Recommendation: ODCFO should update the CAP template provided in its guidance to assist components in developing CAPs to include the year deficiencies are first identified data element defined in the Implementation Guide for OMB Circular A-123. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: ODCFO should update the NFR Database with a field to record the year deficiencies are first identified. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: ODCFO should incorporate appropriate steps to improve its CAP review process, including ensuring that (1) data elements not included in CAPs are appropriately identified and communicated to components and resolved, (2) NFRs are appropriately linked to the correct CAPs to address them, and (3) components document their rationale for accepting the risk associated with certain deficiencies and appropriately identify such instances in the NFR Database. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: ODCFO should update DOD guidance to instruct DOD and components to document root-cause analysis when needed to address deficiencies auditors identified. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: ODCFO should include appropriate steps in its monthly NFR Database review process to evaluate and follow-up on previously identified exceptions to ensure that they are resolved timely. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should direct the Chief Management Officer and other entities, as appropriate, to establish measures to determine if the department is succeeding in achieving its goal to improve its financial management systems. Specifically, it should document targets and time frames to define the level of performance to be achieved. It should also document how DOD plans to measure expected outcomes by identifying data sources, how it plans to measure values, and how DOD plans to verify and validate measured values. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should direct the Chief Management Officer and other entities, as appropriate, to establish a specific time frame for developing an enterprise road map to implement its financial management systems strategy, and ensure that it is developed. The road map should document the current and future states at a high level, from an architecture perspective, and present a transition plan for moving from the current to the future in an efficient, effective manner. The road map should discuss performance gaps, resource requirements, and planned solutions, and it should map DOD's financial management systems strategy to projects and budget. The plan should also document the tasks, time frames, and milestones for implementing new solutions, and include an inventory of systems. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should direct the Chief Management Officer and other entities, as appropriate, to develop detailed migration plans for the Air Force's General Accounting and Finance System-Reengineered, Navy's Standard Accounting and Reporting System, and Army's Standard Finance System and the Standard Operation and Maintenance Army Research and Development System. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should direct the Chief Management Officer and other entities, as appropriate, to establish performance goals that include performance indicators, targets and time frames, to monitor the status of efforts to address IT-related audit findings. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should direct the Chief Management Officer and other entities, as appropriate, to implement a mechanism for identifying financial management systems that support the preparation of the department's financial statements in the department's systems inventory and budget data, and identify a complete list of financial management systems. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should direct the Chief Management Officer and other entities, as appropriate, to ensure that the department limits investments in financial management systems to only what is essential to maintain functioning systems and help ensure system security until it implements the other recommendations in this report. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of the IC should establish specific timeliness objectives for completing investigations conducted by the OIG of the IC. (Recommendation 1)

Agency: Office of the Director of National Intelligence: Office of the Inspector General of the Intelligence Community
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of the IC should establish a time frame to finalize revisions to the OIG's investigations manual. (Recommendation 2)

Agency: Office of the Director of National Intelligence: Office of the Inspector General of the Intelligence Community
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of the IC should establish a process to regularly review and update the OIG's investigative procedures. (Recommendation 3)

Agency: Office of the Director of National Intelligence: Office of the Inspector General of the Intelligence Community
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of the IC should develop and implement a quality assurance program for the OIG's investigations division. This program should consist of routine internal and external quality assurance reviews consistent with CIGIE standards and guidance. (Recommendation 4)

Agency: Office of the Director of National Intelligence: Office of the Inspector General of the Intelligence Community
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of the IC should develop a process to facilitate external quality assurance reviews of other IC-element OIGs' investigations divisions. (Recommendation 5)

Agency: Office of the Director of National Intelligence: Office of the Inspector General of the Intelligence Community
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of the IC should ensure that as the ICIG finalizes its draft investigations procedures and investigator training plan, these documents provide an approach that systematically links the requisite knowledge, skills, and abilities and training requirements throughout an investigator's career progression. (Recommendation 6)

Agency: Office of the Director of National Intelligence: Office of the Inspector General of the Intelligence Community
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of CIA should establish a time frame to finalize revisions to the OIG's investigations manual. (Recommendation 7)

Agency: Central Intelligence Agency: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of CIA should establish a process to regularly review and update the OIG's investigative manual and policies. (Recommendation 8)

Agency: Central Intelligence Agency: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of CIA should implement routine internal quality assurance reviews as part of the quality assurance program for the OIG's investigations divisions consistent with CIGIE standards and guidance. (Recommendation 9)

Agency: Central Intelligence Agency: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of DIA should establish a process to regularly review and update the OIG's investigative procedures. (Recommendation 10)

Agency: Department of Defense: Defense Intelligence Agency: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of DIA should implement routine external quality assurance reviews in the quality assurance program for the OIG's investigations division consistent with CIGIE standards. (Recommendation 11)

Agency: Department of Defense: Defense Intelligence Agency: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of DIA should take steps to ensure that notifications to complainants in reprisal cases occur and are documented in the investigative case file, as required by OIG policy. (Recommendation 12)

Agency: Department of Defense: Defense Intelligence Agency: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NGA should establish specific timeliness objectives for completing investigations conducted by the OIG of NGA. (Recommendation 13)

Agency: Department of Defense: National Geospatial-Intelligence Agency: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NGA should develop and implement a quality assurance program for the OIG's investigations division. This program should consist of routine internal and external quality assurance reviews consistent with CIGIE standards and guidance. (Recommendation 14)

Agency: Department of Defense: National Geospatial-Intelligence Agency: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NGA should take steps to ensure that notifications to complainants in reprisal cases occur and are documented in the investigative case file, as required by OIG policy. (Recommendation 15)

Agency: Department of Defense: National Geospatial-Intelligence Agency: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NRO should establish a time frame to finalize the OIG's draft investigations manual. (Recommendation 16)

Agency: Department of Defense: National Reconnaissance Office: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NRO should establish a process to regularly review and update the OIG's investigative procedures. (Recommendation 17)

Agency: Department of Defense: National Reconnaissance Office: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NRO should continue to develop and implement a quality assurance program for the OIG's investigations division, which should incorporate routine internal and external quality assurance reviews consistent with CIGIE standards and guidance. (Recommendation 18)

Agency: Department of Defense: National Reconnaissance Office: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NRO should consider making the use of documented investigative plans a requirement for all investigations. (Recommendation 19)

Agency: Department of Defense: National Reconnaissance Office: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NRO should revise its training plan to provide an approach that systematically links the requisite knowledge, skills, and abilities to training requirements throughout an investigator's career progression. (Recommendation 20)

Agency: Department of Defense: National Reconnaissance Office: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NRO should take steps to ensure that notifications to complainants in reprisal cases occur and are documented in the investigative case files, as required by OIG policy. (Recommendation 21)

Agency: Department of Defense: National Reconnaissance Office: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NSA should develop and implement a quality assurance program for the OIG's investigations division. This program should consist of routine internal and external quality assurance reviews consistent with CIGIE standards and guidance. (Recommendation 22)

Agency: Department of Defense: National Security Agency/Central Security Service: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Inspector General of NSA should develop an investigator training plan that provides an approach that systematically links the requisite knowledge, skills, and abilities to training requirements to an investigator's career progression. (Recommendation 23)

Agency: Department of Defense: National Security Agency/Central Security Service: Office of the Inspector General
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ORR should clarify in its grant announcements the information and supporting documentation applicants are required to provide in their grant applications with respect to their state licensing status, eligibility, and allegations and concerns. (Recommendation 1).

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Refugee Resettlement
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ORR should take steps to develop, and ensure that officials reviewing grant applications implement, a process to verify the accuracy and completeness of information reported by grant applicants on state licensing status, eligibility, allegations and concerns. (Recommendation 2).

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Refugee Resettlement
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ORR should ensure that the grant review process includes a documented review of applicants' past performance on ORR grants for those that have previously received grants to care for unaccompanied children. This could include, for example, a systematic review of previous quarterly and annual performance reports and a review of corrective actions issued by all ORR monitoring staff to all ORR-funded facilities previously operated by the applicant. (Recommendation 3).

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Refugee Resettlement
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ORR should clarify in its instructions to grantees the information they are required to report on state licensing citations in their quarterly performance reports. (Recommendation 4).

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Refugee Resettlement
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ORR should take steps, such as through guidance or training, to ensure that project officers clearly understand the requirement that grantees report state licensing citations at any of their facilities within 24 hours and include state licensing citations in their quarterly performance reports. (Recommendation 5).

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Refugee Resettlement
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ORR should work with state agencies that license ORR-funded facilities to develop a plan for mutual information sharing, including processes for ORR outreach to states during the grant application review process and ongoing information sharing on ORR and state monitoring processes and identified deficiencies. (Recommendation 6).

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Refugee Resettlement
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ORR should ensure that ORR provides and maintains a current point of contact for each state agency that licenses ORR grantees to facilitate information sharing regarding ORR-funded facilities. (Recommendation 7).

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Refugee Resettlement
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ORR should develop a plan—including roles, responsibilities, and timeframes—to guide and focus ORR's efforts to meet its goals to:

• conduct an audit of each facility's compliance with ORR standards on preventing and responding to sexual assault, as required under the Interim Final Rule,
• conduct on-site monitoring visits to each facility at least every 2 years in accordance with ORR policy, and
• report any noncompliance to the facility within 30 days of the site visit, in accordance with ORR policy.

(Recommendation 8).

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Refugee Resettlement
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary of Defense (Comptroller) should, in collaboration with the Under Secretary of Defense (Acquisition and Sustainment), develop and implement a DOD-wide strategy to remediate real property asset control issues. (Recommendation 1).

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and stated that it was committed to placing increased leadership emphasis on real property asset controls to ensure mission readiness, audit readiness, testing for existence and completeness, and maintaining internal controls.

Recommendation: The Under Secretary of Defense (Comptroller) should, in collaboration with the Under Secretary of Defense (Acquisition and Sustainment), develop department-wide instructions for performing the E&C verifications. (Recommendation 2).

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and stated that it was committed to placing increased leadership emphasis on real property asset policies and instructions to ensure consistent and repeatable existence and completeness verifications.

Recommendation: We recommend that the Secretary of the Treasury ensure that the Fiscal Assistant Secretary enhances Treasury's procedures for the aggregate analysis to consider the impact of all amounts not obtained from significant entity audited financial statements on the reliability of the CFS and use the results to determine if audit coverage is needed for any information. (Recommendation 1)

Agency: Department of the Treasury
Status: Open

Comments: In commenting on our draft report, Treasury stated that it has already taken steps to address this recommendation by updating guidance to federal entities for the preparation of the fiscal year 2020 Agency Financial Reports or Performance and Accountability Reports. In addition, Treasury stated that it has drafted a memo to the Federal Accounting Standards Advisory Board to seek clarification of existing guidance related to reporting differences for federal entities that prepare financial reports according to FASB standards.

Recommendation: We recommend that the Secretary of the Treasury ensure that the Fiscal Assistant Secretary enhances Treasury's process for revising accounting and reporting policies to reasonably assure that financial information—including the SOCNP, Funds from Dedicated Collections note, and Other Liabilities note—is prepared in accordance with U.S. GAAP and sufficiently documented to allow effective management review. (Recommendation 2)

Agency: Department of the Treasury
Status: Open

Comments: In commenting on our draft report, Treasury stated that it has already taken steps to address this recommendation by updating guidance to federal entities for the preparation of the fiscal year 2020 Agency Financial Reports or Performance and Accountability Reports.

Recommendation: We recommend that the Secretary of the Treasury ensure that the Fiscal Assistant Secretary enhances existing procedures to reasonably assure that disclosures for financial information incorporated using accounting standards issued by FASB are prepared in accordance with U.S. GAAP, such as improving (1) the quantitative analysis to consider all FASB information included in the CFS, (2) the FASB questionnaire to consider all relevant disclosures and obtain responses from all significant component entities, and (3) procedures for sufficiently documenting analyses and conclusions related to FASB information in the CFS. (Recommendation 3)

Agency: Department of the Treasury
Status: Open

Comments: In commenting on our draft report, Treasury stated that it drafted a memo to the Federal Accounting Standards Advisory Board to seek clarification of existing guidance related to reporting differences for federal entities that prepare financial reports according to FASB standards.

Recommendation: Congress should consider legislation to require each CFO at a CFO Act agency to oversee and provide leadership for all of the responsibilities necessary to effectively carry out federal financial management activities, including the formulation and financial execution of the budget, planning and performance, risk management, internal control, financial systems, and accounting. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language to clarify the duties and responsibilities of the CFO, including the formulation and financial execution of the budget, planning and performance, risk management, internal control, financial systems, and accounting. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require deputy CFOs in CFO Act agencies to have defined responsibilities consistent with the breadth of those of the agency CFOs. (Matter for Consideration 2)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language to specify that the deputy CFO shall assist the agency CFO in the performance of each of the duties of the agency CFO. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require the Director of OMB to prepare and submit to the appropriate committees of Congress a government-wide 4-year financial management plan (with timing to match the GPRA reporting requirements) and an annual financial management status report.

a. The plan should include actions for improving financial management systems, strengthening the federal financial management workforce, and better linking performance and cost information for decision-making.

b. The plan should be developed in consultation with the CFO Council, the Chief Information Officers Council, the Chief Data Officer Council, the Chief Acquisition Officers Council, CIGIE, GAO, and other appropriate financial management experts. (Matter for Consideration 3)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for a government-wide 4-year financial management plan and an annual financial management status report. The plan is to address actions for improving financial management systems, strengthening the federal financial management workforce, and better linking performance and cost information for decision-making. The plan is to be developed in consultation with the CFO Council, the Chief Information Officers Council, the Chief Data Officer Council, the Chief Acquisition Officers Council, CIGIE, GAO, and other appropriate financial management experts. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require each CFO at a CFO Act agency, in consultation with financial management and other appropriate experts, to prepare an agency plan to implement the 4-year government-wide financial management plan prepared by OMB. (Matter for Consideration 4)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the CFO of each CFO Act agency to prepare, in consultation with financial management and other appropriate experts, an agency plan to implement the 4-year financial management plan prepared by the Director of the Office of Management and Budget and to achieve and sustain effective financial management in the agency. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require the Director of OMB to prepare comprehensive financial management performance-based metrics and use these metrics to evaluate the financial management performance of executive agencies. The metrics should be included in the government-wide and agency-level financial management plans, and agencies' performance against the metrics should be reported in the annual financial management status reports. (Matter for Consideration 5)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the Director of OMB to prepare comprehensive financial management performance-based metrics, which are to be used to evaluate the financial management performance of executive agencies. These metrics are to be included in the government-wide and agency-level financial management plans, and agencies' performance against the metrics are to be reported in annual financial management status reports. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require the head of each executive agency to identify, and if necessary develop, the key financial management information, in addition to financial statements, needed for effective financial management and decision-making. (Matter for Consideration 6)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the head of each CFO Act agency to identify key financial management information needed for effective financial management decision-making. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require the head of each executive agency to annually assess and separately report their conclusion on the effectiveness of internal controls of the agency over financial reporting and other key financial management information. (Matter for Consideration 7)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the head of each CFO Act agency to annually assess and separately report on the effectiveness of internal controls of the agency over financial reporting and other key financial management information. We will continue to monitor the status of this bill.

Recommendation: Congress should consider legislation to require auditors, as part of each financial statement audit of an executive agency, to test and report on internal control over financial reporting and other key financial management information. (Matter for Consideration 8)

Agency: Congress
Status: Open

Comments: A bill (S. 3287) introduced in February 2020 proposed changes to the CFO Act. Among the proposed changes was language that calls for the financial statement auditors of each CFO Act agency to report on their evaluation of internal control over financial reporting and other key financial management information. We will continue to monitor the status of this bill.

Recommendation: The Office of the Chief Financial Officer should require payment reporting sites to document their procedures for identifying, tracking, and reporting improper payments to ensure they provide consistent and comparable information about their improper payments over time. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation and said that it plans to clarify and adjust its current and future guidance to its payment reporting sites to require that the sites (1) develop and maintain procedures to support implementation of its payment integrity requirements for identifying, tracking, and reporting improper payments, and (2) require payment reporting sites to certify that the procedures have been developed and implemented. We will monitor and report on DOE's progress in implementing these planned actions.

Recommendation: The Office of the Chief Financial Officer should develop a monitoring process to ensure that payment reporting sites document and implement procedures that will enable them to correctly identify and report improper payments to the OCFO. (Recommendation 2)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation and said that it will (1) take measures to strengthen and enhance the existing payment integrity monitoring and quality assurance program by conducting period payment reporting site visits and (2) establish a payment integrity working group to identify best practices for incorporation into DOE processes. We will monitor and report on DOE's progress in implementing these planned actions.

Recommendation: The Office of the Chief Financial Officer should require payment reporting sites to document policies for tracking questioned costs to resolution. (Recommendation 3)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation and said they plan to develop and implement processes and procedures for tracking questioned costs to resolution. We will monitor and report on DOE's progress in implementing these planned actions.

Recommendation: The Office of the Chief Financial Officer should track information on the year the payment occurred for all improper payments, regardless of when they are identified, and determine and disclose in DOE's AFR whether the department's total annual improper payments exceeded $100 million in any given year. (Recommendation 4)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation and said it will conduct annual look-back analyses to the extent possible to determine if prior year reporting exceeded the $100 million threshold, and therefore could be subject to additional reporting requirements. We will monitor and report on DOE's progress in implementing these planned actions.

Recommendation: The Office of the Chief Financial Officer should clarify guidance to (1) define the factors for assessing adequacy of payment reporting sites' justifications that conducting recapture audits would not be cost-effective, and (2) require that the Office of the Chief Financial Officer review the sufficiency of these justifications against the criteria defined. (Recommendation 5)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation and said it will revise and enhance procedures defining the OCFO quality assurance process to (1) define the criteria for assessing the adequacy of payment reporting sites' justifications, and (2) review the payment reporting sites' justifications against the criteria defined. We will monitor and report on DOE's progress in implementing these planned actions.

Recommendation: The Office of the Chief Financial Officer should evaluate whether payment reporting sites could identify enough additional improper payments through payment recapture audits to make those audits cost-effective, such as by performing audits at selected sites. (Recommendation 6)

Agency: Department of Energy
Status: Open

Comments: DOE disagreed with the recommendation, stating in its comments that it has an ongoing Fraud Risk Management Working Group and that officials have developed a Fraud Risk Management and Data Analytics Implementation Plan to strengthen DOE's capability to prevent, identify, and recover improper payments and fraud. However, DOE's plan is still in draft form and, according to DOE's technical comments, they will not begin using data analytics until fiscal year 2021. In addition, DOE said that existing payment recapture activities to identify and recover improper payments are sufficient. However, as we discuss in the report, DOE determined that it does not need to conduct payment recapture audits based on justifications submitted by the reporting sites. We continue to believe that by evaluating whether it could identify enough additional improper payments to make payment recapture audits cost-effective, such as by performing audits at a limited number of sites, DOE would have an opportunity to identify and recover additional improper payments or have better information to justify that payment recapture audits are not cost-effective. We plan to monitor DOE actions related to this recommendation.

Recommendation: The Office of the Chief Financial Officer should revise DOE's department-level process for conducting improper payment risk assessments to include (1) developing and documenting the rationale for the variable scale used to score risk factors and weighting of the payment reporting sites; and (2) documenting DOE's consideration of the inherent risk associated with the lag in identifying certain improper payments subsequent to the fiscal year they occurred to ensure that the process results in a reliable assessment of whether the department is susceptible to significant improper payments. (Recommendation 7)

Agency: Department of Energy
Status: Open

Comments: DOE did not agree with the recommendation to develop and document the rationale for the scale used to score risk factors and weighting of payment sites, stating that its risk assessment evaluates the volume and dollar amount of payments by payment category, payments subject to manual controls, and fluctuations in volume and dollar amounts. However, we are recommending that the OCFO document the weighting of all its risk factors, including its decision to consider as equal the risks identified by all sites-regardless of the dollar amount of outlays. We continue to believe that, because DOE did not properly document how it developed and considered risk factors during its fiscal year 2018 risk assessment, it cannot ensure that the process produces a reliable assessment of whether DOE is susceptible to significant improper payments. Regarding the consideration of inherent risk, DOE said that the Payment Integrity Risk Assessment directs payment reporting sites to consider inherent risk as part of DOE's Internal Control Program. However, even if none of the sites identifies the known lag in identifying improper payments as a risk, based on our review of DOE's Agency Financial Reports, this lag is a risk to DOE as a whole. Therefore, we continue to believe that DOE should document in its risk assessment process its consideration of the known lag in identifying improper payments. We plan to monitor DOE actions related to this recommendation.

Recommendation: The Office of the Chief Financial Officer should revise DOE's department-level policies and procedures for reviewing risk assessments submitted by payment reporting sites to require a review and approval of the documentation supporting these assessments to help ensure the accuracy of the sites' assessments. (Recommendation 8)

Agency: Department of Energy
Status: Open

Comments: DOE did not agree with the recommendation, stating that sufficient processes are in place for ensuring the accuracy of payment reporting sites' risk assessments. DOE also stated that OCFO's Payment Integrity Guidance instructs payment reporting sites to maintain detailed information supporting risk assessments. However, as we discuss in the report, 5 of the 10 sites we reviewed did not provide sufficient explanation or documentation supporting their ratings for several of the risk factors. We continue to believe that by developing, documenting, and implementing policies and procedures to require the OCFO to review documentation supporting payment site risk assessments, DOE would enhance its ability to adequately monitor its decentralized improper payment risk assessment process and help ensure that individual payment reporting sites accurately score their risk factors, leading DOE to obtain a more accurate and reliable assessment of its overall risk of susceptibility to improper payments. We plan to monitor DOE actions related to this recommendation.

Recommendation: The Office of the Chief Financial Officer should revise DOE's department-level policies and procedures for conducting improper payment risk assessments to define the process for overriding a payment reporting site's risk determination, when appropriate. (Recommendation 9)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation and said that itwill clarify the quality assurance process for the payment reporting sites' ratings; however, DOE will not override the individual payment sites' risk determinations. Instead, DOE plans to work as needed with payment reporting site officials to determine the appropriate risk ratings. We will monitor and report on DOE's progress in implementing these actions.

