Recommendation: The Under Secretary for Management should ensure that the Office of Program Accountability and Risk Management and component heads execute the Component Acquisition Executive nomination and designation process consistently, as described in its guidance. This should include nominating and designating Component Acquisition Executives to oversee all acquisition programs. (Recommendation 1)

Agency: Department of Homeland Security
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 for Management should ensure that the Component Acquisition Executives that are responsible for oversight of acquisition programs comply with Department of Homeland Security direction to complete Component Acquisition Executive support staffing plans. (Recommendation 2)

Agency: Department of Homeland Security
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 for Management should identify, in policy or guidance, the expertise that constitutes critical acquisition positions for effective Component Acquisition Executive oversight. (Recommendation 3)

Agency: Department of Homeland Security
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 for Management should direct the Office of Program Accountability and Risk Management to establish a time frame for completing its assessment of the Investment Evaluation, Submission, and Tracking (INVEST) system data fields for which the Component Acquisition Executive certification is necessary, based on current use and reporting requirements, and take appropriate actions based on the results. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

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

Recommendation: The Assistant General Counsel should provide additional information on the process OACP uses to investigate potential consumer protection violations, to assess risk, and to pursue enforcement actions and establish a timeframe for doing so. Such transparency could be provided through the handbook that OACP is currently drafting or through other public means such as providing additional information on its website. (Recommendation 1)

Agency: Department of Transportation: Office of Aviation Consumer Protection
Status: Open

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

Recommendation: The Assistant General Counsel should take steps to provide transparency and clarity into the results of OACP's enforcement of consume including investigations that do not result in a consent order. Such information could be aggregated data about cases, investigations, or warning letters. (Recommendation 2)

Agency: Department of Transportation: Office of Aviation Consumer Protection
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 Army should direct the Army Futures Command, in collaboration with the Army Contracting Command and the Assistant Secretary of the Army for Acquisition, Logistics, and Technology, to regularly analyze information on the use of prototype other transactions for Army modernization. (Recommendation 1)

Agency: Department of Defense: Department of the Army
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 Army should direct the Army Futures Command, in collaboration with the Army Contracting Command, to regularly analyze information on the use of grants, cooperative agreements, research other transactions, technology investment agreements, partnership intermediary agreements, and cooperative research and development agreements for Army modernization. (Recommendation 2)

Agency: Department of Defense: Department of the Army
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 Army should ensure the Commanding General of the Army Contracting Command establishes consistent practices for its headquarters to collect, archive, and share lessons learned for research and prototype other transactions, grants, cooperative agreements, technology investment agreements, and partnership intermediary agreements. (Recommendation 3)

Agency: Department of Defense: Department of the Army
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 Army should ensure the Commanding General of the Army Contracting Command has the command's contracting centers work with its headquarters to establish consistent, coordinated practices for the contracting centers to collect, analyze, validate, archive, and share lessons learned for research and prototype other transactions, grants, cooperative agreements, technology investment agreements, and partnership intermediary agreements. (Recommendation 4)

Agency: Department of Defense: Department of the Army
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 Army should ensure the Commanding General of the Combat Capabilities Development Command establishes consistent, coordinated practices for the command to collect, analyze, validate, archive, and share lessons learned for cooperative research and development agreements. (Recommendation 5)

Agency: Department of Defense: Department of the Army
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 Army should ensure an archive is established to store and share lessons learned information related to the Army's alternative approaches for engaging industry and academia. (Recommendation 6)

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

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

Recommendation: The Commandant of the Coast Guard should ensure that the Program Manager of the Vessel Response Plan Program establishes a process to analyze incidents where VRPs have been activated to determine whether or how the Coast Guard should improve its VRP review processes—including its approach to verifying plan information, contracts, and the quality of data used in review processes-- to assure VRP effectiveness. (Recommendation 1)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

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

Recommendation: The Commandant of the Coast Guard should ensure that the Vessel Response Plan Program, in developing the charter and plan of action for the Maritime Oil Spill Response Plan Advisory Group, adopts key practices of program management. These practices include—outlining the (1) systems and methods to be used by the group to carry out its work and monitor progress on achieving desired outcomes, (2) roles and responsibilities of stakeholders involved, (3) mechanisms by which potential improvements identified by the group will be incorporated by the Vessel Response Plan Program into its processes and how such progress will be measured, (4) time frames and milestones for carrying out actions under the plan, and (5) mechanisms by which the group will obtain and incorporate feedback from the maritime industry. (Recommendation 2)

Agency: Department of Homeland Security: United States Coast Guard
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 FinCEN should develop and implement written policies and procedures to help promote the greater use of BSA reports by law enforcement agencies that do not have direct access to the BSA database. Such policies and procedures could include outreach strategies and educational or training materials. (Recommendation 1)

Agency: Department of the Treasury: Financial Crimes Enforcement Network
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 Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require the implementation of risk-based security and privacy controls for external entities that process, store, or share sensitive information with HUD. (Recommendation 1)

Agency: Department of Housing and Urban Development
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 Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require independent assessments of external entities that process, store, or share sensitive information with HUD to ensure controls are implemented. (Recommendation 2)

Agency: Department of Housing and Urban Development
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 Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require identifying and tracking corrective action needed by external entities that process, store, or share sensitive information with HUD. (Recommendation 3)

Agency: Department of Housing and Urban Development
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 Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to review and revise department-level security and privacy policies to ensure that they require monitoring of progress in implementing controls/corrective actions by external entities that process, store, or share sensitive information with HUD. (Recommendation 4)

Agency: Department of Housing and Urban Development
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 Housing and Urban Development should direct the Chief Information Officer, Senior Agency Official for Privacy, and Chief Privacy Officer to develop and maintain a comprehensive systems inventory that incorporates sufficient, reliable information about the external entities with which HUD program information is shared and the extent to which each external entity has access to PII and other sensitive information. (Recommendation 5)

Agency: Department of Housing and Urban Development
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 Health and Human Services in coordination with the Administrator of the Federal Emergency Management Agency—who head agencies leading the COVID-19 response through the Unified Coordination Group—should immediately document roles and responsibilities for supply chain management functions transitioning to the Department of Health and Human Services, including continued support from other federal partners, to ensure sufficient resources exist to sustain and make the necessary progress in stabilizing the supply chain, and address emergent supply issues for the duration of the COVID-19 pandemic. (Recommendation 1)

Agency: Department of Health and Human Services
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 Health and Human Services in coordination with the Administrator of the Federal Emergency Management Agency—who head agencies leading the COVID-19 response through the Unified Coordination Group—should further develop and communicate to stakeholders plans outlining specific actions the federal government will take to help mitigate remaining medical supply gaps necessary to respond to the remainder of the pandemic, including through the use of Defense Production Act authorities. (Recommendation 2)

Agency: Department of Health and Human Services
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 Health and Human Services—who heads one of the agencies leading the COVID-19 response through the Unified Coordination Group—consistent with their roles and responsibilities, should work with relevant federal, state, territorial, and tribal stakeholders to devise interim solutions, such as systems and guidance and dissemination of best practices, to help states enhance their ability to track the status of supply requests and plan for supply needs for the remainder of the COVID-19 pandemic response. (Recommendation 3)

Agency: Department of Health and Human Services
Status: Open

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

Recommendation: The Administrator of the Federal Emergency Management Agency—who heads one of the agencies leading the COVID-19 response through the Unified Coordination Group—consistent with their roles and responsibilities, should work with relevant federal, state, territorial, and tribal stakeholders to devise interim solutions, such as systems and guidance and dissemination of best practices, to help states enhance their ability to track the status of supply requests and plan for supply needs for the remainder of the COVID-19 pandemic response. (Recommendation 4)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
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 Health and Human Services, with support from the Secretary of Defense, should establish a time frame for documenting and sharing a national plan for distributing and administering COVID-19 vaccine, and in developing such a plan ensure that it is consistent with best practices for project planning and scheduling and outlines an approach for how efforts will be coordinated across federal agencies and nonfederal entities. (Recommendation 5)

Agency: Department of Health and Human Services
Status: Open

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

Recommendation: As the Centers for Disease Control and Prevention (CDC) implements its COVID-19 Response Health Equity Strategy, the Director of the Centers for Disease Control and Prevention should determine whether having the authority to require states and jurisdictions to report race and ethnicity information for COVID-19 cases, hospitalizations, and deaths is necessary for ensuring more complete data, and if so, seek such authority from Congress. (Recommendation 6)

Agency: Department of Health and Human Services: Public Health Service: Centers for Disease Control and Prevention
Status: Open

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

Recommendation: As CDC implements its COVID-19 Response Health Equity Strategy, the Director of the Centers for Disease Control and Prevention should involve key stakeholders to help ensure the complete and consistent collection of demographic data. (Recommendation 7)

Agency: Department of Health and Human Services: Public Health Service: Centers for Disease Control and Prevention
Status: Open

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

Recommendation: As CDC implements its COVID-19 Response Health Equity Strategy, the Director of the Centers for Disease Control and Prevention should take steps to help ensure CDC's ability to comprehensively assess the long-term health outcomes of persons with COVID-19, including by race and ethnicity. (Recommendation 8)

Agency: Department of Health and Human Services: Public Health Service: Centers for Disease Control and Prevention
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, in coordination with the Commissioner of Internal Revenue, should update and refine the estimate of eligible recipients who have yet to file for an economic impact payment to help target outreach and communications efforts. (Recommendation 9)

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, in coordination with the Commissioner of Internal Revenue, should make estimates of eligible recipients who have yet to file for an economic impact payment, and other relevant information, available to outreach partners to raise awareness about how and when to file for economic impact payments. (Recommendation 10)

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 the Office of Management and Budget, in consultation with the Department of the Treasury, should issue the addendum to the 2020 Compliance Supplement as soon as possible to provide the necessary audit guidance. (Recommendation 11)

Agency: Executive Office of the President: Office of Management and Budget
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 the Centers for Disease Control and Prevention should ensure that, as it makes updates to its federal guidance related to reassessing schools' operating status, the guidance is cogent, clear, and internally consistent. (Recommendation 12)

Agency: Department of Health and Human Services: Public Health Service: Centers for Disease Control and Prevention
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 Homeland Security, in coordination with the Secretary of Defense, should (1) revise the criteria in the 2019 National Interest Action code memorandum of agreement to clearly identify steps they will take to obtain input from key federal agencies prior to extending or closing a National Interest Action code, (2) establish timelines for evaluating the need to extend a National Interest Action code, and (3) define what constitutes a consistent decrease in contract actions and routine contract activity to ensure the criteria for extending or closing the National Interest Action code reflect government-wide needs for tracking contract actions in longer term emergencies, such as a pandemic. (Recommendation 13)

Agency: Department of Homeland Security
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, in coordination with the Secretary of Homeland Security, should (1) revise the criteria in the 2019 National Interest Action code memorandum of agreement to clearly identify steps they will take to obtain input from key federal agencies prior to extending or closing a National Interest Action code, (2) establish timelines for evaluating the need to extend a National Interest Action code, and (3) define what constitutes a consistent decrease in contract actions and routine contract activity to ensure the criteria for extending or closing the National Interest Action code reflect government-wide needs for tracking contract actions in longer term emergencies, such as a pandemic. (Recommendation 14)

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 Health and Human Services, in consultation with the Centers for Medicare & Medicaid Services and CDC, should develop a strategy to capture more complete data on confirmed COVID-19 cases and deaths in nursing homes retroactively back to January 1, 2020, and to clarify the extent to which nursing homes have reported data before May 8, 2020. To the extent feasible, this strategy to capture more complete data should incorporate information nursing homes previously reported to CDC or to state or local public health offices. (Recommendation 15)

Agency: Department of Health and Human Services
Status: Open

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

Recommendation: Based on the imminent cybersecurity threats, the Secretary of Health and Human Services should expedite implementation of our prior recommendations regarding cybersecurity weaknesses at its component agencies. (Recommendation 16)

Agency: Department of Health and Human Services
Status: Open

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

Recommendation: Congress should consider specifying in the IRC what services and activities it considers sufficient community benefit. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: When we determine what steps the Congress has taken, we will provide updated information.

