisions will include providing detailed procedures for supervisory review as we recommended. As of June 15, 2017, no updated information has been provided by the Department of Defense. We will continue to monitor the status of this recommendation.
    Recommendation: To improve the design of internal controls over the indirect cost rate-setting process, the Director of ONR should finalize and issue internal guidance for negotiating indirect cost rates with universities and nonprofit organizations, including establishing a time frame for issuance of the internal guidance, to help ensure that the procedures are implemented in a timely manner.

    Agency: Department of Defense: Department of the Navy: Office of Naval Research
    Status: Open

    Comments: DOD concurred with this recommendation. In response, DOD stated that the Office of Naval Research (ONR) is currently updating its internal guidance and currently plans to issue this guidance by December 31, 2016. As of June 15, 2017, no updated information has been provided by the Department of Defense. We will continue to monitor the status of this recommendation.
    Recommendation: To improve the design of internal controls over the indirect cost rate-setting process, the Director of ONR should update ONR's existing process for tracking key milestones in the indirect cost rate-setting process to include information such as when indirect cost rate proposals are overdue and when DCAA's audit reports are due.

    Agency: Department of Defense: Department of the Navy: Office of Naval Research
    Status: Open

    Comments: DOD concurred with this recommendation. In response, DOD stated that the Office of Naval Research will update its existing processes for tracking key milestones to include information such as due dates for rate proposals and DCAA audit reports. As of June 15, 2017, no updated information has been provided by the Department of Defense. We will continue to monitor the status of this recommendation.
    Director: Michelle Sager
    Phone: (202) 512-6806

    4 open recommendations
    Recommendation: To enable a more effective approach in working with states to adopt the NDRF, the Secretary of Homeland Security should direct the Administrator of FEMA to conduct a systematic analysis of the information generated from FEMA's readiness assessments to determine the extent of regional office efforts to help states implement the NDRF, including conducting education and outreach.

    Agency: Department of Homeland Security
    Status: Open

    Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, its Office of Readiness Assessment (ORA) launched the 2016 bi-annual FEMA Readiness Assessment Program in April 2016, which includes NDRF related assessment discussions in five FEMA regions. We met with officials in April 2017, who told us that ORA plans to incorporate into this year's assessments, a retrospective review of NDRF findings and progress made in implementing the NDRF since 2013. We will continue to monitor this to see what additional actions the agency takes in response to this recommendation.
    Recommendation: To enable a more effective approach in working with states to adopt the NDRF, the Secretary of Homeland Security should direct the Administrator of FEMA to develop best practices and lessons learned with regard to conducting NDRF education and outreach to states based on the analysis of readiness assessments and create a mechanism to disseminate and share those best practices and lessons learned to FEMA regional offices.

    Agency: Department of Homeland Security
    Status: Open

    Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, its Recovery Support Function Leadership Group initiated an information management workgroup, which shares best practices information as one of its objectives. The workgroup has piloted the use of an existing interagency portal as a potential platform for improved information sharing. We met with officials in April 2017, who told us that FEMA will incorporate its 2016 readiness review findings and best practices from regional Federal Disaster Recovery Coordinators for stakeholder outreach and education into the final platform build-out. We will continue to monitor this to see what additional actions the agency takes in response to this recommendation.
    Recommendation: To enable a more effective approach in working with states to adopt the NDRF, the Secretary of Homeland Security should direct the Administrator of FEMA to clarify with regional offices and Federal Disaster Recovery Coordinators (FDRCs) the role of the regional implementation plans in FDRC performance plans and how they will be used to assess NDRF regional implementation efforts.

    Agency: Department of Homeland Security
    Status: Open

    Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, to achieve greater integration of FEMA's field leadership components, FEMA's Field Operations Directorate (FOD) convened a Field Leadership Working Group of senior subject matter experts to conduct a mission analysis of FEMA's Field Leadership function (which includes Federal Disaster Recovery Coordinators as well as Federal Coordinating Officers and Incident Management Assistance Teams team leads). According to FEMA, one of the assigned tasks of the group involves developing performance metrics to define a steady state and operational performance framework for field leaders, to include Federal Disaster Recovery Coordinators. According to FEMA, the Working Group is currently underway and is preparing a Field Leader Manual for review by FOD leadership. We will continue to monitor this to see what additional actions the agency takes in response to this recommendation.
    Recommendation: To enable a more effective approach in working with states to adopt the NDRF, the Secretary of Homeland Security should direct the Administrator of FEMA to align the annual FDRC performance expectations with clearly defined organizational goals and priorities, consistent with key management practices.