Recommendation: We recommend that the Commissioner of Internal Revenue update and implement policies and procedures for developing a courier contingency plan to prohibit managers responsible for overseeing the preparation of taxpayer receipts for deposits from also transporting them to financial institutions. (Recommendation 20-01)

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

Comments: The IRS agreed with this recommendation and stated that the Wage and Investment organization will update the Courier Contingency Plan polices and procedures to provide for appropriate segregation of duties or other curative measures.

Recommendation: We recommend that the Commissioner of Internal Revenue establish and implement manual refund procedures to direct (1) initiators to document (e.g., record on the taxpayers' accounts or annotate on the related manual refund forms) the justification for bypassing the IAT tool warning related to potential duplicate tax refunds on taxpayers' accounts and (2) managers to monitor whether such warnings were bypassed and review the justifications for reasonableness prior to approving manual refund forms. (Recommendation 20-02)

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

Comments: The IRS agreed with this recommendation and stated that the Wage and Investment organization agrees that actions need to occur to address duplicate tax refund conditions through improved manual refund procedures to require (1) initiator to document the justification for bypassing the Integrated Automated Technologies (IAT) tool warning related to potential duplicate tax refunds on taxpayers' accounts and (2) managers to review the justification documented for bypassing the IAT tool warning for reasonableness prior to approving manual refund forms. However, IRS also stated that it was unable to commit to implementing a corrective action plan at this time due to budgetary constraints on system enhancements.

Recommendation: We recommend that the Commissioner of Internal Revenue establish and implement actions to provide reasonable assurance that business units record the acceptance of goods and services in a timely manner in accordance with IRS policies and procedures. (Recommendation 20-03)

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

Comments: The IRS agreed with this recommendation and stated that the CFO organization will determine the reasons for business unit(s) non-compliance with established policies and procedures related to timely recording of receipts and acceptance of goods and services and, based on this evaluation, develop an action plan that once completed will provide additional tools to aid the business units in reasonably ensuring compliance with established requirements.

Recommendation: We recommend that the Commissioner of Internal Revenue establish and implement actions to provide reasonable assurance that the future lease payment amounts for non-cancellable operating leases are calculated correctly. (Recommendation 20-04)

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

Comments: The IRS agreed with this recommendation and stated that the CFO organization will update policies and procedures to include additional instructions needed to calculate the future lease payments due on the non-cancelable leases with terms greater than one year and will also create an automated calculation to determine the number of remaining months of lease payments.

Recommendation: The Administrator of FNS should develop and implement a process, documented in policies and procedures, to analyze SNAP state-level root causes to identify potential similarities among the states and develop and implement SNAP agency-level corrective actions, if appropriate, to help address them. (Recommendation 1)

Agency: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service
Status: Open

Comments: In commenting on our draft report, USDA stated that the Food and Nutrition Service should formalize its existing processes into a standard operating procedure to analyze the Supplemental Nutrition Assistance Programs (SNAP) state-level root causes to identify potential similarities among states, in order to improve development and implementation of SNAP agency-level corrective actions, if appropriate.

Recommendation: The Secretary of Agriculture should revise USDA's procedures to include processes for monitoring the progress and measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect USDA's corrective actions have on reducing improper payments. (Recommendation 2)

Agency: Department of Agriculture
Status: Open

Comments: In commenting on our draft report, USDA stated that a proposed action plan will be developed to revise USDA's procedures for monitoring the progress and measuring the effectiveness of improper payment corrective actions. Processes will focus on the impact corrective actions have on the root causes of improper payments.

Recommendation: The Secretary of Education should revise and document Education's process for measuring the effectiveness of its corrective actions based on its new statistical estimation methodology for Direct Loan and Pell Grant improper payments. This process should clearly demonstrate the effect Education's corrective actions have on reducing improper payments. (Recommendation 3)

Agency: Department of Education: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, Education stated that Federal Student Aid (FSA) will continue to evaluate and refine its processes to measure corrective actions and the effectiveness of these actions. Further, Education stated that FSA's measurement of corrective action effectiveness and root cause identification will gain additional precision as FSA collects annual improper payment data and builds upon the new baseline of statistically valid improper payment estimates. Education stated that FSA annually measures the overall effectiveness of its corrective action plans collectively against the improper payment reduction targets, rather than measuring the effectiveness of each individual corrective action. However, OMB guidance directs agencies to measure the effectiveness of each individual corrective action annually.

Recommendation: The Secretary of Health and Human Services should document in policies and procedures HHS's improper payment corrective action plan process. As part of these procedures, HHS should include processes for (1) establishing planned completion dates, (2) monitoring the progress of implementing corrective actions, and (3) measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect HHS's corrective actions have on reducing improper payments. (Recommendation 4)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, HHS elaborated on the improper payment corrective action plan process that is called for in OMB guidance. HHS stated that OMB guidance provides agencies the flexibility to measure the effectiveness of corrective actions and believes that this flexibility is vital to its oversight processes to reduce improper payments.

Recommendation: The Secretary of the Treasury should determine whether Treasury's current improper payment root cause analysis provides sufficiently relevant information that can be used as a basis for proposed corrective actions in reducing EITC improper payments and, if not, update the analysis using more timely data to ensure their reliability for identifying root causes of EITC improper payments. (Recommendation 5)

Agency: Department of the Treasury: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, Treasury stated that each year it indicates in its corrective action plan that IRS will continue to work with Treasury to develop legislative proposals that will improve refundable credit compliance and reduce erroneous payments.

Recommendation: The Secretary of the Treasury should update Treasury's strategy for addressing the root causes of EITC improper payments to include (1) coordinating with other agencies to identify potential strategies and data sources that may help in determining EITC eligibility and (2) determining whether legislative changes are needed, and developing proposals as appropriate, to help reduce EITC improper payments, such as those related to the inability to authenticate taxpayer eligibility. (Recommendation 6)

Agency: Department of the Treasury: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, Treasury stated that each year it indicates in its corrective action plan that IRS will continue to work with Treasury to develop legislative proposals that will improve refundable credit compliance and reduce erroneous payments. Although Treasury has made certain legislative proposals, it has not made proposals to specifically help address EITC eligibility criteria issues. Additionally, Treasury's strategy does not include identifying and proposing additional legislative changes needed to help reduce EITC improper payments.

Recommendation: The Commissioner of SSA should develop and implement a process, documented in policies and procedures, to measure the effectiveness of SSA's corrective actions for OASDI and SSI improper payments. This process should clearly demonstrate the effect SSA's corrective actions have on reducing improper payments. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: In commenting on our draft report, SSA stated that it will determine the most cost-effective strategies to remediate the underlying causes of payment errors and monitor, measure, and revise the strategies as needed.

Recommendation: The Director of DFAS should, in accordance with the FMR, implement procedures to help ensure that FBWT reconciliations are consistently performed and that all DFAS sites review and document research conducted on the causes of any differences arising from these reconciliations. (Recommendation 1)

Agency: Department of Defense: Defense Finance and Accounting Service
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. They stated that the Defense Finance and Accounting Service (DFAS) will update the Financial Management Regulation (FMR) and implement procedures to help ensure Fund Balance with Treasury (FBWT) reconciliations are performed consistently and appropriate research on the causes of any difference arising from these reconciliations is reviewed and documented by all DFAS sites. Further, DFAS will update internal documentation/policy to outline DFAS roles and processes for FBWT reconciliations as well as include guidance on the execution of DOD's FMR FBWT reconciliation requirements. The estimated completion date for the implementation of this recommendation is December 2020. We will continue to follow-up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller) should update the FMR to clearly define the required supporting documentation for system-generated accounting adjustments, including the required documentation of business rules driving the recording of these adjustments, such as documentation of the programming logic. (Recommendation 2)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. They stated that the Department is developing a checklist of required supporting documents for incorporation into the DOD Financial Management Regulations (FMR). They will update the DOD FMR Volume, 6A, Chapter 2 to define the required supporting documentation for system generated accounting adjustments. Additionally, the Defense Finance and Accounting Service (DFAS) will update internal documentation to include narratives outlining the business rules for system generated accounting adjustments with the required supporting documentation. The estimated completion date for the implementation of this recommendation is December 2020. We will continue to follow up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller) should perform and document a comprehensive review of the FMR accounting adjustment category codes to determine their ongoing applicability or the need for additional codes to reflect the current financial reporting environment. (Recommendation 3)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department intends to collaborate with the financial community to update the category codes within the DOD Financial Management Regulations (FMR). Specifically, the Office of the Under Secretary of Defense will perform a comprehensive review of Journal Voucher Category Codes listed in DOD FMR, Volume 6A, Chapter 2 and update regulations based on feedback. The Defense Finance and Accounting Service will update internal documentation and procedures to reflect any code changes identified in the revised DOD FMR. The estimated completion date for this recommendation is July 2020. We will continue to follow-up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller) should establish procedures to help ensure the consistent implementation of the requirements of DFAS Form 9339. (Recommendation 4)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department plans to update the Defense Finance and Accounting Service (DFAS) Form 9339 and develop and conduct refresher training to all users of the Form 9339. The estimated completion date for this recommendation is September 2020. We will continue to follow-up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller) should update policies and procedures to identify the causes of out-of-balance accounting adjustments and resolve the causes in a timely manner. (Recommendation 5)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department is collaborating on utilizing existing data to identify and resolve out-of-balances and update DOD Financial Management Regulation, Volume 6A, Chapter 2 to include a section conveying out-of-balance accounting adjustments are not authorized. Root cause analysis efforts will be performed in conjunction with corrective action plans (CAPs) for recommendations 6--8. The estimated completion date for this recommendation is December 2020. We will continue to follow-up with DOD on the status of this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller), in conjunction with the Director of DFAS, should develop and implement policies and procedures to help ensure that root cause analyses for accounting adjustments are consistently performed and documented across DOD. (Recommendation 6)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department, in conjunction with the Director of Defense Finance and Accounting Service (DFAS), intends to utilize existing advanced analytics tools to research and document root cause analyses. The estimated completion date for the implementation of this recommendation is December 2020. We will continue to follow-up on this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller), in conjunction with the Director of DFAS, should develop and implement policies and procedures to help ensure consistent development, implementation, monitoring, and documentation of action plans across DOD that address accounting adjustment causes that staff identified internally. (Recommendation 7)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department intends to collaborate with the financial community, including the Director of the Defense Financial and Accounting Service (DFAS), and utilize existing tools for documenting and implementing consistent procedures for action plans of accounting adjustments. The analytical tool, Advana will be used to analyze the action plan code for consistent analysis to be performed across the DOD. The estimated completion date for the implementation of this recommendation is February 2021. We will continue to follow-up on this recommendation.

Recommendation: The Under Secretary of Defense (Comptroller), in conjunction with the Director of DFAS, should develop and implement procedures across DOD that include clearly defined outcomes focused on reducing accounting adjustments (supported and unsupported) with specific actionable steps and procedures for achieving stated goals. (Recommendation 8)

Agency: Department of Defense: Under Secretary of Defense (Comptroller)
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. The Department, in conjunction with the Director of the Defense Finance and Accounting Service, plans to utilize existing tools to define and measure the outcomes of accounting adjustments. The estimated completion date for the implementation of this recommendation is April 2021. We will continue to follow-up on this recommendation.

Recommendation: The Secretary of the Treasury should ensure that information about the 90-day delay for displaying DOD procurement data on USAspending.gov is transparently communicated to users of the site. Approaches for doing this could include prominently displaying this information on the DOD agency profile page, in the unreported data section, and in search results that include DOD data. (Recommendation 1)

Agency: Department of the Treasury
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Treasury should ensure that information regarding how the Primary Place of Performance Address for Medicare payment data are reported is transparently communicated to the users of USAspending.gov. (Recommendation 2)

Agency: Department of the Treasury
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

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: The Secretary of the Treasury should ensure that the Fiscal Assistant Secretary enhances existing procedures for Treasury management to perform additional reviews for restatements, reclassifications, and adjustments to beginning net position to reasonably assure that they are properly supported and accurately reported. (Recommendation 2)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), we determined that this recommendation remains open. Treasury enhanced its procedures to include additional management reviews, particularly the Financial Reports and Advisory Division Director, for restatements, reclassifications, and adjustments to beginning net position. Although FRAD took steps to enhance its review procedures, the additional review did not prevent FRAD from including descriptions in the draft CFS that were not supported by entity financial statements or from excluding some information from the CFS notes. Further steps are needed to define procedures to ensure consistent and accurate treatment of restatements, reclassifications, and adjustments to beginning net position in the CFS. We will follow-up on progress made by Treasury as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of the Treasury should ensure that the Fiscal Assistant Secretary, working in coordination with the Controller of OMB, establishes effective processes and procedures to reasonably assure that appropriate information regarding legal contingency losses is reported in the CFS. (Recommendation 4)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), we determined that this recommendation remains open. Treasury and OMB (1) increased guidance to federal entities in the Treasury Financial Manual section 2-4700; (2) included an illustrative Contingent Loss Table in OMB Circular No. A-136 for agencies to use as guidance when reporting probable and reasonably possible losses; (3) provided guidance to agencies through monthly Central Reporting Team (CRT) meetings with the agencies' financial reporting staff and at the Government Financial Management Conference; (4) communicated regularly with Department of Justice officials regarding the preparation of the government-wide legal representation letter; and (5) increased the number of Treasury staff performing the legal letter analysis. However, we noted inconsistencies among the significant component entities' financial statement note disclosures, management schedules, and legal representation letters, and the legal contingency loss information reported in the CFS, as well as inconsistencies between entities' year-end management schedules/legal representation letters and the final government-wide legal representation letter. We will follow-up on progress made by Treasury as part of our fiscal year 2020 CFS audit.

Recommendation: The Director of OMB, after consulting with key stakeholders (e.g., the Chief Financial Officers Council), should develop a strategy for ensuring that agencies communicate sufficient and timely internal control plans for effective oversight of disaster relief funds. (Recommendation 1)

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

Comments: The Office of Management and Budget (OMB) disagreed with our recommendation. In the agency's comment section of the GAO report, OMB staff stated that OMB did not believe the sufficiency or timeliness of control plans present material issues that warranted OMB action. While OMB acknowledged that almost all agency control plans were submitted after the statutory deadline, OMB staff stated that this delay in itself neither indicated the absence of controls nor the effectiveness of those controls. Further, OMB staff stated that it is agency management and not OMB that has responsibility for ensuring compliance with applicable laws and regulations. While agencies were responsible for submitting their internal control plans, federal law placed the responsibility of establishing the criteria for the internal control plans with OMB. Therefore, we believe that our recommendation is warranted. In January 2020, OMB informed us that there are no additional updates at this time regarding status, actions, or timelines to develop a strategy. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The Administrator of the Food and Nutrition Service should establish a process to plan and conduct regular fraud risk assessments for the school meals programs that align with the leading practices in the Fraud Risk Framework. (Recommendation 1)

Agency: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service
Status: Open

Comments: As of September 12, 2019, USDA stated that it will undertake, over the course of the next year, a re-evaluation of its existing research and oversight activity to measure and assess fraud risk, its efforts to manage that risk, and its work to minimize the occurrence and impact of fraudulent activity on the school meal programs. USDA also stated that it will look to GAO's Fraud Risk Framework as a model for this effort. USDA expects this effort to include some new activity, such as a deeper examination of the underlying causes of program error in the agency's periodic studies of improper payments. USDA also views this as an opportunity to clarify and highlight how the agency's existing approach to risk management currently addresses fraud risk. USDA agrees that it is appropriate to review and refine its existing controls on a regular basis and recognizes that a more formalized assessment of fraud risk is likely to uncover gaps in existing activity that point to opportunities for further agency action. USDA commits to the development of a response to the effort that is appropriate to the scale of the identified risk and the broader mission of the school meal programs. In September 2020, USDA stated that it has been reviewing agency research and administrative data, as well as conducting new analysis. USDA is concluding work on its risk assessment and plans to circulate it within the agency for review soon. We will continue to monitor USDA's progress in this area.

Recommendation: The Commissioner of Fiscal Service should develop and implement a mechanism to reasonably assure that all the journal entries recorded in the Schedules of the General Fund general ledgers can be readily identified and traced, such as through a unique identifier, to determine the effect of a transaction on all applicable general ledger accounts and line items of the Schedules of the General Fund, including the budget deficit. (Recommendation 1)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should develop and implement a mechanism to reasonably assure that payment transactions recorded in the Schedules of the General Fund general ledgers capture all of the key information needed, including payment schedules if applicable, to readily trace transactions to the information certified by the federal agency. (Recommendation 2)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should develop and implement additional reporting requirements with related guidance for federal agencies that better align with the General Fund financial reporting objectives and enable Fiscal Service to capture the effect of a transaction on all applicable general ledger accounts and line items of the Schedules of the General Fund, including the budget deficit. (Recommendation 3)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: We recommend that the Commissioner of Fiscal Service develop and implement a process that would enable Fiscal Service to obtain the information necessary to effectively assess the effect of the Statement of Difference on the Schedules of the General Fund for those federal agencies that have not implemented the Central Accounting and Reporting System. (Recommendation 4)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: We recommend that the Commissioner of Fiscal Service design and implement procedures to evaluate risks and monitor internal controls over financial reporting relevant to the Schedules of the General Fund. (Recommendation 5)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should develop and implement a mechanism for evaluating agencies' use of BETCs based on the enhanced guidance. (Recommendation 7)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should design and implement procedures to (1) obtain and review supporting documentation for reported activity included on Agency Submission Forms and (2) assess the overall completeness of federal agency activity reported on Agency Submission Forms. (Recommendation 8)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should design and implement procedures to periodically review all active Treasury accounts to determine whether they are valid and the related General Fund account balances are consistent with federal agency records. (Recommendation 10)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should enhance current procedures for reviewing negative balances to include Treasury accounts with indefinite periods of availability. (Recommendation 11)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials implement the necessary actions to effectively address the two primary causes of the significant deficiency in IRS's internal control over unpaid assessments. These actions should (1) resolve the system limitations affecting the recording and maintenance of reliable and appropriately classified unpaid assessments and related taxpayer data to support timely and informed management decisions, and enable appropriate financial reporting of unpaid assessment balances throughout the year, and (2) identify the control deficiencies that result in significant errors in taxpayer accounts and implement control procedures to routinely and effectively prevent, or detect and correct, such errors. (Recommendation 19-01)

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2019, IRS documented the key management decisions in the design and use of the estimation process. This step should reduce the risk that IRS may perform sampling procedures inconsistent with management intent or plans. Continued management commitment and sustained efforts are necessary to build on the progress made to date and to fully address IRS's remaining unresolved issues concerning the management and reporting of unpaid assessments. We will assess IRS's progress in addressing these issues during our audit of IRS's fiscal year 2020 financial statements.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials document and implement a formal comprehensive strategy to provide reasonable assurance concerning its nationwide coordination, consistency, and accountability for internal control over key areas of physical security. This strategy should include nationwide improvements for (1) coordinating among the functional areas involved in physical security; (2) implementing and monitoring the effectiveness of physical security policies, procedures, and internal controls; and (3) ongoing communication in identifying, documenting, and taking corrective action to resolve underlying control issues that affect IRS's facilities. (Recommendation 19-02)

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that Facilities Management and Security Services is in the process of developing and documenting a formal, comprehensive strategy. According to IRS officials, this strategy will include different overarching goals, such as improving workforce effectiveness, ensuring appropriate monitoring functions and employee accountability, and improving coordination and communication of policies and procedures. IRS plans to complete the formal, comprehensive strategy during fiscal year 2020 and finalize the implementation of this strategy by March 2021.

Recommendation: The Commissioner of Internal Revenue should ensure that appropriate IRS officials determine the reasons staff did not consistently comply with IRS's existing requirement for maintaining an emergency contact list at all of its facilities and, based on this determination, establish a process to enforce compliance with the requirement. (Recommendation 19-03)

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2019, IRS used a questionnaire survey and obtained feedback from security section chiefs and physical security specialists to determine the reasons staff did not consistently comply with IRS's existing requirement to maintain an emergency contact list at all IRS facilities. IRS officials stated that during fiscal year 2020, the Facilities Management and Security Services will establish a process to better enforce compliance with the requirement based on the results of the feedback obtained.

Recommendation: The Commissioner of Internal Revenue should ensure that appropriate IRS officials establish and implement policies and procedures requiring that corrective actions be documented in the Alarm Maintenance and Testing Certification Report for malfunctioning alarms identified in the annual alarm tests. (Recommendation 19-04)

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, the Facilities Management and Security Services will (1) update the Internal Revenue Manual to reflect the requirement to use the Alarm Maintenance and Testing Certification Report to document alarm testing results, including any malfunctioning alarms and related corrective actions taken, as appropriate;, and (2) review the Alarm Maintenance and Testing Certification Report Form and incorporate any additional instructions and fields to document the specific alarms tested, the testing results, and related corrective actions taken, as appropriate.