Recommendation: The Commissioner of Internal Revenue should update Form 990, including Schedule H and instructions where appropriate to ensure that the information demonstrating the community benefits a hospital is providing is clear and can be easily identified by Congress and the public, including the community benefit factors. (Recommendation 1)

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

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

Recommendation: The Commissioner of Internal Revenue should assess the benefits and costs, including the tax law implications, of requiring tax-exempt hospital organizations to report community benefit expenses on Schedule H by individual facility rather than by collective organization and take action, as appropriate. (Recommendation 2)

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

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

Recommendation: The Commissioner of Internal Revenue should establish a well-documented process to identify hospitals at risk for noncompliance with the community benefit standard that would ensure hospitals' community benefit activities are being consistently reviewed. (Recommendation 3)

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

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

Recommendation: The Commissioner of Internal Revenue should establish specific audit codes for identifying potential noncompliance with the community benefit standard. (Recommendation 4)

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

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

Recommendation: The Chairman of FCC should direct and coordinate with the Chief Executive Officer of USAC to comprehensively assess fraud risks to the E-rate program, including implementing their respective plans for developing periodic fraud risk assessments, examining the suitability of existing fraud controls, and compiling fraud risk profiles following the timelines described in this report. The assessments should be informed by the key fraud risks identified in this report from closed court cases, prior risk assessments, and OIG reports, among other sources. (Recommendation 1)

Agency: Federal Communications Commission
Status: Open

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

Recommendation: The Chairman of FCC should ensure that FCC and USAC follow the leading practices in GAO's Fraud Risk Framework when designing and implementing data-analytics activities to prevent and detect fraud as part of their respective antifraud strategies for the E-rate program. (Recommendation 2)

Agency: Federal Communications Commission
Status: Open

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

Recommendation: The Chairman of FCC should direct the Chief Executive Officer of USAC to clearly define and fully document the data fields in all relevant E-rate program computer systems to help improve FCC's ability to understand and use data to manage fraud risks. (Recommendation 3)

Agency: Federal Communications Commission
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 Commerce, in consultation with the department-level Executive Resources Board and Office of Executive Resources, should fully implement policy and guidance in development that require the bureaus to maintain career SES reassignment-related documentation in the SES member's Official Personnel Folder, and to provide those documents to the Office of Executive Resources for review and approval before making career SES reassignments. (Recommendation 1)

Agency: Department of Commerce
Status: Open

Comments: In its comments on a draft of this report, Commerce concurred with the recommendation and indicated it will take steps to implement the recommendation. We will continue to monitor Commerce's progress.

Recommendation: The Secretary of Housing and Urban Development should establish a date to finalize its draft standard operating procedures for conducting career SES reassignments, and ensure that the final procedures include (1) obtaining a written moratorium waiver from the career SES member before making the reassignment during the new, noncareer supervisor moratorium, and (2) retaining the waiver in the member's Official Personnel Folder. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In its comments on the draft of the report, HUD said it finalized standard operating procedures for making career SES reassignments, and thus believes it has addressed our recommendation. We will follow up with the department to assess whether its actions fully address the recommendation.

Recommendation: The Acting Director of the Office of Personnel Management should use OPM's oversight authority to monitor career SES reassignments to ensure that federal agencies meet requirements contained in statute or regulation, and follow OPM's related guidance. In situations where OPM finds that an agency has taken a career SES reassignment action contrary to these requirements, it should use its authority to require the agency to take corrective action, as appropriate. (Recommendation 4)

Agency: Office of Personnel Management
Status: Open

Comments: OPM did not concur with our recommendation. In its comment on a draft of the report, OPM said it relies on federal agencies to comply with provisions governing SES reassignments. OPM further stated that it has chosen not to make reassignments a focus of its enforcement efforts, in light of scarce resources and other mandates OPM is required to meet. However, for reasons discussed in the report, we maintain that OPM should use its oversight authority to ensure agencies' reassignments of SES staff are consistent with requirements. We will continue to monitor OPM's progress.

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 Commissioner of FDA should establish a process for the agency to communicate directly with all U.S.-based commercial airlines, including regional airlines, to encourage them to request construction inspections to ensure compliance with the agency's standards for the sanitary construction of aircraft galleys and lavatories. (Recommendation 1)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

Comments: HHS concurs with GAO's recommendation. FDA agrees that enhancing communication with U.S.-based commercial airlines, including major national and regional commuter airlines, to encourage them to request construction inspections can have a positive impact on efforts to gain compliance with the Agency's standards for aircraft galley and lavatory sanitation and potable water system installation. FDA has a long history of working collaboratively with interstate travel conveyance stakeholders to provide public health oversight to the industry. As part of this collaboration, FDA and the airline industry connect through a variety of mechanisms to provide access to diverse industry partners. To effectively engage all relevant stakeholders, FDA will consider ways to enhance current mechanisms and coordinate with airlines on better communication. FDA will review its existing outreach channels to allow airline stakeholders to actively and directly engage with the Agency on construction inspections. FDA will review its Interstate Travel Program website to determine if updates can be made to emphasize airline construction and reconstruction information. FDA maintains open dialog with airline organizations, including the Airlines for America (A4A), the Regional Airline Association (RAA), and the International Flight Services Association (IFSA). Members of A4A are comprised of major national airlines, whereas those of RAA are comprised of regional commuter airlines and those in IFSA include airlines and airline food suppliers. These industry associations are valuable partners in developing solutions to problems that concern the airlines and airline construction. FDA will continue to engage with these organizations in written correspondence and at relevant national industry meetings (such as the Environmental Protection Agency biennial meeting on aircraft drinking water safety) and will include the topic of construction inspections. FDA will also continue to use these existing mechanisms to develop a better communication process with the airline industry on its efforts to improve industry practice and government oversight.

Recommendation: The Commissioner of FDA should, as part of the agency's efforts to update OLS's strategic plan for overseeing agency-wide laboratory safety, resolve agency-wide disagreements on the roles and responsibilities for the centers and OLS in implementing laboratory safety reforms. (Recommendation 1)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

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

Recommendation: The Commissioner of FDA should, as part of the agency's efforts to update OLS's strategic plan for overseeing agency-wide laboratory safety, address issues of duplication, overlap, and fragmentation within the safety program. (Recommendation 2)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

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

Recommendation: The Commissioner of FDA should, as part of the agency's efforts to update OLS's strategic plan for overseeing agency-wide laboratory safety, identify how FDA leadership will communicate agency-wide on a sustained basis about the importance of laboratory safety and OLS's role in ensuring successful implementation of laboratory safety reforms. (Recommendation 3)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

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

Recommendation: The Commissioner of FDA should provide OLS—as FDA's laboratory oversight body—with the necessary oversight authority and access to laboratories to oversee FDA's laboratory safety program and ensure compliance with the agency's laboratory safety policies. (Recommendation 4)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

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

Recommendation: The Commissioner of FDA should take steps to assess and mitigate any risks to independence posed by funding OLS—as FDA's laboratory safety oversight body—through the working capital fund. In conducting its risk assessment, FDA should specifically focus on ensuring the decision-making processes of the working capital fund supports OLS's independence and ability to hire sufficient staff to implement its laboratory safety oversight priorities. (Recommendation 5)

Agency: Department of Health and Human Services: Food and Drug Administration
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 ICE should direct Custody Management to regularly conduct analyses of contracted facility inspections oversight data over time, within and across facilities and regions, and in a manner to enable trends in inspection deficiencies to be identified and addressed. (Recommendation 1)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
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 ICE should direct the Office of Detention Oversight and Custody Management to take steps to ensure that data on deficiencies identified through Office of Detention Oversight's inspections are recorded in a format that is accessible to Custody Management for analysis purposes. (Recommendation 2)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
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 ICE should regularly conduct analyses of data on deficiencies identified through Office of Detention Oversight's inspections. (Recommendation 3)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
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 ICE should ensure that all Operational Review Self-Assessment results and corrective actions are recorded in a format that is conducive to tracking and analysis. (Recommendation 4)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
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 ICE should regularly conduct analyses of detention-related complaint data from relevant offices, including analyses of data over time, within and across facilities and regions, and at a level necessary to identify and address potentially reoccurring complaints. (Recommendation 5)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
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 ICE should require that ERO field offices record any actions taken on, and the resolutions of, detention-related complaints referred to them from the Detention Reporting and Information Line and Administrative Inquiry Unit in a timely manner. (Recommendation 6)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

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

Recommendation: The FAA Administrator should assign authority to an office or other entity to oversee use of the Compliance Program across program offices. (Recommendation 1)

Agency: Department of Transportation: Federal Aviation Administration
Status: Open

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

Recommendation: The FAA Administrator should collect and analyze data to monitor use of the Compliance Program across all program offices. (Recommendation 2)

Agency: Department of Transportation: Federal Aviation Administration
Status: Open

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

Recommendation: The FAA Administrator should conduct an evaluation of the Compliance Program to assess the effectiveness of the program in meeting its goals. (Recommendation 3)

Agency: Department of Transportation: Federal Aviation Administration
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 OMB should take steps to ensure that federal agencies implement its guidance on agency adherence to E.O. 13132 requirements, particularly related to designating a federalism official. (Recommendation 1)

Agency: Executive Office of the President: Office of Management and Budget
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 for Health should fully define in VHA policy the oversight roles and responsibilities related to ensuring facilities' adherence to disbursement agreement policies, including roles related to ReDPro and the role of VISNs. (Recommendation 1)

Agency: Department of Veterans Affairs
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 for Health should more clearly define in VHA policy the purposes of the periodic independent audits and the ReDPro checklist reviews—including differentiating their purposes from one another and ensuring that they do not unnecessarily overlap. (Recommendation 2)

Agency: Department of Veterans Affairs
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 for Health should ensure that OAA and CBI modify the ReDPro checklist and associated guidance, to include ensuring that checklist items are clearly stated, relevant to the updated purpose of the ReDPro checklist, and not unnecessarily duplicative of items to be addressed by the periodic independent audits. The guidance should also include detailed instruction on what the compliance officers should review, and how they should determine the appropriate response for each checklist item. (Recommendation 3)

Agency: Department of Veterans Affairs
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 for Health should ensure that OAA and CBI develop and provide additional ReDPro training for compliance officers, consistent with the updated checklist and guidance. This training should include general information on GME programs and disbursement agreement oversight, as well as detailed information about how ReDPro reviews should be conducted. (Recommendation 4)

Agency: Department of Veterans Affairs
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 for Health should ensure that OAA implements a standardized independent audit tool that is consistent with the updated purpose of the periodic independent audits, and does not unnecessarily overlap with the ReDPro checklist. This could include modifying its existing recommended checklist, or developing a new tool. (Recommendation 5)

Agency: Department of Veterans Affairs
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 for Health should ensure that OAA develops guidance for periodic independent audits to assist the audit teams and facility management in understanding how audits are to be conducted. (Recommendation 6)

Agency: Department of Veterans Affairs
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 for Health should ensure that OAA develops substantive training for independent audit team members, consistent with the updated audit purpose, guidance, and tools. This training should include general information on GME programs and disbursement agreement oversight, as well as detailed information about how the independent audits should be conducted. (Recommendation 7)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Associate Director of FinCEN's Global Investigations Division should provide additional direction for self-initiated GTOs, including how the agency will plan to (1) oversee covered businesses, (2) inform and obtain feedback from appropriate law enforcement agencies, and (3) evaluate the GTOs to determine the appropriate course of action. (Recommendation 1)

