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    Results:

    Subject Term: Invoices

    5 publications with a total of 18 open recommendations
    Director: Kimberly M. Gianopoulos
    Phone: (202) 512-8612

    3 open recommendations
    Recommendation: To better manage the AD/CV duty liquidation process, CBP should issue guidance directing the Antidumping and Countervailing Duty Centralization Team to (a) collect and analyze data on a regular basis to identify and address the causes of liquidations that occur contrary to the process or outside the 6-month time frame mandated by statute, (b) track progress on reducing such liquidations, and (c) report on any effects these liquidations may have on revenue.

    Agency: Department of Homeland Security: United States Customs and Border Protection
    Status: Open

    Comments: CBP concurred with this recommendation and said it would take steps to implement it. CBP has issued guidance requiring the collection, analysis, and reporting of AD/CV data to identify and address the causes of liquidations that occur contrary to the process or outside the 6-month time frame mandated by statute, as GAO recommended in July 2016. CBP is analyzing the results of its fiscal year 2017 self-inspection program to assess its progress on reducing such liquidations and report on the revenue effect. CBP expects to complete its analysis by Fall 2017. Systematically collecting and analyzing liquidation data on a regular basis to identify and address the causes of untimely liquidations and tracking and reporting on progress toward reducing such liquidations could help CBP reduce revenue loss.
    Recommendation: To improve risk management in the collection of AD/CV duties and to identify new or changing risks, CBP should regularly conduct a comprehensive risk analysis that assesses both the likelihood and the significance of risk factors related to AD/CV duty collection. For example, CBP could construct statistical models that explore the associations between potential risk factors and both the probability of nonpayment and the size of nonpayment when it occurs.

    Agency: Department of Homeland Security: United States Customs and Border Protection
    Status: Open

    Comments: CBP concurred with this recommendation and said it would take steps to implement it. As of September 2017, CBP had not regularly conducted a risk analysis that assesses both the likelihood and significance of risk factors related to AD/CV duty collection, as GAO recommended in July 2016. However, CBP was in the process of developing a model to enable it to conduct such a risk analysis on a regular basis. CBP expects to test the model by Fall 2017; however, CBP officials said that full implementation of the model will not take place until the end of fiscal year 2018 due to the complexity of the project. CBP officials noted that they are working to hire additional staff to dedicate to model development; acquire a dedicated server for processing data to regularly update the models; and identify other CBP programs that would benefit from risk models similar to the ones they are developing for AD/CV duties. Regularly conducting a comprehensive risk analysis of factors related to AD/CV duty non-collection could enhance CBP's capacity to collect additional revenue. For example, it could result in the identification of new factors generating a requirement for an importer to provide additional security in the form of bonds as part of an enhanced bonding requirement.
    Recommendation: To improve risk management in the collection of AD/CV duties, CBP should, consistent with U.S. law and international obligations, take steps to use its data and risk assessment strategically to mitigate AD/CV duty nonpayment, such as by using predictive risk analysis to identify entries that pose heightened risk and taking appropriate action to mitigate the risk.

    Agency: Department of Homeland Security: United States Customs and Border Protection
    Status: Open

    Comments: CBP concurred with this recommendation and said it would take steps to implement it. As of September 2017, CBP was in the process of developing a risk analysis model to use in mitigating AD/CV duty nonpayment, as GAO recommended in July 2016. The model will use predictive risk analysis to identify entries that pose a heightened risk of nonpayment. CBP has contacted the Customs Surety Association and the Commercial Customs Operations Advisory Committee to discuss bonding options to help mitigate the risk of nonpayment. Developing a risk analysis model to use in mitigating AD/CV duty nonpayment could enhance CBP's capacity to collect additional revenue. For example, it could be used to identify entries from importers requiring additional security in the form of bonds as part of an enhanced bonding requirement.
    Director: David C. Trimble
    Phone: (202) 512-3841