Recommendation: The Commissioner of Internal Revenue should ensure that the appropriate IRS officials establish and implement policies or procedures, or both, to provide reasonable assurance that the video surveillance systems at all IRS facilities record activity at the correct time and are properly secured. The policies or procedures should include periodic checks and adjustments, as needed, as part of the annual service and maintenance of security equipment and systems. (Recommendation 19-05)

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, the Facilities Management and Security Services will develop, document, and implement policies or procedures, or both, to provide reasonable assurance of the accuracy and physical security of the video surveillance systems at all IRS facilities by including periodic checks and adjustments, as needed, as part of the annual service and maintenance of security equipment.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials update and implement policies or procedures, or both, to clarify (1) who is responsible for conducting the annual review of the visitor access logs, (2) the date by which the review is to be conducted, and (3) how the review should be documented. (Recommendation 19-06)

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, the Information Technology and the Criminal Investigation organizations will update and implement their policies or procedures, or both, to clarify (1) who is responsible for conducting the annual review of the visitor access logs, (2) the date by which the review is to be conducted, and (3) how the review should be documented.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials (1) identify the reason IRS's policies and procedures related to the transmittal forms were not always followed and (2) design and implement actions to provide reasonable assurance that SB/SE units comply with these policies and procedures. (Recommendation 19-07)

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that the Small Business/Self-Employed (SB/SE) Field Collection organization determined that the reasons the policies and procedures were not always followed were either a lack of understanding of the requirements or a lack of consistency in adhering to them. In order to address this, in October 2019, Field Collection distributed a memorandum to its area directors, territory managers, and group managers, reminding them of the required remittance processing procedures, emphasizing the importance of following the procedures, and requesting that they distribute the information in the memorandum within their organization. IRS officials stated that the memorandum will help assure that SB/SE Field Collection units comply with the applicable policies and procedures. Since this memorandum was issued after the end of our fiscal year 2019 audit, we will review the implementation of this action during our fiscal year 2020 audit. Further, IRS officials stated that during fiscal year 2020, the SB/SE Examination organization will identify the reason that IRS's policies and procedures for transmittal forms were not followed, and based on this, it will add guidance to the applicable Internal Revenue Manual sections to clarify and supplement the service-wide guidance for the appropriate control, monitoring, and review of the forms used to transmit packages containing personally identifiable information.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials update and implement policies or procedures, or both, to clearly define the roles and responsibilities of second-level managers and IDRS security account administrators for validating the information on USR designation forms, including specifying how the information should be validated. (Recommendation 19-08)

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2019, the Information Technology (IT) organization updated IRS's Integrated Data Retrieval System (IDRS) security policy contained in the Internal Revenue Manual to ensure that the IDRS account administration process complies with IRS's personnel security policy regarding background investigation completion dates. In addition, IRS officials stated that by November 2020, the IT organization will update the Unit Security Representative (USR) designation form, as well as policies and procedures, to clearly define the roles and responsibilities of second-level managers and IDRS security account administrators for validating the information on USR designation forms, including how the information should be validated.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials update and implement procedures to clearly specify the tax refund data elements that PVS COs are required to verify before certifying the tax refunds in SPS. (Recommendation 19-09)

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

Comments: During fiscal year 2019, the Information Technology organization updated its standard operating procedures to clearly specify the tax refund data elements that the Processing Validation Section Certifying Officers are required to verify before certifying the tax refunds in the Secure Payment System. Since IRS completed this action after we had already performed our fiscal year 2019 testing related to the certification of tax refunds, we will evaluate IRS's actions to address this recommendation during our fiscal year 2020 audit.

Recommendation: The Commissioner of Internal Revenue should ensure that the appropriate IRS officials establish and implement a review process to provide reasonable assurance that the RSNs that Data Conversion key entry operators enter into the ISRP system and post to the master files are correct. (Recommendation 19-10)

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

Comments: IRS actions to address this recommendation are ongoing. IRS officials stated that during fiscal year 2020, the Wage & Investment organization will establish and implement a review process to provide reasonable assurance that the Refund Schedule Numbers on manual refund forms are transcribed accurately into the Integrated Submission and Remittance Processing system.

Recommendation: The Commissioner of Internal Revenue should ensure that the appropriate IRS officials implement a validity check in the ISRP system to confirm that RSNs that Data Conversion key entry operators enter into the system have the required 14 digits. (Recommendation 19-11)

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

Comments: IRS officials stated that the Wage and Investment organization agrees that developing and implementing a Unified Work Request for programming changes is needed to systemically validate the refund schedule numbers input into the Integrated Submission and Remittance Processing system; however, IRS officials indicated that the organization is unable to commit to implementing a corrective action because of budgetary constraints. As a result, IRS will place this recommendation on hold until funds are available.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials update and implement policies or procedures, or both, to require that reviewers follow up with tax examiners to verify the errors that tax examiners made in working on cases related to suspicious or questionable tax returns are corrected. (Recommendation 19-12)

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that by April 2020, IRS will update and implement policies or procedures, or both, requiring that reviewers follow up with tax examiners to verify that the errors tax examiners made in working a case related to suspicious or questionable tax returns are corrected.

Recommendation: The Program Director for Financial Integration should collect and document requirements to define project scope and meet project objectives. These requirements should be updated periodically throughout the life of the project. (Recommendation 2)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: As of August 2020, NNSA provided a project plan for tasks to be completed for common financial reporting through 2021. However, NNSA has not developed requirements that define specific or detailed requirements for successful implementation of common financial reporting, such as the types of information that program managers need.

Recommendation: The Program Director for Financial Integration should develop a detailed project schedule. The detailed schedule should be documented as part of the annual report to Congress required in the National Defense Authorization Act for Fiscal Year 2017. (Recommendation 3)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: As of August 2020, NNSA established a detailed project schedule for the common financial reporting effort through fiscal year 2021. However, NNSA should communicate this detailed project schedule for the effort to Congress on an annual basis.

Recommendation: The Program Director for Financial Integration should develop a formal process to identify risks, document those risks, and plan how to minimize risk exposure. (Recommendation 6)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: In June 2020, NNSA developed a risk management plan for common financial reporting which established a framework for identifying and managing risks. GAO will continue to monitor NNSA's efforts to implement the plan, including how NNSA identifies and documents risks and mitigates risk exposure using its management plan.

Recommendation: The Program Director for Financial Integration should develop an approach to effectively engage with all project stakeholders that incorporates their expectations into project decisions. (Recommendation 7)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: As of September 2020, NNSA has continued to engage on a regular basis with its M&O contractors. However, similar efforts have not continued with stakeholders of the program offices.

Recommendation: The Secretary of Health and Human Services should revise HHS's process for conducting improper payment risk assessments for Head Start to help ensure that it results in a reliable assessment of whether the program is susceptible to significant improper payments. This should include preparing sufficient documentation to support its risk assessments. (Recommendation 1)

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: The Department of Health and Human Services (HHS) concurred with this recommendation. In fiscal year 2019, HHS reported that it utilized Microsoft SharePoint to facilitate and begin to automate the Improper Payment Risk Assessment process. According to HHS, the SharePoint risk assessment form included the added ability to track the status of submissions and collect any applicable supporting documentation. Also, HHS stated that the Assistant Secretary for Financial Resources staff discussed the importance of maintaining supporting documentation during the fiscal year 2019 Improper Payment Risk Assessment Kick-Off meeting with HHS's operating divisions, and also built this feature into the SharePoint form. In fiscal year 2020, HHS reported that the implementation of the long-term solution to conducting improper payment risk assessments, the Risk Assessment Portal (previously called the Automated Improper Payment Framework), is underway and went into production in March 2020. Additionally, HHS indicated that it has revised its improper payment questionnaire and scoring process to ensure HHS performs a reliable assessment of susceptibility to significant improper payments. Also, HHS stated that it will leverage the Risk Assessment Portal, new questionnaire, and revised scoring process in the fiscal year 2020 risk assessment reporting period. Further, HHS stated that it is reviewing GAO reports and resources, capturing best practices from other agencies, and soliciting feedback from HHS's operating divisions to further improve its processes. Last, HHS stated that it will continue to develop policies, procedures, and supporting tools throughout calendar year 2020. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Secretary of Health and Human Services should revise HHS's procedures for conducting improper payment risk assessments to help ensure that all programs and activities are assessed for susceptibility to significant improper payments at least once every 3 years, as required by IPIA. (Recommendation 2)

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: The Department of Health and Human Services (HHS) concurred with this recommendation. In fiscal year 2019, HHS reported that it utilized DATA Act information to create an inventory of programs and activities that could potentially be subject to improper payment risk assessment requirements. According to HHS, it developed a risk-based methodology for selecting programs and activities for review using the DATA Act files. Data fields within the DATA Act files allow HHS to further analyze the program and activity inventory. For example, the object class data enabled HHS to categorize the program's spending to provide insight into each program's unique risks. HHS stated that this methodology was used and documented in fiscal year 2019 but HHS plans to further refine and finalize this approach. In fiscal year 2020, HHS reported that its Office of the Inspector General (OIG) is currently reviewing the methodology as part of the Annual Inspector General review of HHS's improper payment reporting under the Improper Payments Elimination and Recovery Act of 2020. HHS stated that it will implement any feedback from the OIG, as well as lessons learned from the fiscal year 2019 and fiscal year 2020 risk assessment reporting period, in fiscal year 2021. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Attorney General should revise DOJ's process for conducting improper payment risk assessments for Law Enforcement to help ensure that it results in a reliable assessment of whether the program is susceptible to significant improper payments. This should include preparing sufficient documentation to support DOJ's risk assessments. (Recommendation 4)

Agency: Department of Justice
Status: Open
Priority recommendation

Comments: The Department of Justice (DOJ) did not concur with this recommendation. In January 2020, DOJ reiterated that it continues to not concur with the recommendation. DOJ stated that its risk assessment methodology provides DOJ management with a reasonable basis for determining whether the law enforcement program, as well as DOJ's other four mission-aligned programs, are susceptible to significant improper payments. In addition, DOJ reiterated that it continues to not concur with GAO's conclusion that DOJ's risk assessment documentation is not adequate. DOJ stated that its documentation meets all of the requirements in the Improper Payments Information Act of 2002 (IPIA), as amended, and the Office of Management and Budget's (OMB) implementing guidance. Therefore, DOJ stated that it does not believe it would be a prudent use of limited resources to expand on the documentation that already exists. DOJ stated that notwithstanding its differences from GAO on the recommendation, it will continue to examine its risk assessment methodology. Finally, DOJ stated that its goal has been, and continues to be, meeting the requirements of IPIA, as amended, and OMB's implementing guidance in a cost effective manner. We continue to believe this recommendation is appropriate because DOJ's risk assessment documentation did not adequately demonstrate how DOJ determined the weighting of the risk factors or the numerical risk level ranges or whether a program is or is not susceptible to significant improper payments. We will continue to monitor the agency's actions to address the recommendation.

Recommendation: The Director of OMB should take steps to update OMB guidance to specify other types of quality information that agencies with programs noncompliant for 3 or more consecutive years should include in their notifications to Congress, such as significant matters related to risks, issues, root causes, measurable milestones, designated senior officials, accountability mechanisms, and corrective actions or strategies planned or taken by agencies to achieve compliance. (Recommendation 1)

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

Comments: The Office of Management and Budget (OMB) neither agreed or disagreed with the recommendation but stated that it had no comments. In January 2020, OMB informed us that it had no status updates to provide at this time. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The acting Bank president and Board chairman should ensure that the Bank evaluates and implements methods to further promote and sustain an antifraud tone that permeates the Bank's organizational culture, as described in GAO's Fraud Risk Framework. This should include consideration of requiring training on fraud risks relevant to Bank programs, for new employees and all employees on an ongoing basis, with the training to include identifying roles and responsibilities in fraud risk management activities across the Bank. (Recommendation 1)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM told us it continues work in this area and will provide us information on this work as it is completed. We will continue to monitor EXIM's progress in this area.

Recommendation: The acting Bank president and Board chairman should ensure that the Bank develops and implements an antifraud strategy with specific control activities, based upon the results of fraud risk assessments and a corresponding fraud risk profile, as provided in GAO's Fraud Risk Framework. (Recommendation 4)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM told us it was in the final stages of its process for completing its antifraud strategy. We will continue to monitor EXIM's efforts in this area.

Recommendation: The acting Bank president and Board chairman should ensure that the Bank identifies, and then implements, the best options for sharing more fraud-related information--including details of fraud case referrals and outcomes--among Bank staff, to help build fraud awareness, as described in GAO's Fraud Risk Framework. (Recommendation 5)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM stated that it is continuing to work with its Inspector General to implement this recommendation. We will continue to monitor EXIM's progress in this area.

Recommendation: The acting Bank president and Board chairman should lead efforts to collaborate with the Bank's OIG to identify a feasible, cost-effective means to systematically track outcomes of fraud referrals from the Bank to the OIG, including creating a means to link the OIG's proven cases of fraud to the specific Bank transactions from which the OIG actions arose. If any such means are found to be feasible and cost-effective, the acting Bank president and Board chairman should direct appropriate staff to implement them, with such information to be used for purposes consistent with GAO's Fraud Risk Framework, such as data analytics. (Recommendation 6)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM stated that it is continuing to work with its Inspector General to implement this recommendation. We will continue to monitor EXIM's progress in this area.

Recommendation: The acting Bank president and Board chairman should ensure that the Bank monitors and evaluates outcomes of fraud risk management activities, using a risk-based approach and outcome-oriented metrics, and that it subsequently adapts antifraud activities or implements new ones, as determined to be appropriate and consistent with GAO's Fraud Risk Framework. (Recommendation 7)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM stated that it is continuing work to implement this recommendation. We will continue to monitor EXIM's progress in this area.

Recommendation: The Secretary of the Treasury should include in Treasury's fiscal year 2018 AFR information about all civil monetary penalties within its jurisdiction, including the inflation adjustment of the civil monetary penalties. (Recommendation 5)

Agency: Department of the Treasury
Status: Open

Comments: In November 2018, Treasury issued its fiscal year 2018 agency financial report and included information about all civil monetary penalties within its jurisdiction. However, it did not adjust two civil monetary penalty amounts for inflation and indicated that it planned to complete the regulations to adjust these two amounts for inflation by the end of 2018. In November 2019, Treasury issued its fiscal year 2019 agency financial report and included information about all civil monetary penalties within its jurisdiction. However, it did not adjust one of the two civil monetary penalty amounts for inflation in our finding. As of June 2020, Treasury has not taken the necessary corrective actions to completely address this recommendation.

Recommendation: The Commissioner of the IRS should ensure the operational analysis for IMF fully addresses greater utilization of technology or consolidation of investments to better meet organizational goals. (Recommendation 1)

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

Comments: In August 2019, IRS provided its fiscal year 2018 Operational Analysis Results report, dated June 24, 2019. The report demonstrated that IRS, in response to our recommendation, had ensured that the operational analysis for IMF fully addressed greater utilization of technology or consolidation of investments to better meet organizational goals. However, the operational analysis did not reflect IRS's progress to date in modernizing IMF and the associated challenges. As we reported, this omission is concerning given the risk exposure from the agency's continued use of the legacy assembly language code. In order to close the recommendation, IRS needs to update the operational analysis to reflect its progress modernizing IMF.

Recommendation: The Commissioner of the IRS should ensure the operational analysis for Telecommunications Systems and Support (TSS) addresses the extent to which the investments support customer processes as designed, and how well the investments are delivering the goods or services they were designed to deliver. (Recommendation 3)

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

Comments: In August 2019, IRS provided its fiscal year (FY) 2018 Operational Analysis Results report, dated June 24, 2019. While the report included a summary of the FY 2018 operational analysis for TSS, it did not identify the metrics used to determine whether TSS supported customer processes or delivered the goods and services that it is intended to deliver. To close this recommendation, IRS will need to provide the detailed operational analysis for TSS incorporating these metrics. As of December 2019, IRS has not provided the full TSS operational analysis to GAO. Upon receiving the document, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should ensure the operational analysis for TSS includes a comparison of current performance with a pre-established cost baseline. (Recommendation 4)

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

Comments: In August 2019, IRS provided GAO its fiscal year (FY) 2018 Operational Analysis Results report. While the report included a summary of the FY 2018 operational analysis for the Telecommunications Systems and Support (TSS) investment , including planned and actual cost figures for FY2018, the report did not indicate whether the planned cost figure for FY2018 accounted for reimbursable costs and user fees, as we reported. To address this recommendation, IRS will need to provide a full operational analysis for TSS, as well as documentation showing whether reimbursable costs and user fees are included in the planned cost figure. As of December 2019, IRS has not provided a full TSS operational analysis to GAO. Upon receiving the document, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should ensure the operational analysis for End User Systems and Services includes a comparison of current performance with a pre-established cost baseline. (Recommendation 5)

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

Comments: In August 2019, IRS provided its fiscal year (FY) 2018 Operational Analysis Results report, dated June 24, 2019. While the report included a summary of the FY 2018 operational analysis for End User Systems and Services (EUSS) investment, including planned and actual cost figures for FY2018, it did not specify whether the planned cost figure accounted for multi-year funding and user fees, as we reported. To address this recommendation, IRS will need to provide a full operational analysis for EUSS, as well as documentation showing whether multi-year funding and user fees are included in the planned cost figure. As of December 2019, IRS has not provided the full EUSS operational analysis to GAO. Upon receiving it, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with preparing for risk management for the IMF investment. (Recommendation 7)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with analyzing risk for the IMF investment. (Recommendation 8)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice for prioritizing risk for the IMF investment. (Recommendation 9)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates indicating whether the agency has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with mitigating risk for the IMF investment. (Recommendation 10)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with monitoring, reporting, and controlling risk for the IMF investment. (Recommendation 11)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with preparing for risk management for the IDRS investment. (Recommendation 12)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates indicating whether the agency has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with analyzing risk for the IDRS investment. (Recommendation 13)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates on the status of the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with mitigating risk for the IDRS investment. (Recommendation 14)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates indicating whether the agency has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with monitoring, reporting, and controlling risk for the IDRS investment. (Recommendation 15)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by November 2019. As of December 2019, IRS has not provided any updates indicating whether the agency has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with preparing for risk management for the MSSS investment. (Recommendation 16)

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

Comments: In November 2019, IRS provided its IT Enterprise Operations Mainframe and Servers Services and Support (MSSS) Risk Management Plan, dated October 7, 2019. While the plan addressed most of the activities associated with the preparing for risk management key practice, it did not identify risk constraints, risk assumptions, or risk tolerance for the MSSS investment. Upon receiving further information, we will review it to determine if IRS has fully addressed this recommendation.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with analyzing risk for the MSSS investment. (Recommendation 18)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by October 2019. In November 2019, IRS provided its IT Enterprise Operations Mainframe and Servers Services and Support (MSSS) Risk Management Plan, dated October 7, 2019, along with several other documents associated with the agency's IT risk management process. However, the documents do not demonstrate that IRS has implemented the activities associated with the Analyze Risk key practice. Specifically, while the plan describes a risk analysis process in which risks are classified as high, medium, or low risk, neither the plan nor any of the other documents describes criteria for evaluating and quantifying risk likelihood and severity (impact) levels. Additionally, the Risk Management Plan does not indicate whether analysis of MSSS risks includes both inherent and residual risks. Upon receiving additional information indicating that IRS has addressed these activities, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with mitigating risk for the MSSS investment. (Recommendation 19)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by October 2019. In November 2019, IRS provided its IT Enterprise Operations Mainframe and Servers Services and Support (MSSS) Risk Management Plan, dated October 7, 2019, along with several other documents associated with the agency's IT risk management process. However, the documents do not demonstrate that IRS has established threshold values for MSSS risk categories or alternative courses of action for critical risks. Upon receiving additional information indicating that it has addressed these activities. we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should fully implement the risk management key practice associated with monitoring, reporting, and controlling risk for the MSSS investment. (Recommendation 20)

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

Comments: In September 2018, IRS told GAO it would implement the recommendation by October 2019. In November 2019, IRS provided its IT Enterprise Operations Mainframes and Servers Services and Support (MSSS) Risk Management Plan, dated October 7, 2019, along with several other documents associated with the agency's IT risk management process. However, the documents do not demonstrate that IRS has fully implemented all of the activities associated with the monitoring, reporting, and controlling key practice. Specifically, our review of the documents shows that IRS has not established threshold values for MSSS risk categories, and as a result is unable to compare the status of risks to acceptability thresholds to determine the need for implementing a risk mitigation plan. In addition, although the MSSS Risk Management Plan was updated in October 2019, its previous revision occurred in October 2017, indicating that IRS has not yet reviewed all aspects of the risk management program at least once a year. Upon receiving additional information that IRS has addressed these activities, we will review it to determine if IRS has implemented the recommendation.

Recommendation: The Commissioner of the IRS should fully implement IT workforce planning practices, including the following actions (1) setting the strategic direction for workforce planning; (2) analyzing the workforce to identify skill gaps; (3) developing strategies and implementing activities to address skill gaps; and (4) monitoring and reporting on progress in addressing skill gaps. (Recommendation 21)

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

Comments: In September 2018, IRS told GAO it had initiated efforts to address workforce planning agency-wide. The agency stated that the Human Capital Office in coordination with the Information Technology organization prioritizes critical skills gaps to develop gap mitigation strategies, which are implemented through IT annual training plans and succession planning efforts. IRS also stated that the mitigation plans will be monitored in the current Project and Portfolio Management System and that the Human Capital and Information Technology organizations will monitor resource capacity, skills, assigned work effort, and staff availability. In addition, IRS stated that it would utilize special hiring authorities as a competency and staffing mitigation strategy. The agency noted that the special authorities are subject to the availability of resources and agency approval. Further, IRS stated that, due to the diversion of IT resources to the Tax Cuts and Jobs implementation, development of a plan for scaling and expansion of workforce planning efforts will commence after the opening of Filing Season 2020. IRS stated that, due to those constraints, it could not provide a date for fully implementing the recommendation. As of December 2019, IRS has not provided any updates indicating whether it has implemented the recommendation. When we confirm what actions IRS has taken, we will provide updated information.