Agency: Department of the Treasury: Financial Crimes Enforcement Network
Status: Open

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

Recommendation: We recommend that the Attorney General ensure that additional guidance is provided to federal agencies to clarify Fix NICS Act certification requirements for record submissions and reporting. (Recommendation 1)

Agency: Department of Justice
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 Air Force should develop and implement procedures for an ERM governance structure that includes oversight responsibilities for identifying, assessing, responding to, and reporting on the risks associated with agency material weaknesses from all relevant sources. These procedures should clearly demonstrate that risks associated with material weaknesses are considered by Air Force governance, as a whole, and are mitigated appropriately to achieve goals and objectives. (Recommendation 1)

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

Comments: The DOD concurred with this recommendation and highlighted steps taken or planned to address this recommendation. Specifically, in FY19, the Air Force assessed the current-state of the risk management programs throughout the Air Force and developed a maturity model, implementation plan, and a governance structure to comply with OMB A-123 requirements. These enhancements will be implemented and formalized in policy in FY20. Further, beginning in FY19, the Air Force Senior Assessment Team (SAT) and the Senior Management Council (SMC) monitored corrective action plans for material weaknesses identified internally and by independent public accountants, including their impact on the Air Force's ability to achieve its enterprise objectives. In addition, the Air Force developed a process for the SAT and the SMC to discuss corrective action plans for material weaknesses on a quarterly basis as opposed to an annual basis, which will be evidenced in the form of board briefings and meeting minutes. Additionally, in FY19 the Air Force engaged the Enterprise Productivity Improvement Council to serve as the Air Force Risk Management Council (RMC) to oversee enterprise risk management as defined by their Charter, which was signed in February 2020. The Air Force will refine its policies and procedures to clearly specify the risks associated with the material weaknesses being addressed by the Air Force governance boards. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies by September 2020 and publish the policies by September 2021.

Recommendation: The Secretary of the Air Force should develop policies or procedures for assessing internal control to require (1) clearly delineating who within the Air Force is responsible for evaluating the internal control components and principles, how often they are to perform the evaluation, the level (e.g., entity or transactional) of the evaluation, what objectives are covered in the assessment, to whom to communicate the results if they are relevant to others performing assessments of internal control, and what guidance to follow; (2) documenting management's determination of whether each component and principle is designed, implemented, and operating effectively; and (3) documenting management's determination of whether components are operating together in an integrated manner. (Recommendation 2)

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

Comments: The DOD concurred with this recommendation and described steps taken or planned to address the recommendation. The Air Force SAF/FM performs both entity-level control assessments against all internal control components and principles and performs process level control assessments for internal controls over financial reporting and financial systems. The Air Force Audit Agency and the Air Force Inspector General have performed assessments related to operations and compliance. The Air Force will document those roles and responsibilities in formal policies. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies by September 2020 and publish the policies by September 2021.

Recommendation: The Secretary of the Air Force should develop policies or procedures for assessing internal control to require the use of test plans that (1) tie back to specific objectives to be achieved as included in the Business Operations Plan; (2) specify the nature, scope, and timing of procedures to conduct under the OMB Circular No. A-123 assessment process; and (3) reflect a consideration of prior year self-identified control deficiencies and results of internal and external audits. (Recommendation 3)

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

Comments: The DOD concurred with this recommendation and described steps taken or planned to address this recommendation. The Air Force test plans for internal controls over financial reporting and financial systems tie back to their relevant risk frameworks embedded in authoritative audit guidance. The framework used for financial reporting is the Financial Audit Manual, and the framework used for financial systems is the Federal Information Systems Controls Audit Manual, and include the nature, scope and timing of procedures performed. The Air Force's process-level internal control test plans are aligned with business process-level risks and objectives and are not directly associated with the Air Force's strategic objectives. The Air Force Business Operations Plan identifies strategic objectives, not business process-level objectives. Additionally, the Air Force considers previously identified internal control deficiencies in its annual documented internal control assessment scoping process. The Air Force will refine its policies and procedures regarding the use of test plans including operational and compliance controls. Due to the need for policy, procedure, and documentation updates required for operational and compliance controls, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine policies, procedures, and documentation by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should develop policies or procedures for assessing internal control to require SAF/FM to validate (1) the number of organizational units reporting for its overall internal control assessment; (2) how control procedures were tested, what results were achieved, and how conclusions were derived from those results; and (3) whether the results used to compile the current year report are based on current fiscal year's assessments. (Recommendation 4)

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

Comments: The DOD concurred with this recommendation. The Air Force will design policies and procedures to determine assessable units and verify that results are current on an annual basis. Due to the need to reevaluate the Air Force's assessable unit structure and the associated change management that will be necessary to implement the changes to sustain an effective program, the Air Force plans to refine the policies by September 2021 and publish the policies by September 2022.

Recommendation: The Secretary of the Air Force should develop policies or procedures for assessing internal control to require SAF/FM to assess how waivers affect the current year assessment of internal control, the determination of systemic weaknesses, and the compilation of the Air Force's overall Statement of Assurance. (Recommendation 5)

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

Comments: The DOD concurred with this recommendation. The Air Force will design policies and procedures to consider the impact of waivers to the overall assessment of the system of internal control. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies by September 2020 and publish the policies by September 2021.

Recommendation: The Secretary of the Air Force should require that developers of the policy and related guidance associated with designing the procedures for conducting OMB Circular No. A-123 assessments receive recurring training and are appropriately skilled in conducting internal control assessments and are familiar with Standards for Internal Control in the Federal Government. (Recommendation 6)

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

Comments: The DOD concurred with this recommendation and described steps taken or planned to address the recommendation. Specifically, the Air Force is implementing multiple changes to the Air Force's ERM and internal control program, including improved governance, standardized processes and documentation for enterprise risk management, entity-level and process-level controls, training, fraud risk management, and data quality management. Training content in FY20 was updated to reflect additional information, including definitions for internal controls and considerations for determining material weaknesses for operations. The Air Force will continue to update its the policies, guidance, and training to coincide with the current progress of the program. The Air Force will continue to refine the audience of its training to verify that those responsible for implementing and assessing ERM and internal controls are trained sufficiently. Due to the need for policy, procedure, documentation, and training updates required for operational and compliance controls, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies, procedures, documentation, and training by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should analyze all definitions included in Air Force ERM and internal control assessment policy and related guidance to ensure that all definitions and concepts are defined correctly. (Recommendation 7)

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

Comments: The DOD concurred with this recommendation. The Air Force will verify that all definitions and concepts in its policies are current and consistent with other authoritative guidance. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies by September 2020 and publish the policies by September 2021.

Recommendation: The Secretary of the Air Force should require SAF/FM to design recurring training for those who will assess internal control that (1) includes enhancing their skills in evaluating the internal control system and documenting results; (2) reflects all OMB Circular No. A-123 requirements, such as those related to identifying objectives, evaluating deficiencies, and determining material weaknesses; and (3) is provided to all who are responsible for performing internal control assessments. (Recommendation 8)

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

Comments: The DOD concurred with this recommendation and described actions taken or planned to address the recommendation. Specifically, the Air Force performs annual training to Major Commands, Direct Reporting Units, and Functional Executives. In FY20, the Air Force included business process assessable leads in this training. The Air Force plans to continue to refine the audience of its training to verify that those responsible for implementing and assessing ERM and internal controls are trained sufficiently by September 2021.

Recommendation: The Secretary of the Air Force should develop policy or procedures consistent with OMB Circular No. A-123 to assess the system of internal control using a risk-based approach. (Recommendation 9)

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

Comments: The DOD concurred with this recommendation and described actions taken or planned to address the recommendation. Specifically, the Air Force's scoping procedures, beginning in FY19, consider materiality, both quantitative and qualitative risk, as well as risks identified in the enterprise risk management process. The Air Force assesses internal controls over financial reporting and financial systems using a risk-based approach as evidenced currently in documented procedures and testing templates. The Air Force will refine its procedure documentation to include the assessment of internal controls over operations and compliance using a risk-based approach. Due to the need for policy, procedure, and documentation updates required for operational and compliance controls, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies, procedures, and documentation by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should develop procedures to assess internal control over processes related to mission-critical assets, including (1) tests of design that evaluate whether controls are capable of achieving objectives, (2) tests of effectiveness only after a favorable assessment of the design of the control, and (3) a baseline that has accurate descriptions of business processes and identifies key internal controls as designed by management to respond to risks. (Recommendation 10)

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

Comments: The DOD concurred with this recommendation and described actions taken or planned to address the recommendation. The Air Force documents processes and assesses internal controls over financial reporting and financial systems related to mission critical assets that includes determinations as to internal control design, implementation, operating effectiveness and risks. The Air Force will enhance its approach for documenting processes and assessing internal controls over operations and compliance not related to financial reporting and financial systems through policy. Due to the need for policy, procedure, and documentation updates required for operational and compliance controls related to mission-critical assets, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies, procedures, and documentation by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should establish a process and reporting lines of all the sources of information, including reviews performed of internal control processes related to mission-critical assets, that will be considered in the Secretary's Statement of Assurance. (Recommendation 11)

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

Comments: The DOD concurred with this recommendation. The Air Force reports material weaknesses in internal controls over financial reporting and financial systems related to mission critical assets through SAF/FM, but it will solidify its reporting channels for material weaknesses in internal controls over operations and compliance through policy. Due to the need for policy, procedure, documentation, and training updates required to appropriately report deficiencies in internal control over operations and compliance, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies, procedures, documentation, and training by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should develop procedures to require coordination between business process leads and the Air Force's unit managers to ensure that mission-critical asset–related internal control deficiencies are considered in the unit managers' assessments of internal control and related supporting statements of assurance. These procedures should include how, when, and with what frequency the results from the business process internal control reviews should be provided to relevant organizational units for consideration in their respective assurance statements. (Recommendation 12)

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

Comments: The DOD concurred with this recommendation. The Air Force will develop procedures to enhance communication between business process leads and Air Force unit managers to verify that deficiencies are reported appropriately in supporting statements of assurance. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, as well as the change management needed to implement additional communications and protocol processes, the Air Force plans to refine the policies by September 2021 and publish the policies by September 2022.

