Recommendation: The Director of OHS should perform a fraud risk assessment for the Head Start program, to include assessing the likelihood and impact of fraud risks it faces. (Recommendation 1)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open
Priority recommendation

Comments: In February 2020, HHS told us that the Administration for Children and Families (ACF) is developing a Fraud Risk Assessment template for all of its programs (including the Office of Head Start) and is on track to complete the initial Fraud Risk Assessment for its pilot program by June 30, 2020. Upon completion of the Fraud Risk Assessment for the ACF pilot program, ACF anticipates completing its initial Fraud Risk Assessment for OHS, by March 31, 2021. We will assess these actions once completed.

Recommendation: The Director of OHS should establish procedures to monitor and evaluate OHS's new internal workflows for monitoring reviews, to include establishing a baseline to measure the effect of these workflows and identify and address any problems impeding the effective implementation of new workflows to ensure timeliness goals for monitoring reviews are met. (Recommendation 3)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open

Comments: HHS did not concur with this recommendation. In February 2020, HHS stated that OHS regularly evaluates its effectiveness of its workflows to determine how to best adjust the system to support effective follow-up. HHS also stated that, for Fiscal Year 2020, OHS has updated its internal workflow timelines to increase responsiveness to identified findings and ensure grantee support. We will continue to monitor HHS's efforts in this area.

Recommendation: The Director of OHS should provide program-wide guidance on when a student's slot should be considered vacant due to absenteeism. (Recommendation 5)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open

Comments: In February 2020, OHS told us that it is finalizing program guidance that will address when a child's slot should be considered vacant due to absenteeism and what a program should do fill it. OHS stated that it anticipates having a final paper published by summer, 2020. We will continue to monitor OHS's efforts in this area.

Recommendation: The Director of OHS should develop and implement a method for grantees to document attendance and services under EHS pregnancy programs. (Recommendation 6)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open

Comments: In February 2020, OHS told us that it is developing a toolkit of resources specifically designed to offer best practice tips for Early Head Start programs on how to track attendance and services to pregnant women. OHS is surveying the Head Start community to better determine what resources are already available and how programs in different regions and cities track services to pregnant women. OHS anticipates a rollout for the toolkit by summer, 2020.

Recommendation: To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to coordinate with the Federal Highway Administration and tribal stakeholders and reexamine the need for road-description and condition data currently collected in the NTTFI and eliminate fields that do not serve an identified purpose.

Agency: Department of the Interior
Status: Open

Comments: In June 2019, Interior reported that the Bureau of Indian Affairs' (BIA) and Federal Highway Administration's (FHWA) efforts to coordinate with tribes and the Tribal Transportation Program Coordinating Committee (TTPCC) to address this recommendation were progressing. Established by federal regulations, TTPCC is the committee comprised of 24 tribal representatives that provides input and makes recommendations to the BIA and FHWA. According to Interior, TTPCC has identified data elements--14 of 54 data fields--to be considered for removal from NTTFI, and BIA and FHWA have held discussions with tribes concerning a draft plan to remove these identified data elements from NTTFI. Interior reported that tribal groups have posed no objections to the plan and that they anticipate the plan being implemented later in the year. We will continue to monitor actions to address this recommendation.

Recommendation: To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to for fields determined to have continued relevance for management and program oversight take steps to improve the quality of these data by clarifying guidance in the NTTFI coding guide that tribes use to collect data and by providing additional guidance on steps needed to ensure that data are consistently reported.

Agency: Department of the Interior
Status: Open

Comments: In June 2019, Interior reported that a group of tribal users organized by the Bureau of Indian Affairs (BIA) and the Federal Highway Administration (FHWA) to review the NTTFI and the coding guide was progressing in its efforts to recommend updates to the coding guide. According to Interior, the group has made recommendations to the Tribal Transportation Program Coordinating Committee (TTPCC) on which data elements to remove from the NTTFI and for clarifying guidance in the coding guide, relevant to the data elements proposed to remain in the NTTFI. Interior anticipates that updates to the coding guide based on the group's recommendations will be completed in 2019. We will continue to monitor actions to address this recommendation.