Recommendation: The Director of OMB should develop guidance on how agencies test to identify improper payments, such as using a risk-based approach to help ensure that key risks of improper payments, such as eligibility, are addressed through testing processes. (Recommendation 1)

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

Comments: OMB partially concurred with this recommendation. On July 31, 2019, we met with the Office of Management and Budget (OMB). At the meeting, OMB officials indicated that OMB's position has not changed since the issuance of the GAO report and what OMB had already communicated to GAO at the exit conference. Specifically, OMB stated that it should not have to develop more specific guidance as each program and activity has its own risks. Instead, inspectors general are better equipped and positioned to review the sampling and estimation plans as part of their annual Improper Payments Elimination and Recovery Act of 2010 compliance audits and that agencies, their statisticians, and inspectors general should work out the best testing procedures for their agencies. We continue to believe that OMB could provide suggestions during OMB's annual town meeting related to improper payments for areas that inspectors general may consider. Further, although we agree that programs and activities may face different risks of improper payment, we continue to believe that guidance from OMB on how agencies test to identify improper payments, such as using a risk-based approach, could help ensure that agencies address the specific risks they identify when developing improper payment estimates. In February 2020, OMB informed us that it had no status updates to provide at this time. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The Director of OMB should develop guidance clarifying the appropriate treatment of nonresponse cases during improper payment testing. (Recommendation 2)

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

Comments: OMB concurred with this recommendation. On July 31, 2019, we met with the Office of Management and Budget (OMB). At the meeting, OMB officials indicated that OMB's position has not changed since the issuance of the GAO report and what OMB had already communicated to GAO at the exit conference. At the meeting, OMB officials stated that OMB will "consider" updating guidance in OMB Circular A-123, Appendix C, to direct agencies to treat nonresponse cases such as improper payments and to include a new category for tracking such cases but only after assessing the impact such guidance would have on the agencies testing and reporting of improper payments. OMB has not taken action to develop this guidance. In February 2020, OMB informed us that it had no status updates to provide at this time. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The Director of OPM should assess the processes to estimate Retirement improper payments to determine whether they effectively address key risks of improper payments--including eligibility and whether older claims face different risks of improper payments than new claims--and take steps to update the processes to incorporate key risks that are not currently addressed. (Recommendation 4)

Agency: Office of Personnel Management
Status: Open

Comments: The Office of Personnel Management (OPM) partially concurred with this recommendation. Prior to 2006, the improper payment estimate sampling methodology used by OPM included both new and old adjudicated claims. After analyzing several years of data using this methodology, OPM found that including older claims in the sample could result in claimant's records being sampled multiple times. In addition, OPM also found that the variance in the number of errors detected in new claims versus old claims was very low. OPM also looked at the resources used in performing the audit of old and new claims and based on these factors, management determined that it was not an efficient use of resources to include both old and new claims in the review. The methodology was updated to make the process more efficient. By using new claims only, OPM was able to provide feedback to program managers more timely. As a result, management can address issues negatively impacting the improper payment rate and prevent improper payments promptly. OPM agrees with the intent of our recommendation; however, OPM does not agree with our recommendation regarding a risk assessment on eligibility. Eligibility is determined before annuity/survivor benefits are fully adjudicated. As part of its correction plan, OPM stated that it will conduct an audit of older claims to determine if there are different risks to new claims. In February 2020, OPM indicated that it is currently in the process of pulling/gathering the cases that should be in the universe of this audit. OPM plans to complete the corrective action by end of 4th quarter of fiscal year 2020. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Acting Commissioner of Internal Revenue should ensure that the appropriate IRS officials, based on IRS's research and determination, design and implement the corrective actions necessary to reasonably assure that IRS effectively resolves and records unpostable transactions in a timely manner, including establishing clearly defined time frames in the Internal Revenue Manual (IRM) by which the IRS operating divisions should correct unpostable transactions and appropriate related oversight and review processes. (Recommendation 18-02)

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

Comments: IRS's actions to address this recommendation are ongoing. As of September 30, 2019, three of the four operating divisions involved in this recommendation designed and implemented the corrective actions necessary to reasonably assure that IRS effectively resolved and recorded unpostable transactions in a timely manner. In March 2019, one operating division determined that based on the research performed, no actions needed to be taken by the operating division to effectively resolve and record unpostable transactions in a timely manner. We will continue to evaluate IRS's actions to address this recommendation during our audit of IRS's fiscal year 2020 financial statements.

Recommendation: The Acting Commissioner of Internal Revenue should ensure that the appropriate IRS officials develop and implement policies in the IRM for conducting and monitoring the Submission Processing internal control review. These policies should include or be accompanied by procedures to (1) assess and update the review questions and cited IRM criteria to reasonably assure they align with the controls under review; (2) periodically evaluate and document a review of the error threshold methodology to assess its current validity based on changes to the operating environment; (3) report findings identified in the Findings and Corrective Actions Report; and (4) assess and monitor (a) safeguarding internal control activities across all work shifts, particularly during peak seasons, (b) safeguarding internal control activities for the appropriate use and destruction of hard copy taxpayer information, and (c) the results of relevant functional level reviews. (Recommendation 18-03)

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

Comments: During fiscal year 2019, IRS developed policies in the Internal Revenue Manual (IRM) for conducting and monitoring the Submission Processing internal control review. Specifically, the IRM addresses the (1) designated roles and responsibilities among IRS business units for ensuring the review questions and associated criteria are assessed and updated to align with internal controls under review; (2) requirements for periodically evaluating the error threshold methodology used in the review; (3) procedures for the review to assess and monitor (a) internal control activities across work shifts and (b) internal control activities for appropriate use and destruction of hard-copy taxpayer information. However, the IRM did not include requirements for reporting findings identified during all components of the internal control review and for assessing and monitoring results of relevant functional level reviews. Since IRS developed the relevant IRM policies and procedures after we had already performed our fiscal year 2019 internal control testing, we will evaluate IRS's implementation of the established procedures during our fiscal year 2020 audit.

Recommendation: The Acting Commissioner of Internal Revenue should ensure that the appropriate IRS officials develop and implement policies in the IRM for conducting and monitoring the Audit Management Checklist review. These policies should include or be accompanied by procedures for IRS management responsible for establishing policies related to safeguarding controls to (1) periodically monitor the results of the review; (2) clarify the minimum requirements for how frequently the review should be completed at its various facilities while considering factors that may affect the most appropriate timing of these reviews, such as changes in personnel, operational processes, or information technology; and (3) reasonably assure that corrective actions for all identified deficiencies are tracked until fully implemented. (Recommendation 18-04)

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

Comments: In September 2019, IRS notified stakeholders of the added procedures to the Internal Revenue Manual (IRM) for (1) conducting the Audit Management Checklist reviews, including how frequently the reviews should be completed; (2) developing corrective actions for deficiencies; and (3) tracking the status of the corrective actions until fully implemented. Since IRS provided us the IRM procedures after the end of our fiscal year 2019 audit, we will evaluate IRS's implementation of the established procedures during our fiscal year 2020 audit.

Recommendation: The Acting Commissioner of Internal Revenue should ensure that the appropriate IRS officials develop and implement policies in the IRM for conducting and monitoring the All Events History Report review. These policies should include or be accompanied by procedures for IRS management responsible for establishing policies related to safeguarding controls to (1) periodically monitor the results of the review and (2) reasonably assure that corrective actions for all identified deficiencies are tracked until fully implemented. (Recommendation 18-05)

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

Comments: In September 2019, IRS notified stakeholders of the added procedures to the Internal Revenue Manual (IRM) for conducting the All Events History Report reviews, including developing and monitoring corrective actions for deficiencies until fully implemented. Since IRS provided us the IRM procedures after the end of our fiscal year 2019 audit, we will evaluate IRS's implementation of the established procedures during our fiscal year 2020 audit.

Recommendation: To improve internal controls over the Forest Service's budget execution processes, the Chief of the Forest Service should (1) design, document, and implement a comprehensive system for administrative control of funds and (2) submit it for review and approval by USDA before issuance, as required by the USDA Budget Manual. (Recommendation 3)

Agency: Department of Agriculture: Forest Service
Status: Open

Comments: The Forest Service generally agreed with this recommendation and stated that its financial policies concerning budget execution have been revised to address our concerns with allotments, unliquidated obligations, commitments, and administrative control of funds as prescribed by OMB Circular A-11. Further, the Forest Service stated that it has undertaken an in-depth review of its unliquidated obligations and modified the certification process to comply with the USDA requirement. However, the Forest Service has not yet provided support for the review and approval of the administrative control of funds by USDA and OMB. GAO will continue to follow up on the status of this recommendation.

Recommendation: To improve internal controls over the Forest Service's budget execution processes, the Chief of the Forest Service should develop, document, and implement a process and related control activities to reasonably assure that standard operating procedures and desk guides (1) clearly refer to guidance in the Directive System for allotments, reimbursable agreements, and review of unliquidated obligations and (2) are reviewed and approved by responsible officials prior to use. (Recommendation 11)

Agency: Department of Agriculture: Forest Service
Status: Open

Comments: The Forest Service generally agreed with this recommendation and stated that it has made significant progress to address this recommendation. Specifically, the Forest Service stated that its financial policies concerning budget execution have been revised to address allotments, unliquidated obligations, commitments, and administrative control of funds as prescribed by OMB Circular A-11. Further, the Forest Service stated that it has undertaken an in-depth review of its unliquidated obligations and modified the certification process to comply with the USDA requirement. However, as of August 2020, the Forest Service has not provided support for the training provided to implement the revised procedures. GAO will continue to follow up on the status of this recommendation.

Recommendation: The Director of OMB should continue to provide ongoing technical assistance that significantly contributes to agencies making their own determinations about their DATA Act reporting requirements and monitor agency submissions. (Recommendation 1)

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

Comments: OMB stated in January 2020 that it believes that the assistance it has previously provided to help agencies make their own reporting determinations fulfills the recommendation's intent. However, because we continue to identify instances where agencies had not submitted these data, we continue to believe that OMB needs to follow up with agencies that are not submitting quarterly data to find out why they are not reporting. It also needs to update its list of agencies required to report.

Recommendation: The Director of OMB should clarify and align existing guidance regarding the appropriate definitions agencies should use to collect and report on Primary Place of Performance and establish monitoring mechanisms to foster consistent application and compliance. (Recommendation 2)

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

Comments: OMB has issued or contributed to guidance documents that are intended to help agencies collect and report on "Primary Place of Performance." We believe that providing specific examples of how agencies should approach challenging situations when reporting on this data element for grants would provide further clarity.

Recommendation: The Secretary of the Treasury should reasonably assure that ongoing monitoring controls to help ensure the completeness and accuracy of agency submissions are designed, implemented, and operating as designed. (Recommendation 4)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: In September 2019, Treasury officials stated that they are working to formalize a process for monitoring agency submissions. This process will include (1) emailing agencies prior to submission deadlines to remind them of the approaching submission deadlines; (2) following up with agencies that do not submit required data by the submission deadline and offering technical assistance as needed; and (3) forwarding a list of non-compliant agencies to OMB. GAO will continue to monitor Treasury's efforts to establish monitoring controls to help ensure the completeness and accuracy of the data.

Recommendation: The Secretary of the Treasury should disclose known data quality issues and limitations on the new USAspending.gov. (Recommendation 5)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of January 2020, Treasury has made progress by disclosing limitations related to unreported spending, among other things. Treasury is planning a major update to the USAspending.gov website to include more information about known data quality issues. Treasury plans to make this update to the website in the coming months and has an internal target date of June 2020 for completion. When completed, this action will help users make more informed decisions about how to interpret and use the data provided on the website.

Recommendation: The DHS Under Secretary for Management should develop and implement effective processes and improve guidance to reasonably assure that future AAs fully follow AOA process best practices and reflect the four characteristics of a reliable, high-quality AOA process. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: DHS stated that it remains committed to its financial system modernization program and agrees that effective processes and guidance are necessary to assure best practices. In September 2020, DHS officials informed us that they did not have any updates to report on efforts to address this recommendation. We will continue to follow-up with DHS on actions to address this recommendation.

Recommendation: The DHS Under Secretary for Management should improve the Risk Management Planning Handbook and other relevant guidance for managing risks associated with financial management system modernization projects to fully incorporate risk management best practices, including (1) defining thresholds to facilitate review of performance metrics to determine when risks become unacceptable; (2) identifying and analyzing risks to include periodically reconsidering risk sources, documenting risks specifically related to the lack of sufficient, reliable cost and schedule information needed to help properly manage and oversee the project, and timely disposition of IV&V contractor-identified risks; (3) developing risk mitigation plans with specific risk-handling activities, the costs and benefits of implementing them, and contingency plans for selected critical risks; and (4) implementing risk mitigation plans to include establishing periods of performance for risk-handling activities and defining time intervals for updating and certifying the accuracy and completeness of information on risks in DHS's risk register. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: DHS stated that it is committed to its financial system modernization program and agrees that effective processes and guidance are necessary to assure best practices. In September 2019, DHS provided documentation that cross walked DHS' Risk Management Training Aide to the Capability Maturity Model Integration (CMMI) for acquisition risk management best practices. However, the optional nature of the language used in the Training Aide does not reasonably assure that program offices will follow the suggested guidance. Also, the Training Aide does not specifically require the linking of thresholds to cost, schedule, and performance elements of identified risks. Based on our review of the information provided, DHS's corrective actions were not sufficient for addressing the intent of our recommendation. We will continue to evaluate DHS actions to address this recommendation.

Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to annually report improper payment estimates and error rates for the advance PTC program.

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: The Department of Health and Human Services (HHS) concurred with this recommendation. On May 23, 2018, HHS's Centers for Medicare and Medicaid Services (CMS) stated that it is currently in the process of developing an improper payment measurement for the advance premium tax credit (PTC). The development of the measurement methodologies will be a multi-year process which consists of the development of measurement policies, procedures, and tools. It also includes extensive pilot testing to ensure an accurate and efficient improper payment estimate, as well as, acquisition activities for procurement of improper payment measurement contractors. In January 2020, CMS stated that it is still in the process of developing an improper payment measurement for the advance PTC. Further, CMS stated that it provided progress updates in the fiscal year 2019 HHS agency financial report (AFR), and will continue to do so in future AFRs until an improper payment rate is estimated. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, and until annual reporting of improper payment estimates and error rates for the advance PTC program is performed, the Secretary of Health and Human Services should direct the Administrator of CMS to disclose significant matters relating to the Improper Payments Information Act (IPIA) estimation, compliance, and reporting objectives for the advance PTC program in the agency financial report, including CMS's progress and timeline for expediting the achievement of those objectives and the basis for any delays in meeting IPIA requirements.

Agency: Department of Health and Human Services
Status: Open

Comments: HHS concurred with this recommendation. On February 28, 2018, the Department of Health and Human Services's (HHS) Centers for Medicare and Medicaid Services (CMS) stated that updates on the advance premium tax credit (PTC) program improper payment measurement development were provided in the fiscal year (FY) 2017 Agency Financial Report (AFR), which was published in November 2017. In FY 2018, we reviewed the FY 2017 AFR that HHS's CMS cited in support for closing this recommendation. Based on our review, the FY 2017 AFR does not address our recommendation as it does not provide a timeline for reporting an improper payment estimate. In FY 2019, we reviewed HHS's FY 2018 AFR published in November 2018, which includes a statement that HHS will continue to update its annual AFRs on the status of the measurement program development until the improper payment estimate is reported. However, this latest AFR also does not provide a timeline for reporting an improper payment estimate for HHS's PTC program. In January 2020, CMS stated that it is in the process of procuring federal contractors to perform the improper payment measurement. However, CMS further stated that due to uncertainties surrounding the timing of the procurement, CMS does not anticipate publishing a reporting timeline until the contracts have been awarded. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: To improve annual reporting on PTC improper payments, control activities related to eligibility determinations, and calculations of advance PTC, the Secretary of Health and Human Services should direct the Administrator of CMS to design and implement procedures for verifying the identities of phone and mail applicants to reasonably assure that ineligible individuals are not enrolled in qualified health plans in the marketplaces or provided advance PTC.

Agency: Department of Health and Human Services
Status: Open

Comments: The Department of Health and Human Services (HHS) neither agreed nor disagreed with this recommendation. Regarding verification of filer identity, HHS stated, in response to the draft report, that for individuals starting an application via phone, the call center representatives use verbal attestations for verifications from individuals. HHS stated that for paper applications, individuals must provide names and complete addresses as well as other information. In addition, HHS stated that individuals must attest that the information they provide on all applications is accurate by signing under penalty of perjury. However, these steps do not involve the verification of an applicant's identity to a third-party source. In August 2018, HHS officials stated that they are exploring alternatives for assessing risk and ensuring integrity of applicant information that is provided to the program and ways to ensure personal information provided by an individual is accurate through a variety of means. After this analysis phase, they will assess resource requirements, cost, and operational implications for potential implementation approaches with a target date for completion of 2019. As of December 2018, HHS had not designed and implemented procedures for verifying the identities of phone and mail applicants, as GAO recommended. As of January 2020, HHS indicated that it is developing new policy and guidance which could significantly change potential solutions or requirements. However, HHS did not provide us a time frame for when it plans to finalize the new policy and guidance. We will continue to monitor agency's actions to address the recommendation.

Recommendation: To comply with improper payments reporting requirements and improve procedures related to processing PTC information on tax returns, the Commissioner of Internal Revenue should direct the appropriate officials to assess the program against applicable IPIA-defined thresholds and conclude on its susceptibility to significant improper payments, and revise the scope of its improper payments susceptibility assessment for the PTC program to include instances in which advance PTC is greater than or equal to the amount of PTC claimed on the tax return. If the program meets the IPIA definition for being susceptible to significant improper payments based on this assessment, estimate and report improper payments associated with the PTC program consistent with IPIA requirements.

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

Comments: The Internal Revenue Service (IRS) partially agreed with this recommendation. On December 13, 2019, IRS provided us a status update and stated that its Research, Applied Analytics and Statistics division completed an analysis of net premium tax credit (PTC) using National Research Program (NRP) tax years 2015 and 2014 data during the 4th quarter of fiscal year 2019 and developed improper payment estimates using two different methodological approaches. However, IRS indicated that it did not publish these improper payment estimates in Treasury's Agency Financial Report for two reasons: (1) there is as yet insufficient NRP data to develop an estimate that is within the confidence interval and margin of error prescribed by the Office of Management and Budget for improper payments sampling, and (2) the Department of the Treasury (Treasury) wishes to engage with Health and Human Services' Centers for Medicare & Medicaid Services on the potential for developing a joint rate estimate for advance PTC and PTC. In addition, IRS noted that it had not yet determined whether this is even possible from a data compatibility standpoint. Further, IRS stated that while the estimates do not meet the statistical precision requirement, they do suggest that Net PTC would meet the criteria to be considered susceptible to significant improper payments. IRS indicated that when it last discussed this recommendation with GAO, it was suggested this recommendation would be closed once improper payment rates are published. However, IRS would now like GAO to consider closing this recommendation at this time given (1) the IRS's efforts to analyze potential improper payments, (2) Treasury's new approach to reporting, and (3) the need for additional years of data before a statistically valid estimate can be developed. We do not believe the recommendation should be closed at this time based on the three reasons IRS has listed above. However, we credit IRS for exploring ways to meet the intent of the recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: To comply with improper payments reporting requirements and improve procedures related to processing PTC information on tax returns, the Commissioner of Internal Revenue should direct the appropriate officials to assess and document the feasibility of approaches for incorporating information from the marketplaces on individuals who did not demonstrate that they met the eligibility requirements for citizenship or lawful presence in the tax compliance process. If determined feasible, IRS should work with Treasury to require marketplaces to periodically provide such information on individuals and use such information to recover advance PTC made for those individuals.

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

Comments: The Internal Revenue Service (IRS) agreed with this recommendation. In December 2018, an IRS official indicated that IRS conducted a detailed review of the recommendation. IRS informed GAO that it is internally discussing an alternative way to address the recommendation to prevent premium tax credit to noncitizens. The IRS official indicated that IRS is reviewing this alternative with the Department of the Treasury and the Department of Health and Human Services' Centers for Medicare & Medicaid Services. IRS did not provide GAO with a time frame for its implementation. On December 13, 2019, IRS provided us a status update and stated that it had no new information for this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB, to improve corrective action plans for (1) treaties and international agreements, (2) additional audit procedures for intragovernmental activity and balances, and (3) the Reconciliation Statements so that they include sufficient information to address the control deficiencies in these areas effectively.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), we determined that this recommendation remained open. Treasury believes that its current remediation plan, including its various corrective action plans (CAPs), is comprehensive, appropriate, and effective, with robust and ongoing monitoring processes in place. However, we continue to note that the CAPs in these three areas do not include sufficient steps to effectively address related control deficiencies involving processes used to prepare the CFS. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of Defense should direct the Office of the Under Secretary of Defense (Comptroller) to provide guidance in the DOD Financial Management Regulation on the timing of when DOD managers should use available tools to help ensure that monthly cash balances are within the upper and lower cash requirements.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and plans to update guidance in Volume 2B, Chapter 9, Paragraph 090103 4.j. of the DOD Financial Management Regulation. The draft guidance provided by DOD stated that "Components should consider leveraging the aforementioned available cash management tools when cash execution is trending below/above plan for more than three consecutive months of execution." In August 2020, DOD told us that after coordination within DOD, they estimate the final guidance related to our recommendation will be included in the DOD Financial Management Regulation guidance by April 2021.

Recommendation: The IRS Commissioner should direct the appropriate IRS officials to strengthen the process for reasonably assuring that the Internal Revenue Manual (IRM) is reviewed annually to align with the current control procedures and guidance being implemented by agency personnel. This should include a mechanism for reasonably assuring that program owner directors (1) review their respective program control activities and related guidance annually and timely update the IRM as needed, (2) document their reviews, and (3) utilize interim guidance and supplemental guidance correctly for their intended purposes.

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2018, IRS created an annual Internal Revenue Manual (IRM) review and certification requirement to reasonably assure that all IRM sections align with the current control procedures and guidance that IRS personnel are implementing. In addition, the Small Business/Self-Employed (SB/SE) and Tax Exempt & Government Entities (TE/GE) organizations developed action plans to achieve substantial compliance with this requirement. During fiscal year 2019, the SB/SE organization completed its action plan; however, IRS officials stated that the TE/GE organization will complete its action plan during fiscal year 2020. Further, in fiscal year 2019, the Large Business & International organization reviewed and analyzed the results of its involvement in the annual IRM certification process. Based on the results of its analysis, the organization developed an action plan to achieve substantial compliance with the IRM review and certification requirement, which IRS officials stated it will complete by December 2021.

Recommendation: To help ensure that DOD is implementing the fraud, waste, and abuse prevention requirements to the OIGs, the Inspectors General of the Army, Navy, and Air Force should implement the requirements themselves or delegate the implementation of the requirements to the investigative services.

Agency: Department of Defense: Department of the Navy: Naval Inspector General
Status: Open

Comments: DOD concurred with the recommendation in its comments on the draft report. In June 2020, we requested information on the status of the recommendation. When we confirm the actions the Navy has taken, we will provide updated information.

Recommendation: To help ensure that DOD is implementing the fraud, waste, and abuse prevention requirements to the OIGs, the Inspectors General of the Army, Navy, and Air Force should implement the requirements themselves or delegate the implementation of the requirements to the investigative services.

Agency: Department of Defense: Department of the Army: Office of the Inspector General
Status: Open

Comments: DOD concurred with the recommendation in its comments on the draft report. As of July 2020, the Army had drafted a memorandum that would delegate the requirements to the investigative services or program office. We will update the status of this recommendation after the Army issues the final memorandum.

Recommendation: To allow DOE management to effectively monitor invoice reviews and have assurance that this control activity is operating as intended, the Secretary of Energy should establish a DOE-wide invoice review policy that includes requirements for sites to establish well-documented invoice review operating procedures.

Agency: Department of Energy
Status: Open

Comments: In its comments on a draft of the report in March 2017, DOE concurred in principle with this recommendation, stating that it already had an established, detailed DOE-wide invoice review policy provided in DOE's Financial Management Handbook and in the DOE Acquisition Guide. In February 2020, DOE issued an update to its Financial Management Handbook that included additional procedures to address intra-governmental payment and collection transactions. However, neither the prior version of the Financial Management Handbook nor the additional information includes invoice review procedures. The Financial Management Handbook refers users to the DOE Acquisition Guide for procedures for invoice review. However, the Acquisition Guide states that it is intended to offer general guiding principles for approving officials to consider when reviewing and analyzing cost elements included in contract invoices--as opposed to detailed procedures for invoice review--and does not require sites to establish well-documented invoice review operating procedures, as we recommended.