Recommendation: The Commissioner of Internal Revenue should document measurable objectives for using data in selecting exempt organization returns for examination. (Recommendation 1)

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

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

Recommendation: The Commissioner of Internal Revenue should document and consistently use clear criteria and decision rules on assigning point values to queries, using categories and sliding scales. (Recommendation 2)

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

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

Recommendation: The Commissioner of Internal Revenue should require a regular review of query descriptions and programming to ensure their accuracy and minimize queries that flag the same or similar compliance issue. (Recommendation 3)

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

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

Recommendation: The Commissioner of Internal Revenue should develop procedures and criteria to test new queries prior to implementation in the models. (Recommendation 4)

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

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

Recommendation: The Commissioner of Internal Revenue should more fully document how TE/GE processes data and uses data to make examination selection decisions for sources outside of the model such as research projects and other projects that use queries. (Recommendation 5)

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

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

Recommendation: The Commissioner of Internal Revenue should conduct an analysis to identify the optimal interval between model runs. (Recommendation 6)

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

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

Recommendation: The Commissioner of Internal Revenue should establish a process for regularly evaluating selection decisions and related outcomes for the models and other processes that use data to select returns for examinations. (Recommendation 7)

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

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

Recommendation: The Commissioner of Internal Revenue should document consideration or action on recommendations from its 2018 and 2020 contractor assessments. (Recommendation 8)

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

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

Recommendation: The Commissioner of Internal Revenue should document how score and query data for all returns in the models will continue to be saved over the long term. (Recommendation 9)

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

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

Recommendation: The Commissioner of Internal Revenue should ensure that historical data on examination outcomes are consistently defined and used when doing analysis of examination outcomes. (Recommendation 10)

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

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

Recommendation: The Commissioner of Internal Revenue should routinely analyze the reasons for not examining selected returns and identify any necessary actions to address the reasons. (Recommendation 11)

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

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

Recommendation: The Commissioner of Internal Revenue should annually review and update procedures as needed in relevant IRM sections on examination selection and issue interim guidance until the affected IRM sections are updated. (Recommendation 12)

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

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

Recommendation: The Commissioner of Internal Revenue should document why TE/GE has not identified any risks in its risk register for using data to select exempt organization returns for examination. If risks are subsequently identified, TE/GE should document how it plans to analyze and address them. (Recommendation 13)

Agency: Department of the Treasury: Internal Revenue Service
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 Commerce should align the agency's contingency plan with OMB guidance by including (1) plans for a potential prolonged shutdown; (2) flexibilities available to supervisors if furloughed employees were unable to return to work after the end of the shutdown; and (3) procedures for resuming program activities, including steps to ensure appropriate oversight and disbursement of funds upon the end of a shutdown. (Recommendation 1)

Agency: Department of Commerce
Status: Open

Comments: The Department of Commerce agreed with the recommendation and stated that it will develop an action plan to address the recommendation to better align its contingency plan with OMB guidance. When we confirm what actions Commerce has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Homeland Security should align the agency's contingency plan with OMB guidance by including (1) plans for a potential prolonged shutdown; (2) flexibilities available to supervisors if furloughed employees were unable to return to work after the end of the shutdown; and (3) procedures for resuming program activities, including steps to ensure appropriate oversight and disbursement of funds upon the end of a shutdown. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: The Department of Homeland Security agreed with the recommendation and and stated that it has begun to take steps to better address OMB guidance on contingency plans. When we confirm what actions DHS has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of Internal Revenue should align the agency's contingency plan with OMB guidance by including (1) plans for a potential prolonged shutdown; (2) flexibilities available to supervisors if furloughed employees were unable to return to work after the end of the shutdown; and (3) procedures for resuming program activities, including steps to ensure appropriate oversight and disbursement of funds upon the end of a shutdown. (Recommendation 3)

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

Comments: The Internal Revenue Service (IRS) partially agreed with the recommendation. IRS agreed with one element of our recommendation to include additional detail in its agency contingency plan and stated that it is in the process of adding procedures for resuming program activities following a government shutdown into its contingency plan. IRS did not agree with the other elements of the recommendation because it believes it has already addressed plans for a potential prolonged shutdown and flexibilities for supervisors if employees are unable to return to work at the end of a shutdown in its contingency plans. We agree that while IRS has included some details on these elements in its plans, we continue to believe that it should provide more detail, such as points in time when the furlough status of an employee may change, how many employees would be affected, and the legal basis for the changes, within its publically available contingency plan to fully address these elements. We will continue to monitor IRS's efforts in this area.

Recommendation: The U.S. Trade Representative, in consultation with EOP as appropriate, should align the component's contingency plan with OMB guidance. This could be accomplished through (1) revisions to the EOP contingency plan; or (2) by creating a separate USTR plan. (Recommendation 4)

Agency: Executive Office of the President: Office of the United States Trade Representative
Status: Open

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has already begun addressing our recommendations on aligning its contingency plan with OMB guidance. When we confirm what actions USTR has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for International Trade should document the component's shutdown processes, including roles and responsibilities, planning processes for potential shutdowns, and recall processes for furloughed employees during a shutdown. (Recommendation 5)

Agency: Department of Commerce: International Trade Administration
Status: Open

Comments: The Department of Commerce agreed with the recommendation and stated that the International Trade Administration (ITA) has documented its shutdown planning processes and recall processes for furloughed employees during a shutdown. When we confirm what actions ITA has taken in response to this recommendation, we will provide updated information.

Recommendation: The U.S. Trade Representative should document the component's shutdown processes, including roles and responsibilities, planning processes for potential shutdowns, and recall processes for furloughed employees during a shutdown. (Recommendation 6)

Agency: Executive Office of the President: Office of the United States Trade Representative
Status: Open

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has already begun addressing our recommendations on documenting its shutdown processes. When we confirm what actions USTR has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of CBP should develop internal controls to track and document which employees worked and what work was performed daily during a government shutdown. (Recommendation 7)

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

Comments: The Department of Homeland Security agreed with the recommendation and stated that Customs and Border Protection plans to analyze existing systems to determine which is best suited to track and document employee work during a government shutdown and will ensure that the chosen system is available should a future shutdown occur. When we confirm what actions CBP has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of CBP should develop internal controls to limit access to physical workspaces to appropriate employees during a government shutdown. (Recommendation 8)

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

Comments: The Department of Homeland Security (DHS) agreed with the recommendation but stated that because Customs and Border Protection (CBP) does not have systems capable of efficiently restoring physical access for furloughed employees, it would have to reinstate employee access individually and the cost would be substantial. DHS stated that CBP plans to update procedures to ensure more comprehensive workspace access guidance for furloughed employees. We continue to believe that physical access controls are important during shutdowns in order to prevent misuse of government resources. We encourage CBP to improve their systems to be able to efficiently implement such controls and will monitor CBP's efforts going forward.

Recommendation: The Commissioner of Internal Revenue should develop internal controls to limit access to physical workspaces to appropriate employees during a government shutdown. (Recommendation 9)

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

Comments: The Internal Revenue Service disagreed with this recommendation. IRS stated that it believes that it has effective controls in place to manage physical workspace access during a shutdown. In addition, IRS said that it believes that implementing additional access controls do not justify the corresponding resource investments. We continue to believe that IRS should improve its access controls, which currently rely on managers and furlough letters to communicate limits on workspace access. While we recognize the costs of increased access controls, government shutdowns are unique events that require additional access controls in order to prevent potential misuse of government resources and will monitor IRS's efforts to address it.

Recommendation: The U.S. Trade Representative should develop internal controls to limit access to physical workspaces to appropriate employees during a government shutdown. (Recommendation 10)

Agency: Executive Office of the President: Office of the United States Trade Representative
Status: Open

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has made the Executive Office of the President (EOP) aware of the recommendations on developing controls for physical workspace access during a shutdown. We will continue to monitor USTR's efforts to address this recommendation.

Recommendation: The Commissioner of CBP should develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 11)

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

Comments: The Department of Homeland Security (DHS) agreed with the recommendation. DHS stated that Customs and Border Protection (CBP) believes that furloughed employees must be able to passively monitor the status of the government shutdown and access important agency communications using DHS-issued electronic devices. Additionally, disabling and reactivating thousands of employee user accounts during a shutdown posed a significant burden. DHS said that CBP plans to update shutdown procedures to clarify allowed use of DHS-issued electronic devices by furloughed employees. We agree that CBP should update procedures on workspace access as suggested, and continue to believe that virtual access controls are important during shutdowns in order to prevent misuse of government resources. We encourage CBP to improve their systems to be able to efficiently implement such controls and will monitor CBP's progress going forward.

Recommendation: The Commissioner of Internal Revenue should develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 12)

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

Comments: The Internal Revenue Service disagreed with this recommendation. IRS stated that it believes that it has effective controls in place to manage virtual workspace access during a shutdown. In addition, IRS said that it believes that implementing additional access controls do not justify the corresponding resource investments. We continue to believe that IRS should improve its access controls, which currently rely on managers and furlough letters to communicate limits on workspace access. While we recognize the costs of increased access controls, government shutdowns are unique events that require additional access controls in order to prevent potential misuse of government resources and will monitor IRS's efforts to address it.

Recommendation: The Under Secretary for International Trade should develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 13)

Agency: Department of Commerce: International Trade Administration
Status: Open

Comments: The Department of Commerce agreed with the recommendation and stated that the International Trade Administration (ITA) has established and documented internal controls to limit virtual workspace access to excepted or exempt employees during a government shutdown. When we confirm what actions ITA has taken in response to this recommendation, we will provide updated information.

Recommendation: The U.S. Trade Representative should, in consultation with EOP, develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 14)

Agency: Executive Office of the President: Office of the United States Trade Representative
Status: Open

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has made the Executive Office of the President (EOP) aware of the recommendations on developing controls for virtual workspace access during a shutdown. We will continue to monitor USTR's efforts to address this recommendation.

Recommendation: The Commissioner of IRS should change Schedule C or Form 1099-NEC so that taxpayers can identify if they received payment for platform work. (Recommendation 1)

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

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

Recommendation: The Commissioner of IRS should develop a process for monitoring feedback on its communications efforts and products tailored for platform workers, which should include documenting and evaluating feedback. (Recommendation 2)

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

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

Recommendation: The Commissioner of IRS should clarify the instructions and publications for Forms 1040 and 1099-K by adding plain language to clearly indicate to platform workers that the forms apply to them. (Recommendation 3)

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

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

Recommendation: The Commissioner of IRS should work with the Secretary of the Treasury to amend the 6050W "tie-breaker rule" that applies to duplicative reporting requirements so that payments made through a TPSO's third party payment network are reportable under Section 6041, rather than under Section 6050W. (Recommendation 4)

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

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

Recommendation: The Commissioner of IRS should work with Treasury to determine what thresholds would be the most appropriate for payment information reporting and, if warranted, recommend that Congress adjust the thresholds. (Recommendation 5)

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

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

Recommendation: The Commissioner of IRS should work with the Secretary of the Treasury to implement withholding that is voluntary for companies making payments for services to platform workers and other independent contractors who choose to participate. (Recommendation 6)

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

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

Recommendation: The Commissioner of IRS should assess the impact of withholding that is voluntary for companies, once implemented, and if warranted, work with the Secretary of the Treasury on a proposal to Congress that would require TPSOs to offer tax withholding to platform workers and other independent contractors who choose to participate. (Recommendation 7)

Agency: Department of the Treasury: Internal Revenue Service
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 DLA should include a step for the opportunity for PCR review of the proposed contract and subcontracting plan in agency procedures and memorandums, and develop a mechanism for documenting whether the opportunity for PCR review was provided. (Recommendation 1)

Agency: Department of Defense: Defense Logistics Agency
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 Navy should include a step for the opportunity for PCR review of the proposed contract and subcontracting plan in agency procedures and memorandums, and develop a mechanism for documenting whether the opportunity for PCR review was provided. (Recommendation 2)

Agency: Department of Defense: Department of the Navy
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 DLA should take steps to fulfill the requirement that contracting officers ensure that subcontracting reports are submitted by contractors in a timely manner. For example, the agency could require contracting officers to verify that prior reports were submitted when reviewing current submissions. (Recommendation 3)

Agency: Department of Defense: Defense Logistics Agency
Status: Open

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

Recommendation: The NASA Administrator should take steps to fulfill the requirement that contracting officers ensure that subcontracting reports are submitted by contractors in a timely manner. For example, the agency could require contracting officers to verify that prior reports were submitted when reviewing current submissions. (Recommendation 4)

Agency: National Aeronautics and Space Administration
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 Navy should take steps to fulfill the requirement that contracting officers ensure that subcontracting reports are submitted by contractors in a timely manner. For example, the agency could require contracting officers to verify that prior reports were submitted when reviewing current submissions. (Recommendation 5)

Agency: Department of Defense: Department of the Navy
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 DLA should take steps to ensure contracting officers compare subcontracting goals in contractor report submissions to goals in the approved subcontracting plan and address any discrepancies. (Recommendation 6)