Recommendation: To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to establish a process to monitor data to facilitate timely and targeted corrections to missing or erroneous data.

Agency: Department of the Interior
Status: Open

Comments: Interior told us that, along with the Bureau of Indian Affairs (BIA) and Federal Highway Administration (FHWA), it has held several meetings with tribal users to identify missing or erroneous data in the NTTFI. For example, the meeting participants identified that data which were formerly but are no longer used in formulas to allocate federal funding to tribes are likely outdated and not useful. Further, recognizing that approximately 70 percent of NTTFI data reflects inventory and condition information of roads owned by non-BIA and non-tribal entities, such as state and local governments, the meeting participants determined that opportunities exist to work with these external entities to monitor data obtained from them to ensure that it is current and accurate for use and display in the NTTFI. As of June 2019, Interior said that, in anticipation of changes to the NTTFI format, its main actions to address this recommendation will be to coordinate with these external entities to monitor the data they provide to NTTFI to ensure it conforms to NTTFI's new format. We will continue to monitor actions to address this recommendation.

Recommendation: To improve the DMR, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a means to document when the level of service for each road section was last evaluated.

Agency: Department of the Interior
Status: Open

Comments: In June 2019 Interior reported that BIA had developed a data reporting process that incorporates use of a "time-stamp" to indicate when the level of service for a road section is evaluated. Interior said that it anticipates providing guidance on this process to BIA staff, tribes, and others that perform level of service road maintenance assessments so that they can implement the process in 2020. We will continue to monitor efforts to implement this recommendation.

Recommendation: To improve the DMR, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop and maintain documentation supporting the unit costs of maintenance used to estimate maintenance needs.

Agency: Department of the Interior
Status: Open

Comments: In June 2019 Interior reported that the Bureau of Indian Affairs (BIA) had surveyed tribes to determine their capabilities for managing data related to road maintenance costs. Interior further reported that BIA was investigating the use of computer software for tracking road maintenance costs and developing estimates of maintenance needs. Interior said that it expects to complete actions to implement this recommendation in 2020. We will continue to monitor actions to address this recommendation.

Recommendation: To improve the DMR, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a process for more complete and accurate reporting occurring under existing authority of Road Maintenance Program funds expended for performed maintenance on BIA roads.

Agency: Department of the Interior
Status: Open

Comments: In its official comments on our report, Interior said that that it cannot reasonably accomplish this recommendation because, in reference to the tribes which have agreements with the Bureau of Indian Affairs (BIA) to maintain BIA roads in their area, it conflicts with the intent of federal law and the minimum-reporting requirements when a tribal entity takes over the day-to-day actions and tasks of a program. However, following our report's issuance, Interior told us that its actions to address other recommendations will assist the tribes in developing data on Road Maintenance Program (RMP) funds expended for performed maintenance on BIA roads. In addition, Interior said that tribes have expressed interest in gathering this data. Further, in June 2019, Interior reported that the Tribal-Interior Budget Council had approved a plan for a pilot project in the BIA Great Plains Region to gather data relevant to addressing this recommendation. Even though tribal reporting of this data is voluntary, we continue to believe that by coordinating with affected tribes on developing a process for their self-reporting of RMP funds expended for maintenance, and by implementing such a process for tribes that BIA serves directly, Interior could improve the reporting of maintenance performed on BIA roads and be better positioned to provide Congress with more accurate and complete information on RMP funding decisions. We will continue to monitor actions to address this recommendation.

Recommendation: To best align resources allocation decisions to needs, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to review the formula to fund transportation at BIE schools and determine, with BIA and tribal stakeholders, what adjustments, such as distinguishing between gravel and paved roads, are needed to better reflect transportation costs for schools.