Recommendation: To help DOE take a more strategic approach to managing improper payments and risk, including fraud risk, the Secretary of Energy should implement leading practices for managing the department's risk of fraud, including creating a structure with a dedicated entity within DOE to design and oversee fraud risk management activities.

Agency: Department of Energy
Status: Open
Priority recommendation

Comments: In its comments on a draft of the report in March 2017, DOE partially agreed with the recommendation. In its written comments on the report, DOE stated that it considered the recommendation to be closed without corrective action and that it would rely on the existing Office of Financial Policy and Internal Controls and on the DOE Office of Inspector General (OIG) to design and oversee financial fraud risk management activities. However, we disagree that relying in part on the OIG to design and oversee fraud risk management activities meets best practices because, according to GAO's Fraud Risk Framework, the dedicated entity should not include the OIG so that the OIG can maintain its independence. In May 2020, DOE officials said they were developing a fraud risk and data analytics framework. Among other steps, DOE expects to establish a new group in fiscal year 2020 that will oversee DOE's fraud risk management activities. We will continue to monitor DOE's progress in implementing this recommendation.

Recommendation: To help DOE take a more strategic approach to managing improper payments and risk, including fraud risk, the Secretary of Energy should implement leading practices for managing the department's risk of fraud, including conducting fraud risk assessments that are tailored to each program and use the assessments to develop a fraud risk profile

Agency: Department of Energy
Status: Open

Comments: In its comments on a draft of the report in March 2017, DOE concurred with the substance of the recommendation; however they considered the recommendation to be closed without corrective action because DOE believed that its risk assessments met the requirements of the Improper Payments Elimination and Recovery Improvement Act of 2012, as reported by the Office of Inspector General (OIG), and because it has implemented updates to OMB Circular A-123 that added requirements related to managing fraud risk and adherence to GAO's Fraud Risk Framework. However, we found that DOE has not conducted fraud risk assessments that were tailored to its programs and, therefore, do not allow the department to create a fraud risk profile. We also found that, although DOE updated its internal control assessment tools with a list of fraud risks as required by OMB Circular A-123, the list of risks were the same for all DOE sites and were not tailored to the sites' different programs. In May 2020, DOE officials said they were developing a fraud risk and data analytics framework. Among other steps, the framework is expected to include changes to DOE's process to develop its fraud risk profile, beginning in fiscal year 2020. We will continue to monitor DOE's progress in implementing this recommendation.

Recommendation: To help DOE take a more strategic approach to managing improper payments and risk, including fraud risk, the Secretary of Energy should implement leading practices for managing the department's risk of fraud, including developing and documenting an antifraud strategy that describes the programs' approaches for addressing the prioritized fraud risks identified during the fraud risk assessment.

Agency: Department of Energy
Status: Open

Comments: In its comments on the draft report in March 2017, DOE concurred with this recommendation but considered the recommendation closed without corrective action because DOE had implemented the updated OMB Circular A-123 and because DOE's antifraud strategy was embedded in the DOE internal control program. However, DOE officials told us that they had not developed or documented a DOE-wide antifraud strategy or directed individual programs to develop program-specific strategies. Furthermore, DOE's implementation of OMB Circular A-123 included adding a list of potential risks to their internal control assessment tool that were the same for all DOE sites and were not tailored to the sites' different programs. In May 2020, DOE officials said they were developing a fraud risk and data analytics framework. Among other steps, DOE is planning to develop an antifraud strategy in fiscal year 2021. We will continue to monitor DOE's progress in implementing this recommendation.

Recommendation: To help DOE take a more strategic approach to managing improper payments and risk, including fraud risk, the Secretary of Energy should implement leading practices for managing the department's risk of fraud, including designing and implementing specific control activities, including fraud awareness training and data analytics, to prevent and detect fraud and other improper payments.

Agency: Department of Energy
Status: Open

Comments: In its comments on the draft report in March 2017, DOE stated that it concurred in principle with the recommendation, but that it had implemented the recommendation. In May 2020, DOE officials said they were developing a fraud risk and data analytics framework. Among other steps, DOE is planning to begin in fiscal year 2022 to use data analytics across the agency to prevent fraud. We will continue to monitor DOE's progress in implementing this recommendation.

Recommendation: To help ensure that necessary data are available to employ data analytics as a tool to perform contractor cost-surveillance activities, the Secretary of Energy should require contractors to maintain sufficiently detailed transaction-level cost data that are reconcilable with amounts charged to the government, including (1) cost data that, at a minimum, represent a full data population and (2) the details necessary to determine the nature of each cost transaction, with such identifiers as transaction date, dollar amount, item or service description, and transaction codes to indicate the type of cost represented (e.g., construction materials, property lease, and office supplies).

Agency: Department of Energy
Status: Open

Comments: In its comments on the draft report in March 2017, DOE did not agree to implement this recommendation because officials believe that the recommendation establishes agency-specific requirements for DOE contractors that are more prescriptive than current federal requirements. In May 2020, DOE officials said they were developing a fraud risk and data analytics framework. Among other steps, DOE is planning to begin in fiscal year 2022 to use data analytics across the agency to prevent fraud. We will continue to monitor DOE's progress in implementing this recommendation.

Recommendation: The Secretary of Agriculture should direct the Under Secretary for Food, Nutrition, and Consumer Services to design policies and procedures to reasonably assure that all award recipients required to submit single audit reports do so in accordance with OMB guidance.

Agency: Department of Agriculture
Status: Open
Priority recommendation

Comments: U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) neither agreed nor disagreed with our recommendation. As of February 3, 2020, FNS stated that it has made revisions to the agency audit manual to meet the intent of the recommendation. In a section of the manual devoted to Cognizant and Awarding Agency Responsibilities (2 CFR 200.513), FNS is adding a bullet that states that the Federal awarding agency must "ensure that audits are completed and reports are received in a timely manner and in accordance with the requirements of 2 CFR 200.512(a)." FNS plans on releasing the full agency audit manual to FNS users in final by the end of Fiscal Year 2020. We believe that FNS's corrective actions will help FNS to meet the intent of our recommendation with regards to designing policies. However, to fully meet the intent of the recommendation, in addition to revising policies, FNS also needs to implement procedures to ensure staff are following the revised policies. We will assess these efforts once completed.

Recommendation: The Secretary of Agriculture should direct the Under Secretary for Food, Nutrition, and Consumer Services to revise policies and procedures to reasonably assure that management decisions contain the required elements and are issued timely in accordance with OMB guidance.

Agency: Department of Agriculture
Status: Open
Priority recommendation

Comments: U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) neither agreed nor disagreed with our recommendation. As of February 3, 2020, FNS stated that it has made revisions to the agency audit manual to meet the intent of the recommendation. In a section of the manual devoted to Cognizant and Awarding Agency Responsibilities (2 CFR 200.513), FNS stated that it is expanding upon an existing bullet that states that the Federal awarding agency must "issue a management decision on audit findings within six months after receipt of the audit report....". FNS indicated this section of the manual will be expanded to include the four elements that a management decision must clearly state in writing as prescribed in 2 CFR 200.521(a). FNS plans on releasing the full agency audit manual to FNS users in final by the end of Fiscal Year 2020. We believe that FNS's corrective actions will help FNS to meet the intent of our recommendation with regards to designing policies. However, to fully meet the intent of the recommendation, in addition to revising policies, FNS also needs to implement procedures to ensure staff are following the revised policies. We will assess these efforts once completed.

Recommendation: The Secretary of Agriculture should direct the Under Secretary for Food, Nutrition, and Consumer Services to design and implement policies and procedures for identifying and managing high-risk and recurring single audit findings using a risk-based approach.

Agency: Department of Agriculture
Status: Open

Comments: U.S. Department of Agriculture's (USDA) Food and Nutrition Service (FNS) neither agreed nor disagreed with our recommendation. As of February 3, 2020, FNS stated that it has made revisions to the agency audit manual to meet the intent of the recommendation. In a section of the manual devoted to Cognizant and Awarding Agency Responsibilities (2 CFR 200.513), FNS is adding a bullet stating that the cognizant agency is responsible for "developing a risk-based approach to manage high-risk and recurring single audit findings to identify problems so that adequate resources can be dedicated to address the problem." FNS plans on releasing the full agency audit manual to FNS users in final by the end of Fiscal Year 2020. We believe that FNS's corrective actions will partially help FNS to meet the intent of our recommendation with regards to designing policies. When designing policies, we believe FNS also needs to clearly provide guidance on the risk management strategy over high-risk and recurring single audit findings, including the steps to follow for identifying problem areas and setting priorities for addressing them. To fully meet the intent of the recommendation, in addition to revising policies, FNS also needs to implement procedures to ensure staff are following the revised policies. We will assess these efforts once completed.

Recommendation: The Secretary of Agriculture should direct the Under Secretary for Rural Development to design policies and procedures to reasonably assure that all award recipients required to submit single audit reports do so in accordance with OMB guidance.

Agency: Department of Agriculture
Status: Open
Priority recommendation

Comments: U.S. Department of Agriculture's (USDA) Rural Development (RD) concurred with our recommendation. To address the GAO recommendation, in February 2020, RD stated that it has developed a disbursement report that will capture disbursements equal to or greater than $750,000 and is currently documenting that process and creating instructions for the program areas. RD indicated that it plans to complete these actions by June 30, 2020. We will assess these efforts once completed.

Recommendation: The Secretary of Agriculture should direct the Under Secretary for Rural Development to revise policies and procedures to reasonably assure that management decisions contain the required elements and are issued timely in accordance with OMB guidance.

Agency: Department of Agriculture
Status: Open
Priority recommendation

Comments: U.S. Department of Agriculture's (USDA) Rural Development (RD) concurred with our recommendation. To address the GAO recommendation, in February 2020, RD stated it has developed a Management Decision Manual template that the program areas will use and is currently creating instructions for the program areas. RD indicated that it plans to complete these actions by June 30, 2020. We will assess these efforts once completed.

Recommendation: The Secretary of Agriculture should direct the Under Secretary for Rural Development to design and implement policies and procedures for identifying and managing high-risk and recurring single audit findings using a risk-based approach.

Agency: Department of Agriculture
Status: Open

Comments: U.S. Department of Agriculture's (USDA) Rural Development (RD) concurred with our recommendation. To address the GAO recommendation, in February 2020, RD stated that it has developed a process to rate each single audit finding. According to RD, the ratings will be tracked in an Access Database, where it will generate reports indicating reoccurring and high-risk findings by borrower and by program. RD indicated that it plans to complete these actions by June 30, 2020. We will assess these efforts once completed.

Recommendation: The Secretary of Housing and Urban Development should direct the Principal Deputy Assistant Secretary for the Office of Community Planning and Development to design and implement policies and procedures for identifying and managing high-risk and recurring single audit findings using a risk-based approach.

Agency: Department of Housing and Urban Development
Status: Open

Comments: The Department of Housing and Urban Development's (HUD) Office of Community Planning and Development (CPD) stated that it did not agree with GAO's emphasis on high risk/recurring single audit findings. Nevertheless, in March 2019, HUD's CPD stated that it is working towards a redesigned model for analyzing risk as a basis for monitoring. In August 2020, HUD informed us that CPD is finalizing the beta test for the risk model. Although the risk model will be further defined and enhanced in fiscal year 2021 for fiscal year 2022, CPD plans to roll out the beta test of the risk model to develop the fiscal year 2021 risk rankings. Single audit will be one factor that is included in calculating the risk scores. CPD will validate and assess the results of the beta test and make adjustments as needed. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The Secretary of Housing and Urban Development should direct the Principal Deputy Assistant Secretary for the Office of Public and Indian Housing to design and implement policies and procedures for identifying and managing high-risk and recurring single audit findings using a risk-based approach.

Agency: Department of Housing and Urban Development
Status: Open

Comments: The Department of Housing and Urban Development's (HUD) Office of Public and Indian Housing (PIH) agreed with this recommendation. On May 7, 2018, PIH stated that it had implemented a Risk Based Approach Tool designed to identify and manage high-risk and recurring single audit findings. The Risk Based Approach tool was intended to track and focus on audit findings reported as material weaknesses or significant deficiencies and was designed to determine the resources needed and available to assist in mitigating the audit findings. However, in March 2019, PIH informed us that in late 2018, PIH began to work toward repositioning goals, priorities and identification of key risk indicators. PIH stated that it is now focused on aligning risk indicators to the HUD and PIH priorities. PIH priorities for fiscal year 2019 include addressing Public Housing Authorities insolvency which may be identified through an Independent Public Accountant audit or through other means. PIH stated that it no longer uses the assessment tool that included over 100 risk indicators. PIH indicated that it has a revised risk mitigation framework proposal that will be presented to the Enterprise Risk Counsel in the near future. In fiscal year 2020, we have sent additional follow-up questions to the agency and are currently waiting for a response. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The Secretary of the Army should direct the Accountability and Audit Readiness Directorate under the Assistant Secretary of the Army, Financial Management and Comptroller, to enhance the directorate's policies and procedures for (1) tracking and prioritizing all financial management-related audit findings and recommendations under its purview and (2) developing and monitoring CAPs for all such recommendations so that they include sufficient details, such as the criteria used to prioritize the CAPs, the recommended CAP elements, and the process for monitoring and documenting the progress and status of CAPs.

Agency: Department of Defense: Department of the Army
Status: Open
Priority recommendation

Comments: The Army concurred with this recommendation. The Army stated that the Accountability and Audit Readiness Directorate has completed actions to enhance its current standard operating procedures to include (1) updating its corrective action plan (CAP) database and reporting tool, (2) documenting its reporting procedures, and (3) updating its CAP template to include additional elements recommended by the Implementation Guide for OMB Circular A-123. In addition, the Army stated that its policies and procedures include steps to incorporate external financial management-related audit findings assigned to the Accountability and Audit Readiness Directorate by the Internal Review Directorate and that the existing process the Army uses to prioritize findings and the related CAPs and to monitor the progress and status of CAPs has been documented. We reviewed Army's documentation that was provided in January 2020. Army's documentation did not show that it has a process for ensuring that all financial management related findings and recommendations are identified and tracked. To implement this recommendations Army needs to enhance their policies and procedures related to tracking and monitoring the status of these audit findings.

Recommendation: The Secretary of the Air Force should design and document a comprehensive process to ensure that the complete universe of all financial management-related findings and recommendations from all audit sources is identified and tracked.

Agency: Department of Defense: Department of the Air Force
Status: Open
Priority recommendation

Comments: The Air Force concurred with this recommendation. In January 2018, the Air Force stated that it continues to develop a process for identifying and tracking financial management-related findings and recommendations from all audit sources by updating its process guidance. In August 2019, we received draft guidance that Air Force is developing as guidance and procedures for a universe of financial management-related findings and recommendations. In January 2020, we also received a list of the Air Force deficiencies being tracked in the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) database. After assessing the provided documentation, we found that the draft does not include procedures for identifying GAO, DODOIG, and Air Force Audit Agency (AFAA) findings and the database did not include deficiencies identified by those external auditors. As a result of our review of the documentation provided, we determined that the actions taken were not sufficient to close the recommendation.

Recommendation: The Secretary of the Air Force should update the Air Force's written policies and procedures for prioritizing financial management-related audit findings and recommendations from all audit sources and for developing and monitoring CAPs so that they include sufficient details. These procedures should include the following details: (1) The process to be followed for prioritizing the financial management-related findings and recommendations from audit sources. (2) The guidance for developing CAPs for all financial management-related audit findings and recommendations from all audit sources to include complete details, including the elements recommended by the Implementation Guide for OMB Circular A-123. (3) The process for monitoring the status of the CAPs for all financial management-related audit findings and recommendations from all audit sources, including the documentation to support any corrective actions taken, as recommended by the Implementation Guide for OMB Circular A-123.

Agency: Department of Defense: Department of the Air Force
Status: Open
Priority recommendation

Comments: The Air Force concurred with this recommendation. In January 2018, the Air Force stated that its Air Force Deficiency Remediation Tracking processes and guides were being refined. In December 2019, Air Force provided a document titled "NFR Prioritization Process." We found that this document included Air Force's priority categories. However, the document does not include information on determining the priority level or applying the priority levels when addressing the deficiencies. We also received a copy of Air Force's guide for the Corrective Action Plan (CAP) process dated July 2019. We found that this guide does not fully incorporate CAP development for deficiencies from all sources. Additionally, the guide does not provide information on the process for (1) determining resources and other requirements for remediating the deficiency, (2) conducting a cost benefit analysis, and (3) developing criteria for validating that the deficiency has been remediated. The guide also includes a template for conducting a root cause analysis. However, the instructions for conducting a root cause analysis are somewhat limited for determining the initial cause or underlying reason for the deficiency. Per the guide, the Air Force uses the Office of the Under Secretary of Defense (Comptroller) (OUSD(C)) database to monitor and report on Air Force's deficiencies and remediation CAP status. We obtained a listing of the NFRs and related CAPS in the database as of December 2019. We found that deficiencies from all audit sources were not included in the listing, only the independent public accountant's NFRs. The results of our review of a limited number of CAPs indicate that Air Force staff does not always comply with the Air Force's CAP requirements. As a result of our assessment of the Air Force documentation, we determined that the actions taken were not sufficient to close the recommendation.

Recommendation: To improve DOD management's process for monitoring the military services' audit remediation efforts and to provide timely and useful information to stakeholders as needed, the Secretary of Defense should direct the Secretary of the Army, the Secretary of the Navy, and the Secretary of the Air Force to prepare and submit to the Under Secretary of Defense (Comptroller), on at least a bimonthly basis for availability at the FIAR Governance Board meetings, a summary of key information included in the CAPs that at a minimum contains the data elements recommended by the Implementation Guide for OMB Circular A-123 for each CAP related to critical capabilities for achieving audit readiness.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation. DOD stated that it solicits input on a bi-monthly basis, on critical capability corrective action plans (CAPs) at a summary level. This information is provided routinely at regularly scheduled FIAR Governance Board meetings. DOD also stated that an updated notice of finding and recommendation (NFR) form template is being developed and will be provided to the military services to use for reporting this information so that it will include the recommended standard data elements outlined in OMB Circular A-123 to provide greater transparency into the nature of remediation plans. DOD also stated that FIAR Guidance will be updated to explicitly state that military services should include the OMB recommended standard data elements in CAPs. To implement this recommendation, DOD needs to provide documentation that shows that the military services are able to provide a summary of key information in the corrective action plans that at a minimum contains data elements recommended by the Implementation Guide for OMB Circular A-123. .

Recommendation: To reasonably assure that DOD management and external stakeholders have a comprehensive picture of the status of corrective actions needed for audit readiness throughout the department, the Secretary of Defense should direct the Under Secretary of Defense (Comptroller) to prepare a consolidated CAP management summary on a bimonthly basis that includes the data elements referred to above on the status of all CAPs related to critical capabilities for the military services and for the service providers and other defense organizations.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD partially concurred with this recommendation. According to DOD, the military services already provide summary-level updates on their critical capability corrective action plans (CAPs) at FIAR Governance Board meetings. It also stated that the template that is used to present CAPs to the FIAR Governance Board meetings at the summary level has been updated to align CAPs to critical capabilities. DOD still needs to address how all of the data elements from the Implementation Guide for OMB Circular A-123 will be summarized or otherwise reported for all CAPs pertaining to critical capabilities across the Department. In addition, DOD stated that because the Under Secretary of Defense (Comptroller) takes responsibility for maintaining, monitoring, and reporting on the status of CAPs for the service providers and other defense organizations and of DOD-wide issues, the Comptroller will also summarize this information. However, DOD has not clarified what information from the military services will be summarized. To implement this recommendation, DOD needs to provide documentation that shows the Comptroller has prepared a consolidated CAP management summary on a bimonthly basis.

Recommendation: To provide agencies access to SSA's more complete set of death data, Congress should consider amending the Social Security Act to explicitly allow SSA to share its full death file with Treasury for use through the DNP working system.

Agency: Congress
Status: Open

Comments: In fiscal year 2020, the Senate passed S.4104, which included language to address the recommendation. In the context of the Do Not Pay (DNP) working system, the bill, if enacted, would authorize comparison of the Social Security Administration's (SSA) full death file with personally identifiable information reviewed through the working system and would allow redisclosure of such comparison of information to any federal or state agency authorized to use the working system. As of July 15, 2020, the House has not introduced a related bill for fiscal year 2020. Additionally, in February 2020, the administration released its President's 2021 Budget, which proposes legislation to allow the DNP Business Center full access to the SSA full death file. This proposal would include the Department of the Treasury and the SSA working together to determine the most efficient manner to make full death information available for use in preventing improper payment and fraud. We will continue to monitor congressional legislation to address this recommendation. .

Recommendation: To better monitor agency use of the DNP working system once a strategy has been developed, the Director of OMB should develop and implement monitoring mechanisms--such as goals, benchmarks, and performance measures--to evaluate agency use of the DNP working system.

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

Comments: OMB agreed with the concept of monitoring mechanisms and will continue to work with agencies to reduce improper payments and encourage agencies to establish goals to improve payment accuracy that will be monitored and evaluated by OMB. In fiscal year 2019, OMB provided us a status update on July 31, 2019, stating that Treasury does this monitoring and reports updates to OMB on a quarterly basis and that monitoring will occur in conjunction with the President's Management Agenda. In August 2020, Treasury provided us examples of reports that it provides to OMB to assist OMB with evaluating agency use of the DNP working system. We plan to meet with OMB to discuss how it uses these reports and will continue to monitor OMB's actions to address this recommendation.

Recommendation: To reasonably assure that agency-reported information on use of the DNP working system is reliable, the Director of OMB should develop a process for comparing agency reporting on the use of the DNP working system to available sources, such as OMB guidance and DNP working system adjudication reports.

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

Comments: The Office of Management and Budget (OMB) agreed with the concept of ensuring that data are reliable and will consider the feasibility of a process to compare agency submissions to available sources to reasonably assure that agency-reported information on use of the Do Not Pay working system is reliable. OMB provided us a status update on July 1, 2019, stating that OMB will work with Treasury to determine feasibility of doing this review and establishing a process during fiscal year 2019. As of February 2020, OMB has not provided any new status updates for this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: To reasonably assure that agency-reported information on use of the DNP working system is complete, the Director of OMB should revise its guidance to clarify whether agencies should report on their uses of all of the functionalities of the DNP working system in their agency financial reports.