Agency: Department of Defense: Defense Logistics Agency
Status: Open

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

Recommendation: The Administrator of the GSA should take steps to ensure contracting officers compare subcontracting goals in contractor report submissions to goals in the approved subcontracting plan and address any discrepancies. (Recommendation 7)

Agency: General Services Administration
Status: Open

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

Recommendation: The NASA Administrator should take steps to ensure contracting officers compare subcontracting goals in contractor report submissions to goals in the approved subcontracting plan and address any discrepancies. (Recommendation 8)

Agency: National Aeronautics and Space Administration
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 Navy should take steps to ensure contracting officers compare subcontracting goals in contractor report submissions to goals in the approved subcontracting plan and address any discrepancies. (Recommendation 9)

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

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

Recommendation: The SBA Administrator should ensure Commercial Market Representatives clearly and consistently document compliance reviews and maintain these records. (Recommendation 10)

Agency: Small Business Administration
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 OMB should ensure that CMS, FBI, IRS, and SSA are collaborating on their cybersecurity requirements pertaining to state agencies to the greatest extent possible and direct further coordination where needed. (Recommendation 1)

Agency: Executive Office of the President: Office of Management and Budget
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 OMB should take steps to ensure that CMS, FBI, IRS, and SSA coordinate, where feasible, on assessments of state agencies' cybersecurity, which may include steps such as leveraging other agencies' security assessments or conducting assessments jointly. (Recommendation 2)

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

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

Recommendation: The Administrator of CMS should, in collaboration with OMB, solicit input from FBI, IRS, SSA, and state agency stakeholders on revisions to its security policy to ensure that cybersecurity requirements for state agencies are consistent with other federal agencies and NIST guidance to the greatest extent possible and document CMS's rationale for maintaining any requirements variances.(Recommendation 3)

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

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

Recommendation: The Administrator of CMS should revise its assessment policies to maximize coordination with other federal agencies to the greatest extent practicable. (Recommendation 4)

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

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

Recommendation: The FBI Director should, in collaboration with OMB, solicit input from CMS, IRS, SSA, and state agency stakeholders on revisions to its security policy to ensure that cybersecurity requirements for state agencies are consistent with other federal agencies and NIST guidance to the greatest extent possible. (Recommendation 5)

Agency: Department of Justice: Federal Bureau of Investigation
Status: Open

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

Recommendation: The FBI Director should fully develop policies for coordinating with state agencies on the use of prior findings from relevant cybersecurity assessments conducted by other organizations. (Recommendation 6)

Agency: Department of Justice: Federal Bureau of Investigation
Status: Open

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

Recommendation: The FBI Director should revise its assessment policies to maximize coordination with other federal agencies to the greatest extent practicable. (Recommendation 7)

Agency: Department of Justice: Federal Bureau of Investigation
Status: Open

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

Recommendation: The IRS Commissioner should, in collaboration with OMB, solicit input from CMS, FBI, SSA, and state agency stakeholders on revisions to its security policy to ensure that cybersecurity requirements for state agencies are consistent with other federal agencies and NIST guidance to the greatest extent possible. (Recommendation 8)

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

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

Recommendation: The IRS Commissioner should revise its assessment policies to maximize coordination with other federal agencies to the greatest extent practicable. (Recommendation 9)

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

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

Recommendation: The Commissioner of SSA should, in collaboration with OMB, solicit input from CMS, FBI, IRS, and state agency stakeholders on revisions to its security policy to ensure that cybersecurity requirements for state agencies are consistent with other federal agencies and NIST guidance to the greatest extent possible and document the SSA's rationale for maintaining any requirements variances. (Recommendation 10)

Agency: Social Security Administration
Status: Open

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

Recommendation: The Commissioner of SSA should fully develop policies for coordinating with state agencies on the use of prior findings from relevant cybersecurity assessments conducted by other organizations. (Recommendation 11)

Agency: Social Security Administration
Status: Open

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

Recommendation: The Commissioner of SSA should revise its assessment policies to maximize coordination with other federal agencies to the greatest extent practicable. (Recommendation 12)

Agency: Social Security Administration
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 BIE should establish consistent requirements for schools on making up missed special education and related services and monitor schools to ensure that they follow these requirements. (Recommendation 1)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency acknowledges that it must refine the guidance provided by its special education subject matter experts to ensure that guidance on missed special education related services is consistent. They anticipate fully implementing reforms through formally published guidance to its special education professionals.

Recommendation: The Director of BIE should work with knowledgeable stakeholders in Indian education to establish a community of practice or other formal mechanism to identify and disseminate promising practices for schools—especially those in remote locations—on recruiting, hiring, and retaining special education teachers and contracting with providers. The Director of BIE could consider conferring with BIE's special education advisory committee, OSEP, and relevant tribal and state education officials in addressing this recommendation. (Recommendation 2)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency plans to work collaboratively with all of its special education stakeholders to build on its internal human capital capabilities, Strategic Workforce Plan and other human capital improvements.

Recommendation: The Director of BIE should rescind the policy of its division overseeing tribally controlled schools that does not meet Interior's requirement to annually review all schools' documentation to verify the provision of services for every special education student, and ensure that all divisions comply with this requirement. (Recommendation 3)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency is reviewing all of its special education policies and procedures and, as of May 2020, anticipates an updated, comprehensive special education policy and handbook in the coming months. This includes replacing the Tribally-Controlled School Division's 3-year review policy with an annual review. A first draft of the new special education handbook and policy is expected in the summer of 2020.

Recommendation: The Director of BIE should update the agency's workforce plan to include a strategy and timeframe for filling vacant staff positions responsible for overseeing and supporting schools' special education programs. (Recommendation 4)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation and plans to update and expand its Strategic Workforce plan to include new function areas. They expect to update it in the coming months to include special education and Johnson O'Malley functions.

Recommendation: The Director of BIE should fully implement the agency's high-risk monitoring policy for IDEA and other federal education programs, including requirements for agency-wide coordination, and ensure that schools selected for such monitoring receive reports and technical assistance plans within 30 days of agency on-site visits, as required by BIE policy. (Recommendation 5)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. Based on lessons learned in its first two years of implementation, the agency plans to make targeted refinements to the policy and process of high-risk monitoring. Regarding the timeliness of report submission and technical assistance delivery, the agency began a targeted reform designed to address this structural weakness, namely, the need to centralize the administrative functions of its oversight activities. The newly established Performance Office will assume the administrative and management oversight of the high-risk fiscal monitoring policy and handbook, including the timely delivery of monitoring reports and technical assistance plans.

Recommendation: The Director of BIE should establish special education training requirements for staff in the agency's Education Resource Centers who are responsible for supporting and overseeing schools' special education programs, and ensure that staff complete those training requirements. (Recommendation 6)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency will ensure that special education training and professional development requirements are identified as part of its planned Strategic Workforce Plan update and expansion.

Recommendation: The Director of BIE should take steps to ensure that all of the agency's Education Resource Centers conduct outreach with schools to inform them of their new roles in overseeing and supporting schools' special education programs under BIE's reorganization. (Recommendation 7)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. As BIE makes targeted reforms to improve the delivery of special education services, it will ensure that the roles and responsibilities of Education Resource Centers (ERC) are clearly identified and communicated to responsible BIE personnel. Specifically, as it updates and expands the Strategic Workforce Plan, it will clearly and directly define the role of ERC personnel with respect to special education services. In addition, as the new Performance Office establishes timely and routine technical assistance plans, the agency will operationalize the day-to-day engagement and outreach between ERC and school level personnel regarding special education related technical assistance.

Recommendation: The Secretary of State should ensure that the Deputy Assistant Secretary for Defense Trade Controls, in consultation with university representatives, provides additional or revises existing guidance and outreach to address university-specific export control issues to further support universities' understanding and compliance with the International Traffic in Arms Regulations. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: The Department of State concurred with the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Commerce should ensure that the Under Secretary for Industry and Security, in consultation with university representatives, provides additional or revises existing guidance and outreach to address university-specific export control issues to further support universities' understanding and compliance with the Export Administration Regulations. (Recommendation 2)

Agency: Department of Commerce
Status: Open

Comments: The Department of Commerce concurred with the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of State should ensure that the Deputy Assistant Secretary for Defense Trade Controls revises existing export compliance guidelines to include information concerning periodic risk assessments to remind exporters that it is beneficial to periodically identify, analyze, and respond to new risks as part of an effective International Traffic in Arms Regulations compliance program. (Recommendation 3)

Agency: Department of State
Status: Open

Comments: The Department of State concurred with the recommendation. 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 ensure that the Under Secretary of Defense for Research and Engineering takes steps to ensure that its program officers and contracting officers are interpreting export controls consistent with regulations and guidance and consistently determining whether university research constitutes fundamental research. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense concurred with the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to, in coordination with the Office of Program Accountability and Risk Management, develop a risk-based approach for reviewing service requirements—through the Procurement Strategy Roadmap or other means—to ensure proposed service requirements are clearly defined and reviewed before planning how they are to be procured. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: DHS disagreed with our recommendation, preferring to maintain the status quo in its policy and procedures. However, by doing so, DHS is missing important opportunities to prevent negative acquisition outcomes and the potential for wasted resources. In its response, DHS noted its processes for major acquisitions, however, DHS service programs and contracts did not rise to the level of being classified a major service acquisition.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to document the factors the Office of the Chief Procurement Officer considers when waiving procurement actions from its Procurement Strategy Roadmap to ensure it is consistently considering potential acquisition risks in its planning—including those specific to services. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: DHS did not concur with this recommendation, maintaining that the factors considered when waiving a Procurement Strategy Roadmap are not static. We believe, however, that documenting the factors considered will help ensure that the decisions to waive the Procurement Strategy Roadmaps are made consistently, transparently, and help maintain institutional knowledge.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to update the Inherently Governmental and Critical Functions Analysis to require the identification of special interest functions. (Recommendation 3)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation and stated that it will update the Inherently Governmental and Critical Functions Analysis job aid to require the identification of a special interest function when applicable.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to update the Inherently Governmental and Critical Functions Analysis to provide guidance for analyzing, documenting, and updating the federal workforce needed to perform or oversee service contracts requiring heightened management attention. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: DHS did not concur with this recommendation maintaining that the components are certifying that they have sufficient internal capacity or federal employees available for oversight within the Inherently Governmental and Critical Functions Analysis. We continue to believe, however, that without guidance, each component is making its own determination about which factors to consider, and DHS does not know how or whether the components are considering the federal workforce available to oversee service contracts in need of heightened management attention, or what steps, if any, the components are taking to mitigate risks if there are not enough federal personnel available to oversee the contracts after award.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Procurement Officer to develop guidance identifying oversight tasks or safeguards personnel can perform, when needed, to mitigate the risk associated with contracts containing closely associated with inherently governmental functions, special interest functions, or critical functions. (Recommendation 5)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation and stated that it will develop guidance that identifies oversight tasks or safeguards that personnel can perform, when needed, to mitigate the risk associated with contracts containing closely associated with inherently governmental, special interest, or critical functions.