    Agency: Department of Homeland Security
    Status: Open

    Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, the Field Leadership Working Group will implement the elements of this recommendation alongside efforts to clarify the role of the regional National Disaster Recovery Framework implementation plans. FEMA also provided documentation to GAO noting that the Working Group is progressing in its work on its Field Leadership Professional Development Plan. We will continue to monitor this to see what additional actions the agency takes in response to this recommendation.
    Director: Dave Wise
    Phone: (202) 512-2834

    2 open recommendations
    including 1 priority recommendation
    Recommendation: To improve the quality and transparency of data entered into FRPP as GSA transitions the database to a platform that would enable greater government-wide use, the Administrator of GSA, in consultation with OMB and federal agencies, should (1) assess the reliability of FRPP data by determining how individual agencies collect and report FRPP data for each FRPP field, including any supplemental guidance used by agencies to comply with government-wide FRPP data definitions as part of the annual certification of FRPP data; (2) analyze the differences in collecting and reporting practices used by these agencies; and (3) identify and make available to FRPP users the limitations of using FRPP data, in the context of how the data are intended to be used in real property decision making and to measure real property performance across agencies and update federal guidance to address limitations, as needed.

    Agency: General Services Administration
    Status: Open
    Priority recommendation

    Comments: GSA partially agreed with the recommendation noting that it has limited resources to fully analyze and map the data relative to FRPP data definitions, and that it is the responsibility of individual agencies to ensure reliability of the data and compliance with FRPP definitions. As of October 2016, GSA has taken some action to implement this recommendation. GSA told us it has made progress by conducting an in-depth survey in June 2106 focusing on several data elements including: replacement value, status, owned and otherwise management operating costs, repair needs, utilization, and lease costs. The survey asked agencies questions regarding the processes/resources used to source and compile these data elements from agency IT systems as well as internal agency guidance. GSA received responses from 24 agencies and stated it plans to complete its initial analysis of the survey in the fall of 2016 and indicate limitations of these data elements. GSA plans to conduct a series of working group meetings with agencies to conduct an in depth review of the survey results and to develop a set of recommendations for the Federal Real Property Council. GSA said these recommendations may include, but are not limited to, altering data dictionary definitions, sharing best or common practices for reporting these data elements, and sharing the limitations on the use of these data elements. Based on the working group outcomes and input from the Federal Real Property Council and OMB, GSA plans to produce a white paper on these topics by the latter part of 2017.
    Recommendation: To enhance the usefulness of the National Strategy for managing federal real property government-wide, the Director of OMB should expand the National Strategy to further address long-standing real property management challenges by: (1) expanding the scope to include maintenance and repair needs; (2) articulating planned actions and identifying alternative approaches, including alternative-funding mechanisms, to address underlying causes of the real property problems; (3) ensuring that performance measures at the agency level inform the overall progress of the National Strategy; and (4) determining the government-wide costs, benefits, and risks by leveraging agencies' long-term capital plans and identifying approaches to optimally manage that risk.

    Agency: Executive Office of the President: Office of Management and Budget
    Status: Open

    Comments: When we confirm the actions that OMB has taken in response to this recommendation, we will provide updated information.
    Director: James R.McTigue, Jr.
    Phone: (202) 512-9110

    3 open recommendations
    Recommendation: Congress should consider expanding the mandate for 501(c)(3) organizations to electronically file their tax returns to cover a greater share of filed returns.