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

Comments: The Office of Management and Budget (OMB) agreed with ensuring the completeness of data and will continue to work with agencies and the Chief Financial Officer community to ensure that agency-reported information on the use of the Do Not Pay (DNP) working system is complete. In fiscal year 2019, OMB provided us a status update on July 1, 2019, stating that this recommendation was addressed in OMB's Circular A-136. Additionally, we met with OMB officials on July 31, 2019. During the meeting, OMB officials informed us that the OMB Circular A-136, Section II.4.5 (bullet 3) (dated June 28, 2019) states that "Agencies should provide a brief narrative of the reduction in improper payments that is attributable to the DNP Initiative, as applicable. See OMB Circular A-123, Appendix C, Part V for a thorough overview of the roles and responsibilities of agencies to use centralized data sources such as the Treasury Working System and other government databases to prevent improper payments." We have reviewed OMB Circular A-136 and confirmed that the circular does contain the statements above. However, we do not believe that the OMB Circular A-136 meets the intent of our recommendation. GAO issued its recommendation, in part, because GAO found that OMB guidance does not indicate whether agencies should report on all uses of the DNP working system, including those outside payment integration that the DNP working system does not track. For this reason, GAO report concluded that without complete and reliable data and clear guidance on what information agencies should report, OMB cannot effectively monitor and evaluate the use of the DNP working system. Therefore, we do not believe that the OMB Circular A-136 sufficiently clarifies whether agencies should report on their uses of all of the functionalities of the DNP working system in their agency financial reports. As of February 2020, OMB has not provided any new status updates for this recommendation. We will continue to monitor OMB's actions to address this recommendation.

Recommendation: To improve the Navy's implementation of the FIAR Guidance for its General Fund FBWT FIP and facilitate efforts to achieve SBR auditability, the Secretary of the Navy should direct the Assistant Secretary of the Navy, Financial Management and Comptroller, to prepare a level I quantitative drilldown in accordance with the FIAR Guidance.

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: The Navy concurred with this recommendation and stated that it has actions planned, taken, or under way to prepare a quantitative drilldown. In September 2017, Navy provided a listing of certain systems (DCAS, GLs, DDRS-B, and DDRS-AFS) it considered as Level 1 assessable units. However, the listing did not include a drilldown from the financial statement amounts through DDRS-AFS, DDRS-B, and DCAS to the receipt and disbursement source systems. In July 2020, Navy officials stated that Navy is implementing a new system that will enable them to complete a quantitative drill down for its Fund Balance with Treasury (FBWT). The new system is not expected to be fully implemented until March 2021. In the interim, certain FBWT reconciliations are performed at DFAS, that may provide a drilldown capability of FBWT as reported in financial statements to the applicable general ledger amounts.

Recommendation: To improve the Navy's implementation of the FIAR Guidance for its General Fund FBWT FIP and facilitate efforts to achieve SBR auditability, the Secretary of the Navy should direct the Assistant Secretary of the Navy, Financial Management and Comptroller, to prioritize audit readiness efforts for the key FBWT systems, prepare an audit strategy that identifies for each system (1) the Navy's plan for assessing the system to gain assurance that the system can be relied on; (2) the assessment types, including prioritizing the assessments based on qualitative and quantitative factors for each system; and (3) planned start and completion dates of these assessments for each system.

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: The Navy concurred with this recommendation and stated that it has actions planned, taken, or under way to prioritize audit readiness efforts for key Fund Balance with Treasury (FBWT) systems. In September 2017, Navy provided documentation for three systems, but this documentation did not address corrective actions for ineffective controls and the expected completion dates. Further, during our audit, Navy provided a list of 22 relevant systems. In July 2020, Navy officials stated that they are preparing an audit strategy for each system, and documenting control activities and computer controls for significant systems. We will continue to follow-up on the status of this recommendation.

Recommendation: To improve the Navy's implementation of the FIAR Guidance for its General Fund FBWT FIP and facilitate efforts to achieve SBR auditability, the Secretary of the Navy should direct the Assistant Secretary of the Navy, Financial Management and Comptroller, to prepare, in accordance with FIAR Guidance, the documentation of control activities and information technology general computer controls for significant systems; system certifications or accreditations; system, end user, and systems documentation locations; and hardware, software, and interfaces.

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: The Navy concurred with this recommendation and stated that it had actions planned, taken, or under way to document control activities, information technology general computer controls for significant systems, systems documentation locations, and hardware, software, and interfaces. In September 2017, Navy provided documentation for 3 systems, but the documentation did not include system certifications or accreditations; system, end user, and systems documentation locations; and hardware, software, and interfaces. Further, during our audit, Navy provided a list of 22 relevant systems. In July 2020, a Navy official told us that they are preparing an audit strategy for each system, and documenting control activities and computer controls for significant systems. We will continue to monitor Navy's progress addressing this recommendation.

Recommendation: To improve the Navy's implementation of the FIAR Guidance for its General Fund FBWT FIP and facilitate efforts to achieve SBR auditability, the Secretary of the Navy should direct the Assistant Secretary of the Navy, Financial Management and Comptroller, to prepare an internal control assessment document for each assessable unit, summarizing control activities that are appropriately designed and in place.

Agency: Department of Defense: Department of the Navy
Status: Open

Comments: The Navy concurred with this recommendation and stated that it had actions planned, taken, or under way to prepare an internal control assessment document. In September 2017, Navy provided support for actions taken to address this recommendation. However, the documentation provided did not summarize controls by assessable unit (DCAS, DDRS-B, or systems). Instead controls were listed by function (Treasury Reporting, Audit Readiness, and Departmental Reporting). In July 2020, a Navy official stated that documentation of overall Fund Balance with Treasury (FBWT) controls is in process and they are finalizing the Risk Control Matrix for FBWT to include controls at DFAS and at Treasury. The Rick Control Matrix is estimated to be completed by the end of August 2020. We will continue to monitor the progress in addressing this recommendation.

Recommendation: To address weaknesses in the department's financial management systems modernization efforts, the Secretary of HUD should direct the Chief Financial Officer to work with the Chief Information Officer in managing subsequent initiatives to define a high-level depiction of the IT systems anticipated in the future state, a description of the operations that must be performed and who must perform them, and an explanation of where and how the operations are to be carried out.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had collaborated through an IT technical assessment initiative, identifying four primary financial management modernization initiatives remaining from the New Core Program. In July 2020, HUD officials, including the Deputy Chief Financial Officer, provided a roadmap that defined a high-level depiction of the financial management systems anticipated in the future state. However, the department had not yet completed more detailed plans that (1) identify operations that must be performed and who must perform them and (2) explain where and how operations are to be carried out. We will continue to monitor HUD's efforts to address this recommendation.

Recommendation: To address weaknesses in the department's financial management systems modernization efforts, the Secretary of HUD should direct the Chief Financial Officer to work with the Chief Information Officer in managing subsequent initiatives to develop comprehensive plans for scope, schedule and cost.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had identified a need to pursue financial management systems modernization. As of July 2020, the department had begun taking action to address this recommendation. Specifically, HUD planned to integrate loan and property management into its current financial management shared service and had begun planning for how to modernize its budget formulation and cost accounting systems. For the budget formulation effort, HUD had developed high-level plans for the scope of the program, planned an implementation schedule, and estimated on the cost for implementation and operating and maintaining the system for two years. We will continue to monitor HUD's efforts to address this recommendation.

Recommendation: To address weaknesses in the department's financial management systems modernization efforts, the Secretary of HUD should direct the Chief Financial Officer to work with the Chief Information Officer in managing subsequent initiatives to ensure requirements are fully documented and traceable.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. In March 2017, the department reported that the Chief Financial Officer and the Chief Information Officer intended to partner on future departmental financial management systems modernization efforts to fully document requirements and trace requirements to the functionality in the modernized system. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had identified a need to pursue financial management systems modernization in 4 areas previously identified for the New Core program. As of July 2020, HUD was in the early phases of planning for modernization in these areas. According to officials from the Office of the Chief Financial Officer, the department intended to address this recommendation for budget formulation modernization by developing applicable plans and artifacts for managing requirements from the department's project planning and management framework. However, that effort has not yet started. We intend to continue to follow up on HUD's actions.

Recommendation: The Secretary of HUD should also direct the Deputy Secretary to ensure that the Chief Information Officer takes action to improve IT governance control activities used for monitoring programs and identifying needed corrective actions, and strengthen investment oversight by improving coordination with stakeholders and alignment among IT modernization efforts.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on our draft report, HUD neither agreed nor disagreed with our recommendations, but noted that it planned to improve management practices and IT governance for future modernization efforts. Since 2016, HUD has revised its IT governance boards, which provide oversight of all its IT investments, including financial management initiatives, several times. While the department has not yet completed those improvement efforts, HUD updated its project planning and management framework to tailor requirements and artifacts for different program types. According to an official from the Office of the Chief Financial Officer, updates to the requirements for shared services projects incorporated lessons learned from the New Core program. In April 2019, HUD reported that the Office of the Chief Information Officer and Office of the Chief Financial Officer had identified a need to pursue financial management systems modernization in 4 areas previously identified for the New Core program. Officials from both offices have described improvements in their coordination and collaboration on efforts to plan for modernization. We intend to continue to follow up on HUD's actions to ensure that planned improvements to governance and oversight mechanisms are effectively implemented and institutionalized.

Recommendation: To provide reasonable assurance that the property, equipment, and software transactions are properly tracked and capitalized or expensed as appropriate, the Director of CFPB should direct the program offices to require vendors to provide detailed invoices with costs broken out by project.

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: During our fiscal year 2019 audit, we continued to find control deficiencies over CFPB's accounting for its property, equipment, and software. CFPB was still in the process of working with its Office of Procurement and program offices to require more detailed invoices with costs broken out by project. We will continue to evaluate CFPB's actions to address this recommendation during our fiscal year 2020 financial statement audit.

Recommendation: The IRS Commissioner should direct the appropriate IRS officials to determine the reason(s) why staff did not always comply with IRS's established policies and procedures related to initiating, monitoring, and reviewing the monitoring of manual refunds and, based on this determination, establish a process to better enforce compliance with these requirements.

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

Comments: During fiscal year 2019, we identified instances where staff did not comply with IRS's policies and procedures related to monitoring and reviewing the monitoring of manual refunds. IRS officials stated that the Wage and Investment (W&I) organization determined that a fully automated process to perform monitoring of manual refunds is the optimal solution to address, at an enterprise level, deficiencies associated with reliance on employees to monitor refunds in process and take appropriate action when potential duplicate or erroneous refund conditions are encountered. In addition, IRS officials indicated that the W&I organization will develop business requirements and request programming through the Unified Work Request process; however, limited resources and competing priorities prevent the identification of an implementation date. As a result, IRS will place this recommendation on hold until an implementation date is known.

Recommendation: The IRS Commissioner should direct the appropriate IRS officials to identify the cause of and implement a solution for dealing with the periodic backlogs of ICO inventory that is hampering the performance of quality reviews.

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

Comments: During fiscal year 2019, the Wage and Investment (W&I) organization determined that periodic backlogs of Input Correction Operation (ICO) inventory were caused by a combination of factors, such as systemic issues, fluctuations in projected filings, and hiring challenges. IRS officials stated that the W&I organization has also identified and implemented several strategies to address ICO backlogs and mitigate the impact on the quality review program, including hiring more staff in ICO functions, using seasonal employees, cross-training, overtime, transferring of work, and updating the Internal Revenue Manual. Since IRS provided us with this information near the end of our fiscal year 2019 audit in September 2019, we will evaluate IRS's actions to address this recommendation during our fiscal year 2020 audit.

Recommendation: The IRS Commissioner should direct the appropriate officials to establish and implement monitoring procedures designed to reasonably assure that the key detailed information for tangible capitalized P&E is properly recorded and updated in the KISAM system.

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

Comments: IRS established the Asset Management Program Monitoring and Review procedure, effective October 1, 2016, for performing quarterly sample reviews of Information Technology (IT) assets in the Knowledge, Incident/Problem, Service Asset Management (KISAM) system. In September 2017, IRS also revised the Internal Revenue Manual to require Facilities Management and Security Services territory managers or section chiefs to review KISAM key data elements for non-IT assets to verify that they are correct and updated. However, during our fiscal year 2018 floor-to-book inventory testing, we identified exceptions where (1) a key detailed information element (e.g., building code) for property and equipment (P&E) assets was not properly recorded in KISAM and (2) P&E assets found on the floor did not have asset records in KISAM. We will conduct inventory testing and follow-up to determine the status of this issue during our audit of IRS's fiscal year 2020 financial statements.

Recommendation: To ensure that risks associated with ALIS are addressed expediently and holistically, the Secretary of Defense should direct the F-35 Program Executive Officer to improve the reliability of its cost estimates, conduct uncertainty and sensitivity analyses consistent with cost-estimating best practices identified in GAO's Cost Estimating and Assessment Guide.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation. According to DOD officials, as of July 2018, this recommendation conflicts with established Office of the Under Secretary of Defense/Cost Estimation and Program Evaluation guidance for cost estimation and uncertainty analysis. Absent a change in policy at that level, the Joint Program Office will continue to follow Office of the Under Secretary of Defense/Cost Estimation and Program Evaluation policy on this issue. We continue to believe that in order for any risks associated with ALIS to be addressed expediently and holistically, uncertainty and sensitivity analysis must be used on the F-35s cost estimates to improve its overall reliability. Thus, this recommendation will remain open.

Recommendation: To ensure that risks associated with ALIS are addressed expediently and holistically, the Secretary of Defense should direct the F-35 Program Executive Officer to improve the reliability of its cost estimates, ensure that future estimates of ALIS costs use historical data as available and reflect significant program changes consistent with cost-estimating best practices identified in GAO's Cost Estimating and Assessment Guide.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation. According to DOD officials, since April 2016, the F-35 program has continued to update the ALIS estimate with the latest available cost data, based on recent contracts. Until more reliable actual costs become available, the program utilizes negotiated contract costs, incorporates program initiatives, and ensures the estimate reflects the latest technical baseline and requirements. Until actual costs associated with ALIS historical data are incorporated in the F-35 cost estimate, we believe that the estimate will not be as reliable as it could be. For this reason, this recommendation will remain open.

Recommendation: Congress should consider whether additional changes to the financial regulatory structure are needed to reduce or better manage fragmentation and overlap in the oversight of financial institutions and activities to improve (1) the efficiency and effectiveness of oversight; (2) the consistency of consumer and investor protections; and (3) the consistency of financial oversight for similar institutions, products, risks, and services. For example, Congress could consider consolidating the number of federal agencies involved in overseeing the safety and soundness of depository institutions, combining the entities involved in overseeing the securities and derivatives markets, transferring the remaining prudential regulators' consumer protection authorities over large depository institutions to the Consumer Financial Protection Bureau, and the optimal role for the federal government in insurance regulation, among other considerations.

Agency: Congress
Status: Open

Comments: At least two bills have been introduced in the 115th Congress that would change the financial regulatory structure, to some degree, to address fragmented and overlapping regulatory authorities among agencies, as GAO suggested in February 2016. The Financial CHOICE Act of 2017 (H.R. 10) was introduced on April 26, 2017, passed the House in June 2017 and the Senate held hearings in July 2017. Among other things, the Financial CHOICE Act of 2017 calls for the federal financial regulatory agencies to implement policies and procedures to minimize the duplication of effort with respect to enforcement actions. For example, it eliminates the authority of the Consumer Financial Protection Bureau to supervise and examine financial institutions and also eliminates the regulatory and enforcement authority of the agency with respect to unfair, deceptive, and abusive acts and practices by depository institutions. Such actions could help reduce fragmentation and overlap in the financial regulatory structure. In addition, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155) was introduced on November 16, 2017 and passed in the Senate in March 2018. The bill, to some extent, may help address fragmentation, overlap, and duplication in the financial regulatory structure. For example, the bill helps to address fragmentation in insurance oversight by finding that the federal agencies and office involved in insurance regulation should achieve consensus with state insurance regulators when they participate in negotiations on insurance issues before any international forum of financial regulators or supervisors, and create an advisory committee to discuss and report on insurance policy issues including international issues. GAO will continue to monitor the reform efforts to determine the extent to which they could help to address fragmentation and overlap between the federal financial regulatory agencies and reduce opportunities for inefficiencies in the regulatory process and inconsistencies in how regulators conduct oversight activities over similar types of institutions, products, and risks.

Recommendation: Congress should consider whether legislative changes are necessary to align FSOC's authorities with its mission to respond to systemic risks. Congress could do so by making changes to FSOC's mission, its authorities, or both, or to the missions and authorities of one or more of the FSOC member agencies to support a stronger link between the responsibility and capacity to respond to systemic risks. In doing so, Congress could solicit information from FSOC on the effective scope of its collective designation authorities, including any gaps.

Agency: Congress
Status: Open

Comments: While some legislative action has been taken that may alter FSOC's authorities, it is not clear that the legislation would address GAO's February 2016 suggestion. The Financial CHOICE Act of 2017 (H.R. 10) was introduced on April 26, 2017, passed the House in June 2017, and the Senate held hearings in July 2017. The bill would change FSOC's authorities by repealing its authorities to designate non-bank financial institutions and financial market utilities (i.e., payment, clearing, and settlement systems) as "systemically important." In addition, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155) was introduced on November 16, 2017 and passed in the Senate in March 2018. The bill may alter some of FSOC's authorities. However, it is unclear if these acts would alter FSOC's mission to better align it with its authorities to respond to systemic risk or addresses a gap in systemic risk mitigation mechanisms. Without legislative changes that would align FSOC's authorities with its mission, FSOC may lack the tools it needs to comprehensively address systemic risks that may emerge and a gap will continue to exist in the mechanisms for mitigating systemic risks. GAO will continue to monitor the reform efforts to determine the extent to which they help to align FSOC's authorities with its mission to respond to systemic risks.

Recommendation: Congress should consider the options for sustaining the Oil Spill Liability Trust Fund as well as the optimal level of funding to be maintained in the Fund, in light of the expiration of the Fund's per-barrel tax funding source in 2017.

Agency: Congress
Status: Open

Comments: In fiscal year 2019, the 116th Congress' House and Senate introduced bills H.R. 3301 and S. 865, respectively, to extend the per barrel tax expiration dates. In addition, the Senate bill proposes a ceiling to cut off the tax if the fund's balance is above a certain amount and to also restart based on meeting certain thresholds. We will continue to monitor legislation and congressional actions.

Recommendation: To strengthen BLM's controls and reasonably assure accountability over mining law program expenditures, both payroll and nonpayroll, the Secretary of the Interior should direct the Director of the Bureau of Land Management to establish procedures for regular and timely communication to all BLM employees on policy and procedural changes affecting the mining law program's expenditure-related processes.

Agency: Department of the Interior
Status: Open

Comments: The Department of Interior's (DOI) Bureau of Land Management (BLM) agreed with our recommendation. In support of closing this recommendation, officials from BLM re-iterated their policy about sending updates regarding guidance changes, which is included in its directives handbook. They also provided us with an example of its timely communication to BLM employees to announce the issuance of its revised Fund Code Handbook. We reviewed the directives handbook and verified that it contains guidance for communicating policy and procedural changes affecting the mining law program's expenditure-related processes. While the guidance in the directives handbook is a good start towards meeting the intent of our recommendation, we communicated to BLM in fiscal year 2019 that the findings in the report were caused in part by inadequate communication processes and the accessibility of the guidance to staff. To address the recommendation, we would like to see evidence that BLM has established procedures to ensure proper communication of changes or policies to the staff using BLM guidance, which includes having written procedures on how BLM publishes updates or communicates policy information, where guidance should be published in BLM's internal page, and the BLM officials who are in charge of that process. In fiscal year 2020, we have sent additional follow-up questions to the agency and are currently waiting for a response. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of IRS should direct the appropriate IRS officials to establish procedures to monitor whether non-IRS contractors with unescorted physical access to IRS facilities are receiving unauthorized access awareness training.

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

Comments: During fiscal year 2018, Facilities Management and Security Services (FMSS) established training requirements for non-IRS contractors with unescorted physical access to IRS facilities and communicated these requirements to its employees. However, FMSS did not establish procedures to monitor whether these non-IRS contractors receive the required unauthorized access awareness training. In addition, during our fiscal year 2019 audit, we found instances in which non-IRS contractors with unescorted physical access to an IRS facility did not complete the required training.

Recommendation: The Commissioner of IRS should direct the appropriate IRS officials to determine why staff did not consistently comply with IRS's existing requirements for the final candling of receipts at service center campuses and lockbox banks, including logging remittances found during final candling on the final candling log at the time of discovery, safeguarding the remittances at the time of discovery, transferring the remittances to the deposit unit promptly, and passing one envelope at a time over the light source, and based on this determination, establish a process to better enforce compliance with these requirements.

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2017, IRS held a meeting with Submission Processing executives, staff, and the Receipt and Control Operation managers from all five service center campuses (SCC), and as a result of the meeting, IRS developed an action plan to resolve the residual risks associated with candling at the SCCs. IRS officials stated that during fiscal year 2020, it will complete the developed action plan.

Recommendation: To better assess and address the full extent of improper payments in the TRICARE program, the Secretary of Defense should direct the Assistant Secretary of Defense (Health Affairs) to implement a more comprehensive TRICARE improper payment measurement methodology that includes medical record reviews, as done in other parts of its existing postpayment claims review programs.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: The Department of Defense (DOD) concurred with our recommendation. As of November 2019, the DOD's Defense Health Agency (DHA) has taken some action to incorporate medical record reviews in its improper payment estimate, as GAO recommended in February 2015. In June 2017, DHA awarded a contract for TRICARE claims review services which, according to DHA officials, will allow the agency to implement a more comprehensive improper payment measurement methodology using retrospective medical records reviews. As of November 2019, the agency reported to Congress that its managed care support contracts now included medical record reviews. It also expected to include payment error results from medical record reviews in its improper payment calculation for fiscal year 2020. DOD also planned to report the effect of medical record reviews on its improper payment rate in a report to Congress in March 2020. Once DHA incorporates medical record reviews in its improper payment rate calculation methodology, GAO will be able to close this recommendation.