Recommendation: The Secretary of Homeland Security should direct the DHS Chief Financial Officer to work with Congress to identify information to include in its annual congressional budget justifications to provide greater transparency into requested and actual service requirement costs, particularly for those services requiring heightened management attention. (Recommendation 6)

Agency: Department of Homeland Security
Status: Open

Comments: DHS did not concur with this recommendation stating that its annual Congressional Budget Justification already contains substantial service contract information. We maintain, however, that the service contract information currently included limits visibility for both DHS and Congress into requested and actual service requirements costs.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA implements the planned initiative to routinely examine annual case reviews performed by DOD components to help ensure that fees collected into the FMS transportation accounts are accurate. (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 ensure that the Director of DSCA works with DFAS and DOD components to establish a written process to monitor the timeliness of components' delivery reporting to help ensure that fees collected into the FMS transportation accounts are accurate. (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 ensure that the Director of DSCA finalizes and implements internal guidance on how to conduct and document DSCA's monthly review of expenditures from the FMS transportation accounts, including what information should be reviewed and how to identify and follow up on discrepancies. (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 ensure that the Director of DSCA works with DFAS to finalize written guidance to DFAS on how to generate the reports needed for DSCA's monthly review of expenditures from the FMS transportation accounts, including the type of analysis needed. (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 ensure that the Director of DSCA works with DFAS and other DOD components to finalize the planned guidance to DFAS for the review and realignment of expenditures from the FMS transportation accounts to ensure reviews are consistent and include all expenditures. (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 Administrator of FEMA should assess different approaches, in addition to community assistance visits, for using existing resources to ensure communities' compliance with NFIP requirements. This should include analyzing alternatives to community assistance visits. (Recommendation 1)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

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

Recommendation: The Administrator of FEMA should identify appropriate steps to ensure it has complete, up-to-date, and reliable records of community assistance visits, including information on why some visit records remain open for a significant period of time. (Recommendation 2)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

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

Recommendation: The Administrator of FEMA should ensure that communities are consistently collecting data on their substantial damage assessments and that FEMA has a way to readily access those data to evaluate community compliance with NFIP requirements for rebuilding substantially damaged properties. (Recommendation 3)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

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

Recommendation: The Administrator of FEMA should clarify with NFIP communities its policies on sharing data on NFIP claims and provide such information to those communities as needed. (Recommendation 4)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open

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

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 Secretary of Defense should ensure that the DOD CIO takes appropriate steps to ensure implementation of the DC3I tasks. (Recommendation 1)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open
Priority recommendation

Comments: The Department of Defense partially concurred with this recommendation. 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 ensure that DOD components develop plans with scheduled completion dates to implement the four remaining CDIP tasks overseen by DOD CIO. (Recommendation 2)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open
Priority recommendation

Comments: The Department of Defense partially concurred with this recommendation. 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 ensure that the Deputy Secretary of Defense identifies a DOD component to oversee the implementation of the seven CDIP tasks not overseen by DOD CIO and report on progress implementing them. (Recommendation 3)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open
Priority recommendation

Comments: The Department of Defense did not concur with this recommendation. 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 ensure that DOD components accurately monitor and report information on the extent that users have completed the Cyber Awareness Challenge training as well as the number of users whose access to the network was revoked because they have not completed the training. (Recommendation 4)

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

Comments: The Department of Defense partially concurred with this recommendation. 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 ensure that the DOD CIO ensures all DOD components, including DARPA, require their users to take the Cyber Awareness Challenge training developed by DISA. (Recommendation 5)

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

Comments: The Department of Defense concurred with this recommendation. 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 a component to monitor the extent to which practices are implemented to protect the department's network from key cyberattack techniques. (Recommendation 6)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open
Priority recommendation

Comments: The Department of Defense did not concur with this recommendation. 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 ensure that the DOD CIO assesses the extent to which senior leaders' have more complete information to make risk-based decisions—and revise the recurring reports (or develop a new report) accordingly. Such information could include DOD's progress on implementing (a) cybersecurity practices identified in cyber hygiene initiatives and (b) cyber hygiene practices to protect DOD networks from key cyberattack techniques. (Recommendation 7)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open
Priority recommendation

Comments: The Department of Defense partially concurred with this recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Smithsonian should develop written guidance for supervisors specific to how to address complaints of sexual harassment filed under the management process—which may include updating current written guidance for supervisors on handling misconduct, such as the Supervisor's Compass and Smithsonian Directives 212 and 213 (Chapter 752). (Recommendation 1)

Agency: Smithsonian Institution
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 Smithsonian should establish a tracking mechanism for complaints of sexual harassment filed under the management process—including procedures for supervisors within the units to convey reports of sexual harassment to the central Smithsonian administration and/or OEEMA. (Recommendation 2)

Agency: Smithsonian Institution
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 Smithsonian should include affiliated persons in measures used to assess organizational climate at the Smithsonian—which may include incorporating affiliated persons into current efforts or developing additional measures specific to these persons. (Recommendation 3)

Agency: Smithsonian Institution
Status: Open

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

Recommendation: The TSA Administrator should update the BASE cybersecurity template to ensure it reflects cybersecurity key practices, including the Detect and Recover functions outlined in the NIST Cybersecurity Framework. (Recommendation 2)

Agency: Department of Homeland Security: Transportation Security Administration
Status: Open

Comments: TSA concurred with this recommendation and said it would take steps to implement it by updating the BASE Cybersecurity Security Action Item section to ensure it reflects the NIST Cybersecurity Framework Detect and Recover functions. When we confirm what actions TSA has taken in response to this recommendation, we will provide updated information.

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 Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments, provide updated guidance for the oversight of privatized military housing, to include oversight objectives for each service to monitor the physical condition of privatized homes over the remaining duration of the ground leases. (Recommendation 1)

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

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD (S)), as the Chief Housing Officer, issued guidance requiring the military departments to monitor work order completion for housing privatized under the Military Housing Privatization Initiative based on a combination of resident input, timeliness of work order completion, and number of repeat work orders for the same repair. The guidance also required increased tracking of MHPI project work orders by installation staff. Moving forward, the ASD(S) plans to issue quarterly program review guidance that establishes oversight objectives for the military departments to monitor the physical condition of MHPI housing over the duration of their project ground leases, formalizing the requirement that the data be monitored by the Chief Housing Officer. DOD expects this to be completed by December 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Army should take steps, in collaboration with the Army's private housing partners, to review the indicators underlying the privatized housing project performance metrics to ensure they provide an accurate reflection of the condition and quality of the homes. (Recommendation 2

Agency: Department of Defense: Department of the Army: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Secretary of the Army has taken several steps toward addressing this recommendation. For example, the Army published the Portfolio and Asset Management Handbook creating a multi-tiered assessment approach of performance metrics to measure the health of each privatized home through inspection, assessment, satisfaction, and feedback. The Army and the private housing partners revised the Incentive Fee Performance Management Plan, placing increased emphasis on resident satisfaction and work order/maintenance management. The Army also put Commanders in charge, ensuring Army leadership at every Army installation is tracking housing quality and safety. In late 2020, the Army plans to review and evaluate these actions and make a determination by 31 Jan 2021 if any changes or revisions are needed to best implement the recommendation. As such, we will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Air Force should take steps, in collaboration with the Air Force's private housing partners, to review the indicators underlying the privatized housing project performance metrics to ensure they provide an accurate reflection of the condition and quality of the homes. (Recommendation 3)

Agency: Department of Defense: Department of the Air Force: Office of the Secretary of the Air Force
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Air Force is engaging in several steps to address this recommendation. Specifically, in March 2020, the Air Force tasked each of the Military Housing Offices to inspect all move-in, move-out, and change of occupancy maintenance events and all emergency, urgent, and life, health, and safety work orders, which is outlined in Air Force guidance. The Air Force is also engaging in several ongoing actions. In response to a memo to the military departments to provide consistency of performance incentive fees, the Air Force was negotiating with the privatized housing project owners to update performance incentive fee metrics in accordance with ASD directed categories and weightings. As of August 2020, agreements had been finalized with 2 partners and work was ongoing with the remaining partners. In addition, the Air Force was working with the project owners to deploy Satisfacts, a survey tool to independently measure resident satisfaction with projects' work order performance, across all Air Force projects with an expected completion by December 2020. We will continue to monitor the status of these recommendations.

Recommendation: The Secretary of the Navy should take steps, in collaboration with the Navy and Marine Corps' private housing partners, to review the indicators underlying the privatized housing project performance metrics to ensure they provide an accurate reflection of the condition and quality of the homes. (Recommendation 4)

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

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Navy and Marine Corps are engaging in several steps to address this recommendation. Specifically, the Navy and Marine Corps have developed a centralized electronic data warehouse, which receives data from privatized housing partner maintenance systems to display work order and survey performance dashboards. By February 2021, the Navy expects to complete the development of metrics displayed by the data warehouse to include key service call performance metrics and resident feedback data. The Navy and Marine Corps are also developing a web-based monitoring matrix tool housing officials can use to evaluate the performance of privatized housing partners. The tool is intended to provide improved tracking capabilities and improved accessibility to information, thus providing more consistent oversight and improved advocacy service members and their families. The Navy is also working to hire 247 additional Navy and Marine Corps housing staff to review and analyze private partner provided recurring maintenance and customer satisfaction reports in an effort to strengthen oversight and monitoring, with an estimated completion of September 2020. Moving forward, we will continue to monitor the status of these and other efforts.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments and private housing partners, establish minimum data requirements and consistent terminology and practices for work order data collection for comparability across installations and projects and to track trends over time. (Recommendation 5)

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

Comments: e Department of Defense (DOD) partially concurred with this recommendation. In its August 2020 response, DOD stated that the Assistant Secretary of Defense for Sustainment (ASD(S)), as the Chief Housing Officer, plans to issue a policy directing the military departments to establish, to the maximum extent practical, minimum data requirements and consistent terminology and practices for MHPI housing unit work order collection to aid in comparability across installations and projects, and for tracking trends over time. However, DOD noted that the department cannot mandate changes to existing MHPI project legal documents. DOD estimates that this effort will be completed by December 2021. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment require the military departments to establish a process to validate data collected by the private housing partners to better ensure the reliability and validity of work order data and to allow for more effective use of these data for monitoring and tracking purposes. (Recommendation 6)

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

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD(S)), as the Chief Housing Officer, issued guidance directing the military departments to exercise proper oversight to ensure Military Housing Privatization Initiative (MHPI) projects perform in accordance with legal agreements, to include due diligence in monitoring and auditing project maintenance records and other project performance data. The guidance also required military departments to review their entire portfolios of MHPI projects to ensure accurate and appropriate work order management processes. In response to the new guidance, DOD noted that the military departments put in place appropriate oversight measures and undertook the required reviews, though the investigations of project business practices were ongoing in some cases. As another step, the ASD(S) plans to issue guidance directing the military departments to establish a process to validate data collected by their respective MHPI Project Owners to better ensure the reliability and validity of work order data and to allow for more effective use of these data for monitoring and tracking purposes. DOD expects this to be completed by the end of September 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments, develop a process for collecting and calculating resident satisfaction data from the military departments to ensure that the data are compiled and calculated in a standardized and accurate way. (Recommendation 7)

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

Comments: The Department of Defense (DOD) partially concurred with this recommendation based on the fact that the draft report listed the incorrect office as the source for addressing the deficiency, but subsequently changed its response to concur after the recommendation was directed to the appropriate office in the final report. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD(S)) plans to issue guidance establishing a department-wide process for collecting and calculating resident satisfaction data to ensure that the data are compiled and calculated in a standardized and accurate way effective with the survey collection effort in Fiscal Year 2021. The department expects this effort to be completed by October 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure the Assistant Secretary of Defense for Sustainment provides additional explanation of the data collected and reported in future reports to Congress, such as explaining the limitations of available survey data, how resident satisfaction was calculated, and reasons for any missing data, among other things. (Recommendation 8)