Agency: Department of the Interior
Status: Open

Comments: At the time of our report, Interior said that it concurred with this recommendation; however, it subsequently changed its position. Interior noted that its tribal and school partners have not requested changes to this formula and that it was therefore not compelled to undertake the rigorous consultation and negotiated rulemaking actions that would be needed to change the formula. As of June 2019, Interior has not acted to address this recommendation.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to expand its performance measures for the 21st Century program to address all program objectives. Specifically, Education should establish performance measures related to key behavioral, including student attendance and disciplinary incidents, and socio-emotional outcomes.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with our recommendations; rather, it generally noted that it will keep our recommendations in mind as it continues to implement changes in the program as a result of ESSA. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to conduct federal-level data checks on the accuracy of 21st Century program data submitted by states. Such checks could test for logical relationships between fields. Education should also publicly disclose and address any data limitations it identifies, as appropriate.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation, but stated that it was taking some actions to enhance program data. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to provide written, non-regulatory guidance to states on developing and conducting high-quality 21st Century state evaluations to help address the difficulties states face in measuring program performance and effectiveness.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation, but identified steps it plans to take to implement it. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to use the information it collects from its monitoring visits and ongoing interactions with states to share effective practices across states for sustaining their 21st Century programs once program funding ends. This information could be shared using existing mechanisms such as Education's meetings with 21st Century state coordinators.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation, but identified steps it plans to take to implement it. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: To improve VA's ability to accurately track employees' use of official time, the Secretary of Veterans Affairs should direct the Assistant Secretary for Human Resources and Administration to increase efforts to ensure timekeepers at all facilities receive training and consistent guidance on recording official time in VATAS.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA stated that the Office of Labor Management Relations (LMR) revised its policy in December 2016 to include specific directions to human resource offices to begin recording official time in the VA Time and Attendance System (VATAS) once VATAS has been implemented at their respective facilities. The formal concurrence process, which precedes the final publication of the policy, is ongoing. We will consider closing this recommendation when the agency provides documentation of the revised policy.

Recommendation: To improve VA's ability to accurately track employees' use of official time, the Secretary of Veterans Affairs should direct the Assistant Secretary for Human Resources and Administration to standardize the methods used by facilities for determining the amount of official time used prior to the agency-wide implementation of VATAS by encouraging facilities to rely on time and attendance records when calculating the amount of official time used at the facility level.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA stated that the Office of Human Resources and Administration is in the process of developing a memo directing facilities to rely on time and attendance records when calculating the amount of official time used at the facility level. We will consider closing this recommendation when the agency has provided documentation that they have completed this effort.

Recommendation: To improve VA's ability to accurately track employees' use of official time, the Secretary of Veterans Affairs should direct the Assistant Secretary for Human Resources and Administration to, in preparation for the full implementation of VATAS, take steps to transition from using the LMR system to VATAS to collect and compile information on the amount of official time used agency-wide.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA stated that the Office of Labor Management Relations (LMR) will transition from using the LMR Official Time Tracking System to collect and compile data on official time and will coordinate with the Financial Services Center to use VATAS to create a report on the agency-wide use of official time. VA is still in the process of rolling out VATAS and standardizing the input of official time requests within VATAS. We will consider closing this recommendation when the agency has demonstrated efforts to use VATAS for capturing the use of official time and producing reports.

Recommendation: To help ensure that agencies report comparable and reliable data to Enterprise Human Resources Integration (EHRI), the Director of OPM, in coordination with agencies and payroll service providers, should develop guidance for agencies on which activities to enter, or not enter, as paid administrative leave in agency time and attendance systems.