Recommendation: To better assess and address the full extent of improper payments in the TRICARE program, and once a more comprehensive improper payment methodology is implemented, the Secretary of Defense should direct the Assistant Secretary of Defense (Health Affairs) to develop more robust corrective action plans that address underlying causes of improper payments, as determined by the medical record reviews.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: The Department of Defense concurred with our recommendation. As of November 2019, the Department of Defense's Defense Health Agency (DHA) has taken steps to implement a more comprehensive TRICARE improper payment measurement methodology. Until the department fully implements the new methodology and identifies the underlying causes of improper payments, the full extent of improper payments in the TRICARE program will likely not be identified and addressed. As of November 2019, the DHA has not yet fully implemented a more comprehensive measurement methodology, and has, therefore, not developed more robust corrective action plans.

Recommendation: Because ROI provides insights on the productivity of a program and is one important factor in making resource allocation decisions, the Commissioner of Internal Revenue should calculate actual ROI for implemented initiatives, compare the actual ROI to projected ROI, and provide the comparison to budget decision makers for initiatives where IRS allocated resources.

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

Comments: No executive action taken as of December 2019. While IRS agreed that having actual ROI data for implemented initiatives would be useful, it did not believe it was feasible to produce such estimates, as GAO recommended in June 2014. GAO maintains that IRS should be able to provide some information on past initiatives, such as whether funds requested were used in the manner originally proposed. As of December 2016, IRS officials reported there is no timeline for full implementation. Comparing projected ROI to actual ROI can help hold managers and IRS accountable for the funding received.

Recommendation: To help address the uncertainty NIH faces, related to the potential impact of increasing indirect costs on its funding of future research, the Director of NIH should assess the impact of growth in indirect costs on its research mission, including, as necessary, planning for how to deal with potential future increases in indirect costs that could limit the amount of funding available for total research, including the direct costs of research projects.

Agency: Department of Health and Human Services: Public Health Service: National Institutes of Health
Status: Open

Comments: As of July 7, 2015, NIH provided some information indicating that it had taken action to address our recommendation by tracking the size of indirect costs as a proportion of NIH's overall budget as part of the agency's annual budget planning process and risk assessment program. However, we determined that the actions did not fully address the recommendation because they focus on the agency's overall budget and do not assess the potential ongoing impact of indirect costs for universities on its mission. As of September 2018, NIH officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: To improve decision makers' abilities to make fully informed decisions concerning whether training requirements can be met with live and simulation-based training and determine optimal mixes of live and simulation-based training, the Secretary of Defense should direct the Secretary of the Army and the Commandant of the Marine Corps to develop outcome-oriented performance metrics that can be used to assess the impact of simulation-based training on improving the performance or proficiency of servicemembers and units.

Agency: Department of Defense
Status: Open

Comments: As of 18 Aug 2014, the Army and Marine Corps actions for this recommendation are currently ongoing and the recommendation status currently remains open. On 14 June 2014, the DOD Inspector General reported in the Defense Audit Management Information System that "the Office of the Deputy Assistant Secretary of Defense(Readiness) developed a decision algorithm to determine which military tasks could be taught virtually and which military tasks should only be taught in classroom or field environments (i.e., live). The algorithm was provided to the Services for peer-review and possible implementation. The Army is reviewing its progressive training models through a process called Training Summit IV (TS IV). These models establish how virtual and constructive based training is integrated with live training to optimize training readiness. The TS IV will include training model review by proponent schools, as well as a cross-section of unit commanders and leaders. This effort will be completed in Fiscal Year (FY) 2014 and presented for validation and G-3/5/7 approval at the Army Training General Officer Steering Committee in November 2014. Also, the Marine Corps initiated a request for an internal servicewide study of existing and potential approaches to this topic (4th Quarter FY 2013). The initial focus is in determining how metrics can be better used to assess the impact of simulation based on meeting Marine Corps Training Standards. Furthermore, a targeted study began in the 1st Quarter FY 2014 and is focused initially on enhancing the methodology for assessing individual based simulators against Training and Readiness (T&R) Standards. In FY 2015, the study results will shape policy on how future T&R manuals will identify the appropriateness of simulators and simulations for training."

Recommendation: To improve decision makers' abilities to make fully informed decisions concerning whether training requirements can be met with live and simulation-based training and determine optimal mixes of live and simulation-based training, the Secretary of Defense should direct the Secretary of the Army and the Commandant of the Marine Corps to develop a methodology--to include identifying the costs that should be included and how these costs should be captured--for comparing the costs associated with the use of live and simulation-based training.

Agency: Department of Defense
Status: Open

Comments: As of 18 Aug 2014, the Army and Marine Corps actions for this recommendation are currently ongoing and the recommendation status currently remains open. On 14 June 2014, the DOD Inspector General reported in the Defense Audit Management Information System that "the Office of the Deputy Assistant Secretary of Defense (Readiness) has coordinated with the Army and Marine Corps to identify standard approaches to capture costs and cost benefit analysis that could be used DoD-wide. The Army has undertaken a "cost of training" analysis that is an on-going action to determine cost of readiness and/or training. One area of concentration is to look at the "Other Burdened Resources Required for Training Readiness." This area is further broken down into two areas: Investment/Modernization and Installation Services. The Investment/Modernization area will look at Non-System Training Aids, Devices, Simulators and Simulations while Installation Services will look at Post Deployment Software Support. In addition, the Army is gathering data to validate an existing model developed by the Simulations to Mission Command Interoperability Director (Program Executive Office for Simulation, Training, and Instrumentation) for the Value of Simulation Study consisting of five phases: Phase one focused on development of a working methodology to assess both quantitative and qualitative value of simulations used to support collective training (completed). Phase two is currently gathering data for model validation. Phase three will be an expansion to other simulation capabilities. Phase four is data gathering and validation. Phase five is expanded testing/methodology use case study/validation for return on investment use. The Marine Corps established a study, described in response to Recommendation 1, which will evaluate and propose the initial cost factors not currently captured during Programming yet would be relevant in determining the appropriate mix of live and simulated training. The initial results are expected in FY 2015."

Recommendation: To increase beneficiaries' awareness of providers' financial interest in a particular treatment, Congress should consider directing the Secretary of Health and Human Services to require providers who self-refer IMRT services to disclose to their patients that they have a financial interest in the service.

Agency: Congress
Status: Open

Comments: In August 2013, to increase beneficiaries' awareness of providers' financial interest in a particular treatment, we suggested that Congress should consider directing the Secretary of Health and Human Services to require providers who self-refer IMRT services to disclose to their patients that they have a financial interest in the service. As of June 2020, Congress has not implemented this suggestion.

Recommendation: The Administrator of CMS should insert a self-referral flag on its Medicare Part B claims form, require providers to indicate whether the IMRT service for which a provider bills Medicare is self-referred, and monitor the effects that self-referral has on costs and beneficiary treatment selection.

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: In August 2013, we recommended that the Administrator of the Centers for Medicare & Medicaid Services (CMS) insert a self-referral flag on its Medicare Part B claims form, require providers to indicate whether the intensity-modulated radiation therapy (IMRT) service for which a provider bills Medicare is self-referred, and monitor the effects that self-referral has on costs and beneficiary treatment selection. The Department of Health and Human Services (HHS) did not concur with this recommendation, noting that CMS does not believe that this recommendation will address overutilization that occurs as a result of self-referral, would be complex to administer, and may have unintended consequences. We continue to believe that such a flag on Part B claims would likely be the easiest and most cost-effective way for CMS to identify self-referred IMRT services and monitor the effects of self-referral. As of June 2020, CMS has not provided any additional information about actions it has taken to address this recommendation.

Recommendation: To improve the reliability of the information presented in the CFS budget statements, the Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB's Office of Federal Financial Management, to establish and implement effective procedures for reporting amounts in the CFS budget statements that are fully consistent with the underlying information in significant federal entities' audited financial statements and other financial data.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), this recommendation remained open. Treasury continued to develop its budget deficit/surplus and cash reconciliation procedures. Specifically, Treasury performed a preliminary analysis on several federal entities' implementation of the new Statement of Federal Financial Accounting Standards No. 53, Budget and Accrual Reconciliation (BAR), and noted inconsistencies in the way each entity populated line items in the BAR. Treasury and OMB provided additional guidance for the BAR in OMB Circular No. A-136 and on the Treasury U.S. Standard General Ledger website, including a BAR crosswalk template. However, additional work is needed to reconcile line items to audited federal entity financial statements. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

Recommendation: To improve the reliability of the information presented in the CFS budget statements, the Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB's Office of Federal Financial Management, to establish and implement effective procedures for identifying and reporting all items needed to prepare the CFS budget statements.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), this recommendation remained open. Treasury continued to make improvements in fiscal year 2019 by implementing procedures, publishing guidance, and developing new transaction codes to improve the accounting for and reporting of General Fund transactions and balances that Treasury uses to compute the budget deficit reported in the consolidated financial statements. However, additional work is needed in determining the appropriate presentation for the reconciling items, which could affect the line items included. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

Recommendation: To help improve its ability to oversee M&O contractor costs, including indirect costs, for its laboratories and make more effective use of DOE and contractor resources, the Secretary of Energy should take--or, as appropriate, direct the Administrator of NNSA to incorporate more specific benchmarking requirements into future laboratory contracts--similar to the benchmarking requirements used by DOE to assess and manage pension and post-retirement benefit costs--including which costs should be benchmarked, how frequently benchmarking should occur, and what process should be used to ensure corrective actions are taken, as needed.

Agency: Department of Energy
Status: Open

Comments: In April 2017, the Director of NNSA Office of Policy issued guidance to NNSA Laboratory Field Office Managers to update contracts to include a new clause requiring laboratory contractors to submit a strategic plan every year in accordance with guidance. Part of the annual plan requires contractors to discuss the costs of doing business and cost-increase factors at the sites, including overhead dollars. The annual strategic plan is due to the NNSA Office of Policy by August 15 each year. The annual strategic plans included information on indirect costs and cost drivers, but did not include benchmarking. We again requested information on the benchmarking requirements, if any, in July 2020.

Recommendation: The Acting Commissioner of Internal Revenue should direct the appropriate IRS officials to perform a risk assessment to determine the appropriate level of Integrated Data Retrieval System (IDRS) access that should be granted to employee groups that handle hard-copy taxpayer receipts and related sensitive taxpayer information as part of their job responsibilities.

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

Comments: IRS's actions to address this recommendation are ongoing. In October 2019, the functions within the Small Business/Self-Employed organization completed risk assessments to determine the appropriate level of Integrated Data Retrieval System (IDRS) access that should be granted to the employees who handle hard-copy taxpayer receipts and related sensitive taxpayer information as part of their job responsibilities. In addition, IRS officials stated that during fiscal year 2020, the Taxpayer Advocate Service organization, in coordination with the Information Technology organization, as necessary, will complete a risk assessment of all employee groups that handle hard-copy taxpayer receipts and related sensitive taxpayer information to determine the most appropriate level of IDRS access.

Recommendation: The Acting Commissioner of Internal Revenue should direct the appropriate IRS officials to, based on the results of the risk assessment, update the Internal Revenue Manual (IRM) accordingly to specify the appropriate level of IDRS access that should be allowed for (1) remittance perfection technicians and (2) all other employee groups with IDRS access that handle hard-copy taxpayer receipts and related sensitive information as part of their job responsibilities.

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that by October 2020, the Small Business/Self-Employed, Taxpayer Advocate Service, and Tax Exempt & Government Entities organizations will work with the Information Technology organization, as necessary, to ensure that the applicable Internal Revenue Manual section(s) are revised for any policy changes on (1) risk mitigation, including specifying the appropriate level of Integrated Data Retrieval System access that should be allowed and (2) risk acceptance for affected employee groups, as needed.

Recommendation: The Acting Commissioner of Internal Revenue should direct the appropriate IRS officials to establish procedures to implement the updated IRM, including required steps to follow to prevent (1) remittance perfection technicians and (2) all other employee groups that handle hard-copy taxpayer receipts and related sensitive information as part of their job responsibilities from gaining access to command codes not required as part of their designated job duties.

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that by October 2020, the Small Business/Self-Employed, Taxpayer Advocate Service, and Tax Exempt & Government Entities organizations will work with the Information Technology organization, as necessary, to establish procedures to prevent affected employees from gaining access to command codes not required as part of their designated job duties, as needed.

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to estimating improper payments, to establish and implement key quality assurance procedures, such as reconciliations, to ensure the completeness and accuracy of the sampled populations.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: The Department of Defense (DOD), in concurring with this recommendation, stated that DOD will work with the Defense Finance and Accounting Service (DFAS) to implement key quality assurance procedures, such as reconciliations, to ensure the completeness and accuracy of sampled populations. In August 2017, DOD officials stated that its Office of the Under Secretary of Defense (Comptroller) will continue its work with DFAS to annually reconcile gross outlays (as stated on its Statement of Budgetary Resources) with outlays as reported in its Agency Financial Report. These reconciliations are currently done only on a summary level. In the future, DOD's validation of its universe of transactions combined with planned reconciliations with the Defense Departmental Reporting System trial balance and transaction data from DOD's entitlement systems will provide more complete reconciliations. As of December 2019, DOD officials stated that DOD needs to resolve its material weakness relating to the universe of transactions. This material weakness is preventing the department from performing the reconciliations necessary to ensure that the populations, from which the samples are drawn to estimate improper payments, are complete and accurate. As of May 2020, DOD had developed a spreadsheet including over 80 financial management and disbursing systems. The Office of the Under Secretary of Defense, OUSD(C), is planning to review and analyze these systems to (1) determine the types of payments and lists of systems used to process the types of payments; (2) confirm if reconciliations are done to verify the total outlays; and (3) determine the testing status of the universe of payments. As of September 30, 2020, this recommendation remains open.

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to implementing recovery audits, to monitor the implementation of the revised FMR chapter on recovery audits to ensure that the components either develop recovery audits or demonstrate that it is not cost effective to do so.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: Department of Defense (DOD) officials, in concurring with this recommendation, stated that DOD would work with the applicable components to monitor the implementation of the revised Financial Management Regulation (FMR) chapter on recovery audits (subsequently renamed as payment recapture audits). According to DOD officials, this action would help to ensure that recovery audits are developed, or will demonstrate that it is not cost-effective to do these audits. In July 2015, DOD was working to update the FMR chapter on recovery audits to reflect revised Office of Management and Budget (OMB) guidance issued in October 2014. DOD issued its revised FMR chapter in November 2015. This chapter requires components to develop cost-effective payment recapture audits or to submit a quantitative justification to the Office of the Under Secretary (Comptroller) for approval. However, we consider this recommendation to be open because DOD did not provide documentation demonstrating that the Office of the Under Secretary of Defense (Comptroller) is monitoring component implementation of recovery auditing. Further, as of April 2017, DOD's efforts to develop cost-estimates for recovery audits were still under way. As of October 2018, this recommendation remains open. As of December 2019, DOD stated that in FY 2020, the Office of the Under Secretary (Comptroller) will coordinate with the DOD improper payment reporting components to analyze whether it would be cost effective to implement payment recapture audit programs for their payments. In a March 20, 2020 memorandum, the Deputy CFO asked DOD components, programs, or activities with annual payments exceeding $1 million to submit a payment recapture plan by June 30, 2020. If a component determines that payment recapture audits are not cost-effective, then the plan must provide the specific analysis and documentation used to reach that conclusion. When completed, the results of the evaluation will serve the Department's final position on payment recapture audit programs. As of September 30, 2020, this recommendation remains open as this evaluation was not yet complete.

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to implementing recovery audits, to develop and submit to OMB for approval a payment recapture audit plan that fully complies with OMB guidance.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: Department of Defense (DOD) officials, in concurring with this recommendation, stated that DOD would develop and submit to the Office of Management and Budget (OMB) a payment recapture plan that fully complies with OMB guidance and is informed by a cost-effectiveness analysis. In July 2015, DOD's Office of the Under Secretary of Defense (Comptroller) efforts to develop a payment recapture audit plan to ensure cost-effectiveness were ongoing and these efforts must be completed before a plan can be submitted to the OMB. In June 2016, DOD officials stated that the Comptroller's efforts to develop a payment recapture audit plan to ensure cost-effectiveness were ongoing. As of August 28, 2017, DOD officials stated that the Office of the Under Secretary of Defense (Comptroller) will determine if a payment recapture audit plan was developed and submitted to OMB for approval in the previous fiscal years. If so, the Office of the Under Secretary of Defense (Comptroller) will determine its relevance and significance (i.e. cost effectiveness)to the improper payments program. If the payment recapture audit plan is considered to be applicable, the Office of the Under Secretary of Defense (Comptroller) will update the previous plan to comply with current OMB guidance. As of October 2018, this recommendation remains open. As of December 2019, DOD stated that in FY 2020, the Office of the Under Secretary (Comptroller) will coordinate with the DOD improper payment reporting components to analyze whether it would be cost effective to implement payment recapture audit programs for their payments. In a March 20, 2020 memorandum, the Deputy CFO asked DOD components, programs, or activities with annual payments exceeding $1 million to submit a payment recapture plan by June 30, 2020. If a component determines that payment recapture audits are not cost-effective, then the plan must provide the specific analysis and documentation used to reach that conclusion. When completed, the results of the evaluation will serve the Department's final position on payment recapture audit programs. As of September 30, 2020, this recommendation remains open as this evaluation was not yet complete..

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense (Comptroller), with regard to reporting, to design and implement procedures to ensure that the department's annual improper payment and recovery audit reporting is complete, accurate, and in compliance with IPERA and OMB guidance.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: Department of Defense (DOD) officials, in concurring with this recommendation, stated that DOD would design and implement procedures to further ensure that its annual improper payment and recovery audit reporting is complete, accurate, and in compliance with the Improper Payments Elimination and Recovery Act (IPERA) requirements and Office of Management and Budget (OMB) guidance. In June 2015, DOD revised its FMR chapter on improper payments to require components to provide information needed to report on improper payment and recovery audit activities in its annual financial report (AFR) in accordance with IPERA requirements and OMB guidance. DOD's fiscal year 2015 AFR reflected its implementation of the revised FMR. We found that DOD's improper payment reporting in its fiscal year 2015 AFR had improved. However, we were not provided with evidence that Office of the Under Secretary of Defense (Comptroller) is performing oversight and monitoring activities to ensure the accuracy and completeness of the improper payment and recovery audit data submitted by DOD components for inclusion in the AFR. DOD is continuing to work on procedures for ensuring that its reporting on improper payment and recovery audits is accurate, complete, and in compliance with IPERA and OMB guidance. The Office of the Under Secretary of Defense (Comptroller) has developed and implemented a Payment Integrity Checklist to ensure that the department's annual improper payment and recovery audit reporting was complete, accurate, and in compliance with IPERA and OMB guidance. However, the DOD Inspector General in its May 2020 report, stated that while DOD published improper payment estimates for all eight programs for fiscal year 2019, it did not publish reliable estimates for five of the eight programs: Military Health Benefits, Civilian Pay, Military Retirement, DOD Travel Pay, and Commercial Pay. Moreover, DOD did not use accurate populations in calculating the improper payment estimates for the Military Retirement, Commercial Pay, and DOD Travel Pay programs. Based on these issues affecting improper payment reporting, we consider this recommendation to be open as of September 30, 2020.

Recommendation: In light of declining discretionary budgets, to reduce or eliminate the reliance of the AQI program on taxpayer funding, Congress should consider allowing USDA to set AQI fees to recover the aggregate estimated costs of AQI services--thereby allowing the Secretary of Agriculture to set fee rates to recover the full costs of the AQI program.

Agency: Congress
Status: Open

Comments: As of January 2020, Congress had not passed legislation to give the Secretary of Agriculture authority to set fee rates to fully recover the aggregate costs of agricultural quarantine inspection (AQI) services, as GAO suggested in March 2013. The current AQI fee authority does not permit the U.S. Department of Agriculture to set AQI fees to recover the aggregate estimated costs of AQI services. Authorizing the Secretary of Agriculture to set fee rates to recover the full costs of the AQI program would save the federal government money by reducing the program's reliance on U.S. Customs and Border Protection's annual Salaries and Expenses appropriation.

Recommendation: Congress should consider amending USDA's authorization to assess AQI fees on bus companies, private vessels, and private aircraft and include in those fees the costs of AQI services for the passengers on those buses, private vessels, and private aircraft.

Agency: Congress
Status: Open

Comments: As of January 2020, Congress had not passed legislation to give the Secretary of Agriculture authority to assess agricultural quarantine inspection (AQI) fees on private vessels, private aircraft, and commercial buses and include in those fees the costs of AQI services for the passengers on those vehicles. The current AQI fee authority does not permit the U.S. Department of Agriculture to assess AQI fees on private vessels, private aircraft and commercial buses and to recover, through those fees, the costs of AQI services for the passengers on those vehicles.

Recommendation: To better balance the benefits of expedited rulemaking procedures with the benefits of public comments that are typically part of regular notice-and-comment rulemakings, and improve the quality and transparency of rulemaking records, the Director of OMB, in consultation with the Chairman of Administrative Conference of the United States (ACUS), should issue guidance to encourage agencies to respond to comments on final major rules, for which the agency has discretion, that are issued without a prior notice of proposed rulemaking.

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

Comments: In a status update from OMB received on March 6, 2020, OMB stated that it agrees that agencies should respond to comments on final major rules, for which the agency has discretion, that are issued without a prior notice of proposed rulemaking. OMB says it will continue to prioritize this issue during review of regulations under EO 12866, and that it is currently considering whether additional guidance is appropriate and will consult with the staff of the Administrative Conference of the United States on this issue.

Recommendation: The Acting Commissioner of Internal Revenue should take the following action outline a strategy that defines appropriate levels of telephone and correspondence service and wait time and lists specific steps to manage service based on an assessment of time frames, demand, capabilities, and resources.

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

Comments: IRS neither agreed nor disagreed with GAO's recommendation from December 2012, but has made progress in developing a customer service strategy that defines appropriate levels of telephone service; however, as of February 2020, IRS had not finalized its strategy nor determined the appropriate levels of service for correspondence and wait time. In January 2017, IRS shared results of a benchmarking study that compared its telephone service, measures, and goals to comparable agencies and companies. The team that conducted the study recommended options for additional measures to indicate the level of access taxpayers have to service across service channels. In September 2019, IRS provided GAO its revised customer service strategy; however, it did not include correspondence service. In July 2019, the Taxpayer First Act (Public Law 116-25) was enacted which requires IRS to develop a comprehensive customer service strategy. As of February 2020, IRS had established an internal office to implement this requirement. Completion of a comprehensive customer service strategy that defines appropriate levels of service and wait time as well as specific steps to manage services based on an assessment of time frames, demand, capabilities, and resource requirements would enable IRS to make a more informed request to Congress about resources needed to deliver specific levels of service. Further, finalizing a long-term comprehensive strategy will help ensure IRS is maximizing the benefit to taxpayers and possibly reduce costs in other areas.