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

Comments: The Department of Defense (DOD) partially concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD(S)) would provide additional explanation of the MHPI resident satisfaction data collected and reported in future annual Military Housing Privatization Initiative (MHPI) reports to Congress, effective with the annual report covering fiscal year 2019. DOD noted that the additional information will include, among other things, an explanation of the limitations of available survey data, how resident satisfaction was calculated, and reasons for any missing data. As of August 2020, the annual MHPI report covering fiscal year 2018 was in final coordination and the department noted that the report would addresses a vast majority, but not all, of the requirements identified in our recommendation. DOD noted that the additional information would be provided in the next annual MHPI report. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Army should develop and implement a plan to clearly and systematically communicate to residents the difference between the military housing office and the private partner. At a minimum, these plans should include the Army housing office's roles, responsibilities, locations, and contact information and should ensure that all residents are aware that they can directly contact Army housing office officials. (Recommendation 9)

Agency: Department of Defense: Department of the Army: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its response, DOD noted that the Army developed a "Plain Language" briefing as required by the 2020 National Defense Authorization Act that included the Army Housing Office's roles, responsibilities, location, and contact information at each privatized housing project site. DOD noted that the intent of the briefing was to ensure that all residents were aware of their ability to directly contact Army Housing Office and/or the Garrison Commanders. DOD stated that the briefing was disseminated to all of the Military Housing Offices, who are using it in newcomer briefings, and stated that the briefing would be provided to all current residents of privatized military housing, but that measure would not be tracked due to attrition. In addition, DOD noted that Headquarters, Department of the Army was tasking Army Materiel Command to develop a more detailed plan to communicate to residents the difference between the Army Housing Office and the private housing partner. The Army's intent is to not only capture residents upon their arrival at an installation, but making the services of the MHO known over the duration of a resident's time on at installation. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Navy should develop and implement a plan to clearly and systematically communicate to residents the difference between the military housing office and the private partner. At a minimum, these plans should include the Navy housing office's roles, responsibilities, locations, and contact information and should ensure that all residents are aware that they can directly contact Navy housing office officials. (Recommendation 11)

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

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Navy has taken various steps to address this recommendation, with additional steps planned. For example, the Navy has ensured that each installation has a specific issue resolution process description marketing flyer available, both in hard copy and on the public housing websites, with a reminder that residents can contact both the privatized housing property manager and the Navy housing office with any issues. Moreover, every housing unit has been provided with a refrigerator magnet reminding residents that they can and should contact the Navy housing office if they have any issues with their home. In addition, the Navy and Marine Corps have established a requirement to contact each privatized housing resident not later than 15 days after move-in and again 60 days after move-in to provide an opportunity to request assistance and remind them of available support. Moving forward, the Navy has an ongoing effort to require private housing companies to market the same messaging as the service issue resolution processes for the MHOs that they support, for consistent advocacy messaging to the tenants. The information will be added to PPV partner websites, printed material and resident handbooks. The Navy also plans to use its annual survey to tracks resident satisfaction and awareness of the Navy's issue resolution process, with expected completion by October 2020. In addition, the Marine Corps has identified a near-term initiative to procure name tags for all MHO employees to wear, identifying themselves as distinct and separate from privatized housing property management company, which will be standardized across all USMC installations. The Marine Corps also plans to develop a standard welcome aboard package to include magnets and other items with key point of contact information. The Marine Corps expects these efforts to be completed by the end of September 2020.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments, assess the risks of proposed initiatives aimed at improving the privatized military housing program on the financial viability of the projects. (Recommendation 12)

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

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment, as the Chief Housing Officer, planned to issue a policy establishing the assessment of Military Housing Privatization Initiative (MHPI) project financial viability as part of quarterly program reviews as a long-term requirement. The department noted that the program review data would be augmented by input from the MHPI companies, who are assessing the likely impact of proposed initiatives in conjunction with their third party lenders. The department expected this effort to be completed by December 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Administrator of CMS should take steps to obtain quality information on the experiences of dual-eligible beneficiaries who have been default enrolled into D-SNPs, such as by obtaining information about the extent to which and reasons that beneficiaries disenroll from a D-SNP after being default enrolled. (Recommendation 1)

Agency: Department of Health and Human Services: Centers for Medicare and Medicaid Services
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 State should direct the Assistant Secretary for International Security and Nonproliferation to include additional information about the expenditures it considers in its NEA-mandated reporting for Executive Order 12938.

Agency: Department of State: Office of the Secretary
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 for Research and Engineering should direct the Laboratories and Personnel Office to take steps to ensure that the details of the pilot program's data protections are incorporated into the existing agreements. (Recommendation 1)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will require the Primary Sponsor for each applicable federally funded research and development center (FFRDC) to provide documentation that shows that the details of the pilot program's data protections have been incorporated into existing sponsoring agreements and contracts, and estimated these actions would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to take steps to ensure that the FFRDCs and sponsors are implementing the pilot program's protections for sensitive data. (Recommendation 2)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will task the Primary Sponsor for each applicable federally funded research and development center (FFRDC) to provide a report detailing the FFRDC's plan for implementing the pilot program's protections for sensitive data and confirming that the FFRDC is adhering to that plan. OUSD(R&E)/L&PO estimated these actions would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to establish a monitoring and oversight mechanism to ensure that primary sponsors submit complete information on pilot projects, as required by DOD's guidance for the pilot program. (Recommendation 3)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will develop a monitoring and oversight plan, and estimated it would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to develop a plan that outlines the methodology by which DOD will assess the pilot and how and when information collected will be analyzed to evaluate the pilot program. (Recommendation 4)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will develop and coordinate a plan that outlines the methodology by which DOD will assess the pilot as well as the methodology for collecting and analyzing information to evaluate the pilot program. OUSD(R&E)/L&PO estimated these actions would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to develop a plan to identify and evaluate lessons learned from the pilot program. (Recommendation 5)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will develop a plan to identify and evaluate lessons learned from the pilot program, and estimated the plan would be completed in early Fall 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should direct the Laboratories and Personnel Office to develop a plan for obtaining input from stakeholders on the pilot program. (Recommendation 6)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: The Under Secretary of Defense for Research and Engineering (OUSD(R&E)), Laboratories and Personnel Office (L&PO) concurred with this recommendation. In May 2020, OUSD(R&E)/L&PO stated it will develop a plan to obtain stakeholder inputs for use in evaluating the pilot program, and estimated the plan would be completed in early Fall 2020.

Recommendation: The Director of OCC should establish internal written policies to effectively implement and document the State Plan review and approval process for future review and approval periods. (Recommendation 1)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of the Child Care Bureau
Status: Open

Comments: In September 2020, OCC told us it has been working on establishing written policies (e.g., internal guidance documents and checklists) to implement and document the State Plan review and approval process. OCC expects to complete this work for the FY2022-2024 Plan period. We will continue to monitor OCC's efforts to implement this recommendation.

Recommendation: The Director of OCC should define the informational needs related to the results of program-integrity activities. (Recommendation 2)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of the Child Care Bureau
Status: Open

Comments: In September 2020, OCC told us that it is developing the next CCDF State/Territory Plan Preprint due for submission by states and territories July 1, 2021. According to OCC, it plans to incorporate its information needs regarding the results of program integrity into the Preprint document as it develops the document. We will continue to monitor OCC's progress in implementing this recommendation.

Recommendation: The Director of OCC should communicate externally to the states its informational needs related to the results of states' program-integrity activities. (Recommendation 3)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of the Child Care Bureau
Status: Open

Comments: In September 2020, OCC told us that it is developing the next CCDF State/Territory Plan Preprint due for submission by states and territories July 1, 2021. According to OCC, it plans to communicate its information needs regarding the results of program integrity activities to states and territories as part of the Preprint Training activities - including webinars and peer-to-peer virtual meetings - so Lead Agencies understand what is expected for them to address in the CCDF Plan. We will continue to monitor OCC's progress in implementing this recommendation.

Recommendation: The Director of OCC should communicate internally to staff its informational needs related to the results of states' program-integrity activities. (Recommendation 4)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of the Child Care Bureau
Status: Open

Comments: In September 2020, OCC told us that it is developing the next CCDF State/Territory Plan Preprint due for submission by states and territories July 1, 2021. According to OCC, it plans to communicate its information needs regarding the results of program integrity activities to staff in both regional and central offices as part of the Preprint Training activities so staff understand what is expected for Lead Agencies to address in the CCDF Plan. We will continue to monitor OCC's progress in implementing this recommendation.

Recommendation: The Director of OCC should develop documented criteria to guide the review of CAPs submitted by states to ensure that proposed corrective actions are aimed at root causes of improper payments and are effectively implemented. (Recommendation 5)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of the Child Care Bureau
Status: Open

Comments: In September 2020, OCC told us it revised the CAP Review Tool to in response to our recommendation. OCC also told us that it plans to implement the revised CAP Review Tool beginning September 2020 to document the review of CAPs submitted for the most recent ACF-404 reporting cycle (June 2020). We asked OCC to provide documentation showing the revised CAP Review Tool is responsive to our recommendation. We will update this recommendation status after reviewing the documentation OCC provides.

Recommendation: The Director of OCC should timely complete its effort to develop established written policies for the CAP follow-up process to ensure that OCC's oversight and monitoring of CAPs is carried out consistently. (Recommendation 6)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of the Child Care Bureau
Status: Open

Comments: In September 2020, OCC told us it developed draft written policies for the CAP follow-up process to ensure that OCC's oversight and monitoring of CAPs is carried out consistently. However, due to the impact of the COVID-19 on staffing capacity, OCC has not presented the draft policies to regional offices for feedback. OCC told us it plans to finalize the written policies for the CAP follow-up process by December 2020. We will continue to monitor OCC's progress in implementing this recommendation.

Recommendation: The Director of OCC should develop and document criteria to assess the effectiveness of states' program-integrity control activities. (Recommendation 7)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of the Child Care Bureau
Status: Open

Comments: In September 2020, OCC told us it analyzed information gathered from federal and state resources to develop and document criteria to be used to assess the effectiveness of states' program integrity control activities. We asked OCC to provide us the document showing all criteria to be used to assess the effectiveness of states' program integrity control activities. We will update this recommendation status after reviewing the documentation OCC provides.

Recommendation: The Director of OCC should evaluate the feasibility of collecting information from the Grantee Internal Controls Self-Assessment Instrument (Self-Assessment Instrument) and Fraud Toolkit, such as during its Monitoring System process, to monitor the effectiveness of states' program-integrity control activities. (Recommendation 8)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of the Child Care Bureau
Status: Open

Comments: In September 2020, OCC told us it is working to make the Self-Assessment Instrument and Fraud Toolkit more user-friendly to encourage increased use within the state CCDF program. With increased usage, OCC believes it will be in a better position to assess how the collection of data from these two instruments can be incorporated into the Onsite Monitoring System or other oversight activity. OCC told us it anticipates completing work to implement this recommendation by December 2020. We will continue to monitor OCC's progress in implementing this recommendation.

Recommendation: The Assistant Secretary for ACF should ensure that ACF conducts a fraud risk assessment to provide a basis for the documentation and development of an antifraud strategy that describes the CCDF program's approach to address prioritizing fraud risks identified. (Recommendation 9)

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

Comments: In September 2020, HHS told us it anticipates completing the initial fraud risk assessment for the CCDF program by December 2020. We will continue to monitor HHS's efforts to implement this recommendation.

Recommendation: The Commandant of the Coast Guard should establish a systematic mechanism to track implementation and measure the Coast Guard's progress in achieving organizational change goals. (Recommendation 1)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: The Coast Guard concurred with this recommendation and said it would establish a policy requiring that requests to change organizational structure include a plan, and establish a mechanism to track implementation and measure progress in achieving organizational change goals. The Coast Guard stated that this will be completed by December 31, 2020.