    Agency: Congress
    Status: Open

    Comments: The threshold over which Treasury/IRS can require electronic reporting is still 250 returns. As of February 18, 2016, there is no proposed legislation in the current Congress which would amend this threshold.
    Recommendation: To improve oversight of charitable organizations, the Commissioner of Internal Revenue should direct EO to develop quantitative, results-oriented compliance goals and additional performance measures and indicators that can be used to assess impact of exams and other enforcement activities on compliance.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: IRS reported it has taken a series of actions to implement this recommendation. First, in FY 2016, IRS implemented a new data-driven case selection model to identify the most non-compliant returns based upon what is reported. Starting in FY 2017, IRS plans to measure the effectiveness of these new data-analytic models and use that performance information as the basis for ongoing discussions with EO Examinations managers on which queries are yielding results and which need to be modified or deleted from the work plan. IRS also developed a weighted disposal code measure, which is intended to help examiners prioritize case selection according to criteria that give more weight to more consequential outcomes. For example, a data mining query generating a lot of revocations would take priority over a query that may only generate written advisories. IRS incorporated the new measure into its current and future work plan monitoring and projections. IRS also began discussions with TE/GE Research and SOI to figure out how to define compliance for the EO population, establish a compliance baseline, and how to develop methods to measure the impact of enforcement actions on voluntary compliance levels in the EO population. Once all these actions are fully implemented, IRS will be in a better position to use this information to develop quantitative, results-oriented compliance goals and additional performance measures and indicators that can be used to assess impact of exams and other enforcement activities on compliance.
    Recommendation: To improve oversight of charitable organizations, the Commissioner of Internal Revenue should continue to work with Treasury officials to do the following: review the flexibility afforded under the Pension Protection Act of 2006 consistent with statutory protections of taxpayer data, clarify what flexibility state regulators have in how they protect and use federal tax data, make modifications to guidance, policies, or regulations as warranted, and clearly communicate this information with state charity regulators.

    Agency: Department of the Treasury: Internal Revenue Service
    Status: Open

    Comments: In 2016, IRS reported taking three actions to implement this recommendation. First, IRS coordinated a training session for State Charity Regulators on safeguards. The training included a review of the Safeguards Security Report (SSR) and covered several topics including current period safeguard activities, changes to safeguarding procedures, and disposal of information. According to IRS, there were 53 participants representing 45 different states. IRS also revised the 6104 (c)Memorandum of Understanding (MOU) inserting a new paragraph that instructs state charity regulators to contact the Tax Exempt/Government Entities (TEGE) Liaison if there are questions about whether an administrative or judicial proceeding has been initiated. This puts in place a mechanism to provide assurance to the regulator if they have concerns. Third, TEGE officials met with the Department of the Treasury and Office of Chief Counsel to discuss the Priority Guidance Plan for 2015-2016. According to IRS, this meeting included a discussion about flexibility afforded under the PPA and how state regulators can protect and use federal tax data consistent with statutory protections of taxpayer data. More recently, IRS informed us that they made additional changes to the MOU to address concerns raised by state charity officials about re-disclosures. IRS also reported on information-sharing efforts to publicize these changes among state charity regulators including a presentation at the annual National Association of State Charity Officials conference and a virtual presentation that reached over 100 participants representing 33 states. IRS informed state charity regulators that the MOU had been revised to address their concerns about re-disclosures in proceedings had been addressed in the MOU. The TEGE Liaison made a presentation at the Annual NASCO Conference in Washington DC on October 6, 2015 and included this information in the presentation.
    Director: David Gootnick
    Phone: (202) 512-3149

    1 open recommendations
    including 1 priority recommendation
    Recommendation: To improve the agency's tracking and reporting on progress of its Local Solutions initiative, the USAID Administrator should identify additional indicators to better capture Local Solutions progress toward the initiative's goals.