Recommendation: To ensure that up-to-date data are available on the road damages imposed by all vehicles types compared with the revenues each contributes to the Highway Trust Fund, the Secretary of Transportation should direct the FHWA Administrator to revise and publish the agency's Highway Cost Allocation Study and update it periodically as warranted.

Agency: Department of Transportation
Status: Open

Comments: As of April 2020, FHWA stated it does not plan to revise and publish the agency's Highway Cost Allocation Study because of the cost of doing so and the uncertainty about whether and how it would be used. GAO continues to believe that up to date information on the cost of road damage imposed by all vehicle types compared with the revenues contributed by those vehicles to the Highway Trust Fund is needed to help determine whether user fees are sufficient to cover damage costs. Moreover, Congress and the administration need to agree on a long-term sustainable plan for balancing spending from and revenues to the Highway Trust Fund and, for this reason, funding surface transportation is on GAO's High Risk List. GAO will continue to monitor any efforts by DOT and FHWA to respond to our recommendation.

Recommendation: To improve transparency of and accountability for Medicaid non-DSH supplemental payments, Congress should consider requiring the Administrator of CMS to (1) improve state reporting of non-DSH supplemental payments, including requiring annual reporting of payments made to individual facilities and other information that the agency determines is necessary to oversee non-DSH supplemental payments; (2) clarify permissible methods for calculating non-DSH supplemental payments; and (3) require states to submit an annual independent certified audit verifying state compliance with permissible methods for calculating non-DSH supplemental payments.

Agency: Congress
Status: Open

Comments: No legislation enacted as of February 2020. However, CMS has taken some administrative actions, which are underway, to improve its oversight of non-DSH supplemental payments. In November 2019, CMS issued a proposed rule that the agency said would promote state accountability, improve federal oversight, and strengthen fiscal integrity of the Medicaid program. Among other things, the proposed rule would require states to report on non-DSH supplemental payments on a facility-specific basis, as well as specify data sources, data standards, and acceptable methods for demonstrating compliance for non-DSH supplemental payment calculations. GAO plans to continue to monitor congressional action and the status of the proposed rule, as well as review a final rule, if one is issued, to determine the extent to which they improve state reporting of non-DSH supplemental payments, clarify permissible methods for calculating non-DSH supplemental payments, and require audits to verify that states use permissible methods to calculate non-DSH supplemental payments.

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 did not explain how to plan, execute, and analyze the results of an inventory count. As a result, 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 follow-up, the Commission informed us that they plan to implement procedures to address this recommendation but have not dedicated resources to it yet. We will continue to follow-up on this recommendation.

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, 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 follow-up, the Commission informed us that they plan to implement procedures to address this recommendation but have not dedicated resources to it yet. We will continue to follow-up on this recommendation.

Recommendation: PPACA contained several important program integrity provisions for the 340B program, and additional steps can also ensure appropriate use of the program. Therefore, the Secretary of HHS should instruct the administrator of HRSA to finalize new, more specific guidance on the definition of a 340B patient.

Agency: Department of Health and Human Services
Status: Open

Comments: In January 2017, HRSA withdrew proposed guidance that included further specificity on the definition of 340B patient in response to the new administration's January 20 memorandum directing agencies to withdraw regulations that were pending before the Office of Management and Budget but had not yet been published in the Federal Register. In March 2018, HRSA told GAO that it continues to assess next steps with the Administration on the proposed omnibus guidance, which included the patient definition. In June 2019, HRSA reported that it is still working with the Department to determine next steps for this recommendation. In July 2020, HRSA reported that it conducted an evaluation of its audit process and other program integrity efforts and determined that guidance does not provide the agency with appropriate enforcement capability. Therefore, HRSA is not pursing new guidance under the Program at this time. The FY 2021 President's Budget includes a proposal to provide HRSA comprehensive regulatory authority.

Recommendation: PPACA contained several important program integrity provisions for the 340B program, and additional steps can also ensure appropriate use of the program. Therefore, the Secretary of HHS should instruct the administrator of HRSA to issue guidance to further specify the criteria that hospitals that are not publicly owned or operated must meet to be eligible for the 340B program.

Agency: Department of Health and Human Services
Status: Open

Comments: In January 2017, HRSA withdrew proposed guidance that included additional specificity regarding hospital eligibility in response to the new administration's January 20 memorandum directing agencies to withdraw regulations that were pending before the Office of Management and Budget but had not yet been published in the Federal Register. In March 2018, HRSA reported that it believes it is unable to implement this recommendation without additional legislative authority because the statute does not speak to the issue raised in the recommendation. HRSA also noted that the FY19 President's Budget includes a proposal to provide HRSA comprehensive regulatory authority, and that if this proposal is enacted, it could regulate on hospital eligibility. In June 2019, HRSA reported that it is still unable to implement this recommendation without additional legislative authority, though the President's FY 2020 Budget includes a proposal to provide HRSA with such authority. In July 2020, HRSA reported that it conducted an evaluation of its audit process and other program integrity efforts and determined that guidance does not provide the agency with appropriate enforcement capability. Therefore, HRSA is not pursing new guidance under the Program at this time. The FY 2021 President's Budget includes a proposal to provide HRSA comprehensive regulatory authority.

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.

Recommendation: Congress may wish to consider instituting a penalty on non-material advisor promoters for failing to provide investor lists to IRS within a specified time period when requested, comparable to the 20-business-day requirement for material advisors.

Agency: Congress
Status: Open

Comments: As of February 2020, we have not identified legislative action in the 114th or 115th Congress or any enacted legislation since 2011 amending section 6111 (disclosure of reportable transactions including the definition of a material advisor), section 6112 (requirement to keep lists of investors) or section 6708 (imposing the penalty for failure to maintain and provide lists to IRS).

Recommendation: To improve reporting on the results of examinations on ATAT issues, the Commissioner of Internal Revenue should separately track the tax amounts recommended, assessed, and collected between ATAT issues and non-ATAT issues.

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

Comments: As of December 2019, IRS did not plan on taking any further actions to track examination results for ATAT versus non-ATAT issues, as GAO recommended in May 2011. In July 2012, IRS told GAO that although it agreed with GAO's May 2011 recommendation, resource and capability constraints preclude it from capturing information in this way. GAO maintains that tracking examination results for ATAT versus non-ATAT issues would provide IRS management with the data needed to make informed judgments about program effectiveness and resource allocations. IRS has taken steps to check whether taxpayers file all required ATAT-related disclosure obligations. In February 2013, IRS implemented a new indicator and matching process to regularly review whether taxpayers are meeting their ATAT-related filing obligations. Additionally, IRS developed a procedure to evaluate the completeness of ATAT-related disclosure forms and follow up on incomplete forms as necessary and updated the Internal Revenue Manual to reflect these changes. Developing and implementing these new processes and procedures will provide IRS with additional information for determining whether the disclosures are made as required and are complete.

Recommendation: To strengthen accountability and transparency in FHA's management of the Fund, Congress may wish to consider clarifying (1) the definition of the Fund's capital ratio--specifically, whether the denominator of the ratio was intended to be the amortized insurance-in-force; (2) the definition of the phrase "established target subsidy rate" used in HERA; and (3) the nature and extent of information that FHA should be reporting on subsidy rates pursuant to HERA, recognizing that subsidy rates are generally only reestimated once a year under current budget processes.

Agency: Congress
Status: Open

Comments: As of October 2019, Congress had not acted on this matter for consideration.

Recommendation: To help ensure that CFTC and SEC are strategically positioned to implement the joint report's recommendations and address remaining harmonization opportunities, as CFTC and SEC continue to develop the charter for the Joint Advisory Committee, the Chairmen of CFTC and SEC should take steps to establish, with associated time frames, clearer goals for future harmonization efforts and requirements for reporting and evaluating progress toward these goals. Specifically, the agencies could benefit from formalizing a plan to assess implementation of the joint report's recommendations and harmonization opportunities that may not have been fully addressed by the joint report, such as differences in market structure and investor definitions. Such a plan could include goals for future harmonization efforts, such as time frames for implementing the recommendations; assessment of whether remaining differences in statutes and regulations result in inconsistent regulation of similar products and entities that could lead to opportunities for regulatory arbitrage; and periodic reports to Congress on their progress, including the implementation and impact of the recommendations.

Agency: Commodity Futures Trading Commission
Status: Open

Comments: In July 2018, the CFTC and SEC Chairmen signed an updated version of a Memorandum of Understanding (MOU) originally signed in 2008. The new MOU created an updated framework for information sharing to make it easier for the two agencies to share information. A CFTC official noted that the MOU underscored two agencies' commitment to addressing harmonization efforts. In addition, CFTC officials identified examples of harmonization areas where CFTC and SEC have made some additional progress. This recommendation remains open until CFTC identifies steps taken to create a plan for assessing progress on working with SEC on remaining harmonization opportunities.

Recommendation: Given the increasing extent of business travel to the U.S. and the eroding effect of inflation, Congress may wish to consider raising the amount of U.S. income paid by a foreign employer that is exempt from tax for nonresidents who meet the other conditions of the exemption.

Agency: Congress
Status: Open

Comments: As of August 2019, Congress has not raised the amount of U.S. income paid by a foreign employer that is exempt from tax for nonresidents who meet the other conditions of the exemption.

Recommendation: Given the difficulty of enforcing the requirement for aliens to obtain certificates of compliance--sailing permits--before departing the country and the existence of withholding requirements and tax treaties, Congress may wish to consider eliminating the sailing permit requirement.

Agency: Congress
Status: Open

Comments: As of August 2019, Congress has not eliminated the sailing permit requirement.

Recommendation: To improve compliance with shareholder basis rules, Congress may wish to require S corporations to calculate and report shareholder's stock and debt basis as completely as possible. S corporations would report the calculation on the Schedule K-1 and send it to shareholders as well as IRS. If Congress judges that stock purchase price information that is currently only available to shareholders should not be transmitted to the S corporation due to privacy concerns, an alternative is to require that S corporations report less complete basis calculations using information already available to the S corporation.

Agency: Congress
Status: Open

Comments: As of January 2020, Congress had not enacted legislation to require S corporations--a federal business type that provides certain tax benefits like passing income and losses to shareholders' individual returns-- to calculate and report shareholder's stock and debt basis as completely as possible and report the calculation to shareholders and IRS, as GAO suggested in December 2009.

Recommendation: In order to better assess whether changes are needed in the way IRS administers activities not engaged in for profit provisions, the Commissioner of Internal Revenue should take steps to estimate the extent of activities not engaged in for profit noncompliance from its ongoing research programs.

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

Comments: IRS agreed to research sole proprietor noncompliance, as GAO recommended in September 2009. It is focusing on those who improperly claim business losses (i.e., not profits). IRS's Office of Research, Analysis and Statistics is using the reporting compliance study of Form 1040 filers to gather the data on such noncompliant business losses. This research covered sampled tax returns filed for tax years 2009, 2010, and 2011 and used audits of the sampled tax returns that are filed for each tax year. In November 2016, IRS research officials provided the initial rough estimates of the percentage of disallowed losses and associated dollar amounts for all 3 tax years but as of December 2019, they had not yet indicated how these estimates helped IRS to understand the nature of the tax noncompliance. The officials cautioned that their ability to develop the estimates depends on the number of observations that can be applied from each tax year. This research, when completed, could help IRS to identify noncompliant sole proprietor issues and take action to reduce losses.

Recommendation: The Secretary of the Treasury should ensure that the tax gap strategy includes (1) a segment on improving sole proprietor compliance that is coordinated with broader tax gap reduction efforts and (2) specific proposals, such as the options we identified, that constitute an integrated package.

Agency: Department of the Treasury
Status: Open

Comments: As of January 2020, Treasury has taken no action to address this recommendation and has not provided GAO with plans to do so. Treasury's tax gap strategy does not cover sole proprietor compliance in detail while coordinating it with broader tax gap reduction efforts as GAO recommended in July 2007. In March 2016, Treasury officials reported to GAO that they have implemented or proposed several actions to address the tax gap among sole proprietors, such as requiring reporting on payment card payments and improved audit selection procedures for sole proprietors. However, GAO's July 2007 report noted there are many trade offs involved in various options for improving sole proprietor compliance. GAO recommended that Treasury's strategy for reducing the tax gap include a segment on sole proprietor compliance that is coordinated with broader tax gap reduction efforts.

Recommendation: To enhance the transparency of CMS oversight and clarify and communicate the types of allowable state financing arrangements, the Administrator of CMS should provide each state CMS reviews under its initiative with specific and written explanations regarding agency determinations on the allowability of various arrangements for financing the nonfederal share of Medicaid payments and make these determinations available to all states and interested parties.

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
Status: Open

Comments: CMS has taken steps to provide states with specific and written explanations regarding agency determinations on whether various arrangements for financing the nonfederal share of Medicaid payments are allowable and making those determinations available to states and interested parties. In November 2019, CMS issued a proposed rule that the agency said would promote state accountability, improve federal oversight, and strengthen fiscal integrity of the Medicaid program. The proposed rule would establish new policies and codify existing policies related to the sources of funds that states use to finance the nonfederal share of Medicaid payments. For example, the rule is intended to provide CMS and states with better information and guidance to identify existing and emerging state financing issues, provide more clarity on allowable financing arrangements and promote state accountability. GAO will continue to monitor the status of the proposed rule, as well as review a final rule, if one is issued, to determine the extent to which it addresses the recommendation.

Recommendation: The Secretary of the Interior should direct the Deputy Assistant Secretary for Insular Affairs to develop a framework for OIA employees to use in conducting site visits to help ensure objectives are achieved, to assure that relevant information is shared with responsible officials, and to allow more efficient and effective monitoring of issues.

Agency: Department of the Interior
Status: Open

Comments: On May 24, 2017, the Department of Interior (DOI) sent out an email to its staff showing the dissemination of the new format required for completing trip reports by the staff of the Office of Insular Affairs (OIA). The new format requires staff to include travel justification (i.e., purpose/objective, location, and travel period) and trip report (i.e., meetings, site visits, results, and next steps, as applicable.) The intent of the recommendation is for DOI to have a framework that includes (1) status of required single audit reports; (2) the progress of actions to resolve reported internal control weaknesses; and (3) current needs for technical assistance, capacity building, and staff level expertise. Further, the intent of GAO's recommendation is that this information be integrated into a comprehensive monitoring process. We did not see these elements included in DOI's new format. At present, the agency has been unable to provide additional information that supports the development of a framework for conducting sites visits that incorporates procedures about how information will be shared and monitored. In August 2020, the agency informed us that it has taken additional corrective actions some time ago and is in the process of trying to locate the supporting documentation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: To help further the progress toward meeting the goals of IPIA and determining states' role in assisting federal agencies to report a national improper payment estimate on federal programs, the Director, Office of Management and Budget, should expand IPIA guidance to provide criteria that federal agencies should consider when developing a plan or methodology for estimating a national improper payment estimate for state-administered programs, such as criteria that address the nature and extent of data and documentation needed from the states to calculate a national improper payment estimate.

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

Comments: The Office of Management and Budget (OMB) concurred with this recommendation. Since the issuance of the GAO report, OMB has made several revisions to its OMB Circular No. A-123, Appendix C "Requirements for Effective Measurement and Remediation of Improper Payments." The latest revision is dated June 26, 2018. The intent of OMB Circular No. A-123, Appendix C, is to ensure that federal agencies focus on prevention and have the proper incentives to improve their improper payment rates. In August 2020, OMB provided us its improper payment guidance on sampling and estimation in place at the time of the GAO audit. Based on this documentation, we sent a follow-up request to OMB for additional information. We are currently waiting to hear back from OMB so we can continue with our review. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB's Office of Federal Financial Management, to establish written policies and procedures to help ensure that major treaty and other international agreement information is properly identified and reported in the CFS. Specifically, these policies and procedures should require that agencies develop a detailed schedule of all major treaties and other international agreements that obligate the U.S. government to provide cash, goods, or services, or that create other financial arrangements that are contingent on the occurrence or nonoccurrence of future events (a starting point for compiling these data could be the State Department's Treaties in Force).

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), this recommendation remained open. Treasury developed guidance and formed a working group along with State Department and other federal entity representatives in fiscal year 2019. The working group was established with the Chief Financial Officer Council (CFOC) for the purpose of developing a cost-effective solution to improve the accountability and ensure completeness in the reporting of treaties and other international agreements to address GAO's five long-standing open recommendations. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB's Office of Federal Financial Management, to establish written policies and procedures to help ensure that major treaty and other international agreement information is properly identified and reported in the CFS. Specifically, these policies and procedures should require that agencies classify all such scheduled major treaties and other international agreements as commitments or contingencies.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), this recommendation remained open. Treasury developed guidance and formed a working group along with State Department and other federal entity representatives in fiscal year 2019. The working group was established with the Chief Financial Officer Council (CFOC) for the purpose of developing a cost-effective solution to improve the accountability and ensure completeness in the reporting of treaties and other international agreements to address GAO's five long-standing open recommendations. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB's Office of Federal Financial Management, to establish written policies and procedures to help ensure that major treaty and other international agreement information is properly identified and reported in the CFS. Specifically, these policies and procedures should require that agencies disclose in the notes to the CFS amounts for major treaties and other international agreements that have a reasonably possible chance of resulting in a loss or claim as a contingency.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), this recommendation remained open. Treasury developed guidance and formed a working group along with State Department and other federal entity representatives in fiscal year 2019. The working group was established with the Chief Financial Officer Council (CFOC) for the purpose of developing a cost-effective solution to improve the accountability and ensure completeness in the reporting of treaties and other international agreements to address GAO's five long-standing open recommendations. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB's Office of Federal Financial Management, to establish written policies and procedures to help ensure that major treaty and other international agreement information is properly identified and reported in the CFS. Specifically, these policies and procedures should require that agencies disclose in the notes to the CFS amounts for major treaties and other international agreements that are classified as commitments and that may require measurable future financial obligations.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), this recommendation remained open. Treasury developed guidance and formed a working group along with State Department and other federal entity representatives in fiscal year 2019. The working group was established with the Chief Financial Officer Council (CFOC) for the purpose of developing a cost-effective solution to improve the accountability and ensure completeness in the reporting of treaties and other international agreements to address GAO's five long-standing open recommendations. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB's Office of Federal Financial Management, to establish written policies and procedures to help ensure that major treaty and other international agreement information is properly identified and reported in the CFS. Specifically, these policies and procedures should require that agencies take steps to prevent major treaties and other international agreements that are classified as remote from being recorded or disclosed as probable or reasonably possible in the CFS.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), this recommendation remained open. Treasury developed guidance and formed a working group along with State Department and other federal entity representatives in fiscal year 2019. The working group was established with the Chief Financial Officer Council (CFOC) for the purpose of developing a cost-effective solution to improve the accountability and ensure completeness in the reporting of treaties and other international agreements to address GAO's five long-standing open recommendations. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

Recommendation: The Senior Civilian Official for the Office of the Assistant Secretary of the Navy should develop a review process so that data call information on sponsor owned material is correctly reported.

Agency: Department of Defense: Department of the Navy: Office of the Assistant Secretary of the Navy (Financial Management): Senior Civilian Official
Status: Open

Comments: According to Navy officials, sponsor owned material is a subset of Operating Materials and Supplies (OM&S) contained within the OM&S-Remainder (OM&S-R) account. The Navy's auditors have reported a material weakness related to the OM&S-R account since fiscal year 2005. Recently, the auditors reported that the Navy did not have adequate policies, procedures, internal controls, and supporting documentation to support the balance and reporting of the OM&S-R account. The Navy currently has efforts underway to address this material weakness with a target completion date of early fiscal year 2021.

Recommendation: The Senior Civilian Official for the Office of the Assistant Secretary of the Navy should revise the Navy's policies for compiling its financial statements so that they are in accordance with federal accounting standards and the DOD Financial Management Regulation. Specifically: (1) ammunition items needing repair and those categorized as excess, obsolete, and unserviceable should be revalued appropriately to comply with SFFAS No. 3 and the DOD Financial Management Regulation; and (2) shipboard inventories aboard smaller combatant ships should be reported as operating materials and supplies in accordance with federal accounting standards.

Agency: Department of Defense: Department of the Navy: Office of the Assistant Secretary of the Navy (Financial Management): Senior Civilian Official
Status: Open

Comments: Regarding the first part of this recommendation, the Navy reports its ordnance within the Operating Materials and Supplies-Ordinance (OM&S-O) account and acknowledged in its most recent agency financial report (AFR) that valuation adjustments pertaining to repair cost are not currently calculated for ordnance. Also, the Navy's auditors have reported a material weakness related to the OM&S-O account since fiscal year 2005. Recently, the auditors reported that the Navy did not have adequate policies, procedures, and internal controls to effectively implement accounting standards related to its OM&S-O account. The Navy currently has efforts underway intended to address this material weakness with a target correction date of late fiscal year 2021. Regarding the second part of this recommendation, SFFAS 3 states that OM&S should be accounted for using the consumption method; in that materials are to be reported as an asset until they are issued to an end user for consumption in normal operations, at which point they would be expensed. Navy acknowledges, in its fiscal year 2019 AFR, that due to system limitations operating expenses are not always recognized when the items are consumed. The Navy also stated that efforts are underway to transition to the consumption method to properly recognize expenses; however, no target completion date was provided.

Recommendation: The Commissioner of Internal Revenue should match independent contractors' information returns with their tax returns to more systematically identify employers who are misclassifying employees as independent contractors and to better target audit resources for doing employment tax examinations.

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

Comments: Call 202/512-6100 for additional information.

Recommendation: Section 630 of the Revenue Act of 1978 restricts IRS' authority to ensure that current and future classifications will be correct. In view of the equity issues and tax revenues involved, Congress may wish to consider repealing this restriction against requiring employers to prospectively reclassify employees who have been misclassified as independent contractors.

Agency: Congress
Status: Open

Comments: Call 202/512-6100 for additional information.