    5 open recommendations
    Recommendation: To help improve its ability to assess the risk of improper payments and make more effective use of DOE and contractor resources, the Secretary of Energy should direct the department's Chief Financial Officer to revise the department's IPERA guidance and direct field office sites with responsibility for non-M&O contractor risk assessments to address risk factors as they relate to those sites and take steps to ensure sites implement it.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had revised its fiscal year 2015 and 2016 improper payments guidance. The revised guidance directs field office sites with responsibility for non-M&O contractor risk assessments to address risk factors as they relate to those sites. The guidance further requires each site Chief Financial Officer to certify to the accuracy of improper payments and risk rating. We will continue to monitor DOE's efforts to ensure sites implement this new guidance.
    Recommendation: To help improve its ability to assess the risk of improper payments and make more effective use of DOE and contractor resources, the Secretary of Energy should direct the department's Chief Financial Officer to revise the department's IPERA guidance and clarify how payment sites are to address risk factors and document the basis for their risk rating determinations and take steps to ensure sites implement it.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had revised its fiscal years 2015 and 2016 improper payments guidance requiring sites to prepare risk assessments using a new risk assessment format. The guidance states that the new format was developed to improve consistency among the sites and improve documentation supporting the risk ratings. In the new format, each risk factor includes a description of the risk factor, rating criteria and/or questions to consider during the evaluation to assist sites in determining a risk rating by payment type. The guidance also requires all sites to maintain supporting documentation for their risk assessment. We will continue to monitor DOE's efforts to ensure sites implement this new guidance.
    Recommendation: To help improve its ability to assess the risk of improper payments and make more effective use of DOE and contractor resources, the Secretary of Energy should direct the department's Chief Financial Officer to revise the department's IPERA guidance and clarify who is responsible at DOE for reviewing and approving risk assessments for consistency across sites and take steps to ensure those entities implement it.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had revised its fiscal years 2015 and 2016 improper payments guidance to require site Chief Financial Officers and the Director of Risk Management of the Loan Programs Office to provide a signed certification to DOE's Director of the Office of Finance and Accounting certifying to the accuracy of improper payments and the risk assessment and rating submitted. The guidance provides templates for these certifications. We will continue to monitor DOE's efforts to ensure sites implement this new guidance.
    Recommendation: To help improve its ability to assess the risk of improper payments and make more effective use of DOE and contractor resources, the Secretary of Energy should direct the department's Chief Financial Officer to revise the department's IPERA guidance and provide specific examples of other risk factors that present inherent risks likely to contribute to significant improper payments, in addition to the eight risk factors, direct payment sites to consider those when performing their improper payment risk assessments, and take steps to ensure sites implement it.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had revised its fiscal year 2015 and 2016 improper payments guidance. In addition to the required OMB risk factors, the guidance added the following additional risk factors to be included in the risk assessments: (1) contractor payment processing oversight and (2) segregation of duties. The guidance states these factors have been added to ensure that inherently high-risk areas that can contribute to a site's susceptibility to significant improper payments are properly evaluated. We will continue to monitor DOE's efforts to ensure sites implement this new guidance.
    Recommendation: To provide better transparency regarding its total known improper payments reported under IPERA, the Secretary of Energy should direct the department's Chief Financial Officer to improve public reporting on the amount of total known improper payments by disclosing additional information regarding this amount and the extent to which improper payments could be occurring.

    Agency: Department of Energy
    Status: Open

    Comments: As of May 2017, DOE had added supplemental information to its fiscal year 2016 Agency Financial Report. We will continue to gather additional information from DOE to determine the extent to which this information addresses the amount of total known improper payments.
    Director: Malenich, J Lawrence
    Phone: (202) 512-3406

    2 open recommendations
    Recommendation: The CFPB should direct the Chief Financial Officer to design and implement control procedures that require coordination between the Office of Procurement and other program offices at the time of capitalization to ensure that property and equipment costs, including costs associated with internal-use software, are properly capitalized or expensed as appropriate.

    Agency: Consumer Financial Protection Bureau
    Status: Open

    Comments: Although CFPB took actions to attempt to address this recommendation, as of September 30, 2016, it was still in the process of implementing additional corrective actions. In addition, our fiscal year 2016 audit continued to identify deficiencies over the recording of property, equipment, and software costs. We will continue to evaluate CFPB's actions to address this recommendation during our fiscal year 2017 financial statement audit.
    Recommendation: The CFPB should direct the Chief Financial Officer to strengthen the design and implementation of control procedures to require, as part of the Office of the Chief Financial Officer's quarterly review procedures, review of underlying supporting documents, including tracking schedules, invoices, and obligating documents, to ensure that property and equipment transactions are properly identified and capitalized or expensed as appropriate.

    Agency: Consumer Financial Protection Bureau
    Status: Open

    Comments: As of September 30, 2016, we continued to find that the Office of the Chief Financial Officer's review was not always effective in timely detecting and correcting classification errors between costs that should be capitalized and costs that should be expensed. We will continue to evaluate CFPB's actions to address this recommendation during our fiscal year 2017 financial statement audit.
    Director: Dicken, John E
    Phone: (202) 512-7114

    1 open recommendations
    Recommendation: The Secretary of HHS should direct the Administrator of CMS to monitor the relationship between PPACA-based FULs and the NADACs on an ongoing basis to help determine whether PPACA-based FULs effectively control federal Medicaid expenditures without reducing beneficiary access to drugs subject to FULs over time.

    Agency: Department of Health and Human Services
    Status: Open

    Comments: As part of the final rule implementing the PPACA-based FUL formula, CMS monitors the relationship between the FUL and the NADAC for individual drugs on an ongoing basis and ensures that the FUL does not fall below the NADAC. CMS, however, does not monitor the relationship between the FUL and NADAC in aggregate. This monitoring would provide CMS information on the extent to which the FUL effectively controls federal Medicaid expenditures, particularly in cases where there may be potential for over-reimbursement. CMS officials expect that, by mid-2017, many states will determine reimbursement using an average acquisition cost based on the NADAC. As a result, any potential variation between the FUL and NADAC would be reduced according to CMS officials. We plan to obtain state plan amendments from CMS to confirm whether states are reimbursing at an average acquisition cost or using some other methodology to control Medicaid expenditures.
    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.