Agency: Office of Personnel Management
Status: Open

Comments: To address agency use of paid administrative leave that may exceed reasonable amounts as well as discrepancies in recording and reporting paid administrative leave, in December 2016, Congress passed the "Administrative Leave Act of 2016." The act mandates new categories of paid leave, including "investigative leave," "notice leave," and "weather and safety leave" and sets limitations on the duration of paid administrative leave as well as the new categories of investigative and notice leave. The Act also requires OPM to establish regulations on (1) when to grant administrative leave and the other new categories of paid leave, and (2) the proper recording and reporting of these types of paid leave. In July 2017, OPM proposed new rules to regulate paid administrative leave, but has not finalized all these rules. In April 2018, OPM issued final regulations for "weather and safety leave" and announced that it would issue separate final regulations for "administrative leave," "investigative leave," and "notice leave" at a later date. In July 2019, OPM officials told us that they have not finalized the remaining regulations due to legal and practical concerns related to employees serving overseas. For example, the proposed rules could conflict with overseas personnel observing local holidays for security, diplomatic, and practical reasons. OPM also announced that it is reconvening its interagency working group for dismissal and closure procedures to update its "DC Dismissal and Closure Procedures" guidance to reflect the new "weather and safety leave" procedures. In addition, in response to our recommendation, in May 2015, OPM issued a fact sheet on administrative leave, which discusses the appropriate use of an agency's administrative leave authority, including a definition of administrative leave as well as applicable government-wide, individual agency, and emergency policies on the use of administrative leave. However, this fact sheet will need to be revised to reflect the newly issued regulations for "weather and safety leave" in addition to the regulations for the other categories of paid leave when they are in effect. Once all regulations are finalized, the proposed rules, along with updated fact sheet guidance, should help agencies and federal employees appropriately use, record, and report administrative leave. We will be contacting OPM to receive an update on the status of this recommendation once all the regulations are finalized and the fact sheet guidance is revised.

Recommendation: To help ensure that agencies report comparable and reliable data to EHRI, the Director of OPM, in coordination with agencies and payroll service providers, should provide updated and specific guidance to payroll service providers on which activities to report, or not report, to the paid administrative leave data element in EHRI.

Agency: Office of Personnel Management
Status: Open

Comments: To address agency use of paid administrative leave that may exceed reasonable amounts as well as discrepancies in recording and reporting paid administrative leave, in December 2016, Congress passed the "Administrative Leave Act of 2016." The act mandates new categories of paid leave, including "investigative leave," "notice leave," and "weather and safety leave" and sets limitations on the duration of paid administrative leave as well as the new categories of investigative and notice leave. The Act also requires OPM to establish regulations on (1) when to grant administrative leave and the other new categories of paid leave, and (2) the proper recording and reporting of these types of paid leave. In July 2017, OPM proposed new rules to regulate paid administrative leave, but has not finalized all these rules. In April 2018, OPM issued final regulations for "weather and safety leave" and announced that it would issue separate final regulations for "administrative leave," "investigative leave," and "notice leave" at a later date. To accompany the final regulations for "weather and safety leave," OPM issued two new data standards for agencies to report Paid Holiday Time Off and Weather and Safety Leave Hours Used that became effective in May 2018. Also, in November 2018, OPM released an update to its "DC Dismissal and Closure Procedures" guidance to reflect the new "weather and safety leave" procedures. Once all regulations are finalized, the proposed rules, along with updated guidance to payroll providers for reporting paid administrative leave and the new leave categories, should help agencies report comparable and reliable data to EHRI. We will be contacting OPM to receive an update on the status of this recommendation once the regulations are finalized and the guidance is revised.

Recommendation: The Commissioner of the IRS should direct the appropriate IRS officials to revise the post orders for the service center campuses (SCC) and lockbox bank security guards to include specific procedures for timely reporting exterior lighting outages to SCC or lockbox bank facilities management. These procedures should specify (1) whom to contact to report lighting outages and (2) how to document and track lighting outages until resolved.

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that during fiscal year 2020, Facilities Management and Security Services (FMSS) will update the Internal Revenue Manual to reflect the necessary guidance for service center guards and FMSS physical security specialists to know (1) whom the guards are to contact to report lighting outages and (2) how lighting outages are to be documented and tracked until resolved.