    Agency: United States Agency for International Development
    Status: Open
    Priority recommendation

    Comments: As part of a three-tier approach to integrate more strategic monitoring efforts, USAID is conducting an internal review of the department's best practices, processes, and procedures for promoting the goals of the Local Solutions initiative, which are to strengthen capacity, promote ownership, and increase sustainability. Through this review, the agency expects to identify ways of monitoring the Local Solutions initiative that will more accurately capture the underlying models of change and help identify indicators that will help capture progress toward the initiative's goals. In October 2016, USAID officials said that the agency is in the process of developing a menu of potential indicators and will request missions to provide feedback on these indicators. Agency-wide indicators for local ownership are expected no sooner than spring of 2017. In April 2017, officials stated that the agency is working on finalizing draft indicators for local ownership. The expected date of completion is now late summer 2017.
    Director: Melito, Thomas
    Phone: (202)512-9601

    2 open recommendations
    Recommendation: To enhance U.S. efforts to promote international religious freedom, the Secretary of State and the Chair of USCIRF should jointly define how State and USCIRF should interact in their efforts to promote international religious freedom, paying particular attention to defining the ex-officio role of the Ambassador-at-Large for International Religious Freedom as a nonvoting USCIRF member.

    Agency: United States Commission on International Religious Freedom
    Status: Open

    Comments: In March 2015, officials from the Bureau of Democracy, Human Rights & Labor (DRL) said that the DRL Front Office and senior management have yet to approve a joint letter between State's Office of International Religious Freedom and the US Commission for International Religious Freedom (USCIRF) that addresses GAO's recommendation. According to the officials, the DRL front office wanted to revisit the letter given the recent appointment of a new Ambassador-at-Large. According to the Ambassador, he met with USCIRF and wanted to provide input to the joint letter, but as of March 2015, the letter had not been approved by State. We followed up again in both August 2015 and August 2016 and were told that no progress on the letter or a joint understanding had been made. In July 2017, the President announced his nominee to be the new Ambassador at Large for International Religious Freedom. As of November 3, 2017, the nomination is pending. State and USCIRF have not reached agreement on a letter responding to our recommendation.
    Recommendation: To enhance U.S. efforts to promote international religious freedom, the Secretary of State and the Chair of USCIRF should jointly define how State and USCIRF should interact in their efforts to promote international religious freedom, paying particular attention to defining the ex-officio role of the Ambassador-at-Large for International Religious Freedom as a nonvoting USCIRF member.

    Agency: Department of State
    Status: Open

    Comments: After the report was issued, in a letter dated May 28, 2013, the State Department said it has met with the U.S. Commission on International Religious Freedom (USCIRF) to discuss a plan for better systematizing the interactions between the entities, including by more clearly defining the ex-officio role of the Ambassador-at-Large. In October 2013 and again in March 2014, State said it continued to discuss this plan with USCIRF. In October 2014, State said it had drafted a joint letter with USCIRF in response to our recommendation, but that it was awaiting a Front Office signature. In March 2015, officials from the Bureau of Democracy, Human Rights & Labor (DRL) said that the DRL Front Office and senior management have yet to approve a joint letter between State's Office of International Religious Freedom and the US Commission for International Religious Freedom (USCIRF) that addresses GAO's recommendation. According to the officials, the DRL front office wanted to revisit the letter given the recent appointment of a new Ambassador-at-Large. According to the Ambassador, he met with USCIRF and wanted to provide input to the joint letter, but as of March 2015, the letter had not been approved by State. We followed up again in both August 2015 and August 2016 and were told that no progress on the letter or a joint understanding had been made. In July 2017, the President announced his nominee to be the new Ambassador at Large for International Religious Freedom. As of November 3, 2017, the nomination has been referred to the full Senate for confirmation. State and USCIRF have not reached agreement on a letter responding to our recommendation.
    Director: White, James R
    Phone: (202) 512-9039

    1 open recommendations
    Recommendation: As Congress considers whether tax-exempt governmental bonds should be used for professional sports stadiums that are generally privately used, it may also wish to consider whether other facilities, including hotels and golf courses, that are privately used should continue to be financed with tax-exempt governmental bonds.

    Agency: Congress
    Status: Open

    Comments: No legislative action enacted as of March 2017. A bill was introduced in Congress in February 2017 (H.R. 811) which, if enacted, would, in general, not allow tax-exempt government bonds to be used to finance professional sports stadiums. Reconsidering the tax-exempt status of certain bonds could generate hundreds of millions of dollars in additional federal revenue.