Recommendation: The Commandant of the Coast Guard should establish a mechanism to periodically seek and monitor employee satisfaction with organizational change efforts. (Recommendation 2)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: The Coast Guard concurred with this recommendation and agreed that mechanisms to periodically seek and monitor employee satisfaction with organizational change efforts are valuable. However, they stated that their current feedback mechanisms capture this information therefore they requested we close the recommendation. The Coast Guard also stated its preference to add questions to existing surveys rather than create new survey instruments. However, we found that the Coast Guard's current surveys do not capture employee's perspectives as organizational changes are implemented. This recommendation remains open pending Coast Guard providing evidence of its actions to modify existing surveys with added questions that monitor employee satisfaction with organizational changes.

Recommendation: The Commandant of the Coast Guard should update its Manpower Requirements Manual with guidance for how to execute its manpower requirements determination process, and take steps to ensure the process is implemented. (Recommendation 3)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: The Coast Guard concurred with this recommendation and said it would develop a Tactics, Techniques and Procedures document to provide guidance for executing the manpower requirements determination process. This would provide additional guidance on the overall manpower requirements determination process, including explicit directions for the collection and analysis of manpower data, and the establishment of enterprise standards for key factors and allowances used when conducting analysis. The Coast Guard stated that this will be completed by September 30, 2020.

Recommendation: The Commandant of the Coast Guard should track and document the extent to which it has completed manpower requirements analyses and determinations for each unit type. (Recommendation 4)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: The Coast Guard concurred with this recommendation and said it would initiate the process to document and track Manpower Requirements in the Coast Guard's human resources system. The Coast Guard stated that this would be completed by December 31, 2020.

Recommendation: The Commandant of the Coast Guard should update its April 2018 Manpower Requirements Plan to include time frames and milestones for completing manpower requirements analyses and determinations for all positions and units. (Recommendation 5)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: The Coast Guard concurred with this recommendation and said it would update its Manpower Requirements Plan during the next required periodic report submitted to Congress, in fiscal year 2022. The Coast Guard stated that this would be completed by March 31, 2022.

Recommendation: The Commandant of the Coast Guard should determine the resources its manpower requirements determination program needs, both staff and funding, to achieve its goal of completing manpower requirements determinations for all positions and units. (Recommendation 6)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: The Coast Guard concurred with this recommendation and said it would review its 2010 manpower requirements analysis that determined the resources the Coast Guard required for its manpower requirements determination program. Its Office of Human Resources Strategy and Capability will then re-validate the inputs and update the findings for the manpower requirements analysis to reflect the currents needs of the manpower requirements determination program. The Coast Guard stated that this will be completed by September 30, 2020.

Recommendation: The Chief Counsel of the Internal Revenue Service, in coordination with appropriate offices, should identify and document parameters and procedures for applying enhanced collaborative approaches to regulation and other guidance development with IRS Business Operating Divisions. (Recommendation 1)

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

Comments: As of August 2020, IRS disagrees with this recommendation and does not plan to take action on it. IRS officials said their Chief Counsel Directives Manual provides sufficient guidance and flexibility to allow for enhanced collaboration when appropriate. However, officials acknowledged that this collaboration was particularly helpful in implementing TCJA provisions and greatly contributed to IRS's successful implementation. By implementing this recommendation, IRS can help ensure that institutional knowledge and beneficial practices from TCJA implementation will be documented and effectively leveraged to support implementation of future time-sensitive or complex tax law changes without restricting IRS's flexibility. Documenting procedures would ensure IRS can retain organizational knowledge and mitigate the risk of having that knowledge limited to a few personnel.

Recommendation: The Commissioner of Internal Revenue should develop a process to accurately and thoroughly capture implementation status of ongoing projects in accordance with Standards for Internal Control in the Federal Government. (Recommendation 2)

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

Comments: As of August 2020, IRS disagrees with this recommendation and does not plan to take action on it. IRS officials acknowledged inconsistencies in reports but said these inconsistencies were not detrimental to overall implementation. We maintain that accurately and thoroughly capturing implementation status on ongoing projects would provide accurate information to decision makers and could prevent potential misreporting, mismanagement, or inefficient resource investment in the future.

Recommendation: The Commissioner of Small Business/Self Employed should coordinate with appropriate IRS divisions or offices to identify the costs and benefits of retroactively transcribing taxpayer data resulting from TCJA. (Recommendation 3)

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

Comments: As of August 2020, IRS disagrees with this recommendation and does not plan to take action on it. IRS officials said the retroactive transcription of TCJA returns would be a time intensive activity with significant opportunity costs, and that the benefits of retroactive transcription are currently not quantifiable. A high-level analysis of costs and benefits could help IRS management determine what, if any, data would benefit compliance and enforcement efforts. IRS could use readily available existing information (such as the number of returns affected by a certain provision, LB&I and IT cost data on conversion efforts already implemented, or the usefulness of past compliance analytics in similar areas) to inform the analysis. For example, IRS staff are manually reviewing certain forms associated with one TCJA provision for compliance purposes and IRS could use information from this effort (e.g., amount of time and any compliance results) to inform a high-level estimate of costs and benefits.

Recommendation: Based on the costs and benefits identified in recommendation 3, the Commissioner of Small Business/Self Employed should determine which TCJA provisions' data should be converted into a more useful electronic format for compliance and enforcement purposes and work with the appropriate offices to obtain the transcribed data, as appropriate. (Recommendation 4)

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

Comments: As of August 2020, IRS disagrees with this recommendation and does not plan to take action on it. IRS officials said that implementing this recommendation would require identifying the costs and benefits, which they do not plan to take action on. However, IRS officials acknowledged that IRS operating divisions and offices make strategic decisions regarding how best to use TCJA-related return data for compliance and enforcement purposes. We believe that converting data in instances where the benefits outweigh the costs would better position IRS to more effectively and efficiently pursue its mission of ensuring taxpayer compliance. For example, in the case of one TJCA provision, because IRS is not collecting information in an easily accessible format, IRS staff are manually reviewing forms to help with compliance efforts.

Recommendation: The Assistant Secretary of Tax Policy should update Treasury's internal guidance to ensure that Treasury's regulatory impact analyses include examination of the distributional effects of revenue changes when regulations influence tax liability. (Recommendation 5)

Agency: Department of the Treasury: Office of the Assistant Secretary of the Treasury (Tax Policy)
Status: Open

Comments: As of August 2020, Treasury disagrees with this recommendation and does not plan to take action on it. Treasury officials said the analyses underlying Treasury's tax regulations have fully complied with the Memorandum of Agreement established with the U.S. Office of Management and Budget (OMB), which focuses on non-revenue effects. We maintain that decisions Treasury and IRS made when developing regulations to implement TCJA could potentially impact tax liability by billions of dollars per year; however, Treasury's internal guidance dictates that these revenue effects should not be included in its economic analyses of the regulations. In some regulations, Treasury has addressed revenue effects in its analyses, but this has not been done consistently. By adjusting its internal guidance to ensure that distributional effects of revenue changes are consistently reflected in its analyses, it would better inform the regulatory decision-making process, while also providing the public with greater transparency.

Recommendation: The Director of the Office of Workers' Compensation Programs should develop and implement procedures for coal mine operator self-insurance renewal that clarifies how long an operator is authorized to self-insure; when an operator must submit its renewal application and supporting documentation; and the conditions under which an operator's self-insurance authority would not be renewed. (Recommendation 1)

Agency: Department of Labor: Office of Workers' Compensation Programs
Status: Open

Comments: DOL agreed with this recommendation and said it is acting to implement it to achieve further improvements in ensuring the effective oversight of coal mine operator insurance. DOL reported that it would ensure letters granting or renewing self-insurance authority will inform operators that their authorization expires in one year and that they must submit renewal information three months in advance of the expiration date.

Recommendation: The Director of the Office of Workers' Compensation Programs should develop and implement procedures for self-insured coal mine operator appeals that identify time lines for self-insured operators to submit documentation supporting their appeals and that identify a goal for how much time DOL should take to make appeals decisions. (Recommendation 2)

Agency: Department of Labor: Office of Workers' Compensation Programs
Status: Open

Comments: DOL agreed with this recommendation and said it is acting to implement it to achieve further improvements in ensuring the effective oversight of coal mine operator insurance. DOL reported that it will ensure letters denying self-insurance will inform operators that they have a 30-day appeal period (limited to one extension) and that DOL has set a goal of resolving all appeals within 90 days of the denial letter.

Recommendation: The Director of the Office of Workers' Compensation Programs should develop and implement a process to monitor operator compliance with commercial insurance requirements and periodically evaluate the effectiveness of this process. This process should be designed to detect errors and omissions in reporting insurance coverage using complete, accurate, and consistently recorded data. (Recommendation 3)

Agency: Department of Labor: Office of Workers' Compensation Programs
Status: Open

Comments: DOL agreed with this recommendation and said it is acting to implement it to achieve further improvements in ensuring the effective oversight of coal mine operator insurance. DOL reported that it will modify existing computer systems to identify lapses or cancellations of commercial insurance coverage, and require operators identified as having lapsed or cancelled coverage to obtain or provide proof of coverage within 30 days.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Chairman of the Joint Chiefs of Staff and the Secretary of the Navy, determine whether it can assign the required number of Navy officers to the other military departments' JPME programs, consistent with Chairman of the Joint Chiefs of Staff guidance. (Recommendation 1)

Agency: Department of Defense: Office of the Secretary 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 ensure that the Chairman of the Joint Chiefs of Staff, in coordination with the Under Secretary of Defense for Personnel and Readiness and the military services, develop policy concerning actions, if any, the military services can take to mitigate JPME seminar student mix shortfalls and still meet the intent of the OPMEP's joint acculturation requirement. (Recommendation 2)

Agency: Department of Defense: Office of the Secretary 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 ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Chairman of the Chiefs of Staff, develop and issue a department-wide mission statement for PME that will explain the program's purpose and goals, and serve as a basis for performance measures. (Recommendation 3)

Agency: Department of Defense: Office of the Secretary 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 ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Chairman of the Joint Chiefs of Staff, issue and implement performance measures—to include the tracking of costs—that align with the department-wide mission statement for PME. (Recommendation 4)

Agency: Department of Defense: Office of the Secretary 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 ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Chairman of the Joint Chiefs of Staff, require the military services to periodically report information to its office about the military services' PME and JPME programs—such as results of program reviews. (Recommendation 5)

Agency: Department of Defense: Office of the Secretary 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 ensure that the Under Secretary of Defense(Comptroller) updates the DOD Financial Management Regulation to require the Marine Corps to include a budget request data exhibit for the Marine Corps War College in support of DOD's annual budget request. (Recommendation 6)

Agency: Department of Defense: Office of the Secretary 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 ensure that the Under Secretary of Defense (Comptroller), in coordination with the military services and the Chairman of the Joint Chiefs of Staff, issue guidance to standardize the cost data that the military services should include in their annual PME budget request data submissions. (Recommendation 7)

Agency: Department of Defense: Office of the Secretary 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 Director of the U.S. Marshals Service should take steps to ensure that supervisory review of division and district investigations is documented in accordance with USMS policy. (Recommendation 1)

Agency: Department of Justice: United States Marshals Service
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 ATF should develop policy for verifying the accuracy and completeness of information in ATF employee misconduct systems. (Recommendation 2)

Agency: Department of Justice: Bureau of Alcohol, Tobacco, Firearms and Explosives
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 the U.S. Marshals Service should develop policy for verifying the accuracy and completeness of information in USMS employee misconduct systems. (Recommendation 3)

Agency: Department of Justice: United States Marshals Service
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 ATF should develop a performance measure to monitor the timeliness of misconduct investigations, according to policy requirements. (Recommendation 4)

Agency: Department of Justice: Bureau of Alcohol, Tobacco, Firearms and Explosives
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 the U.S. Marshals Service should develop a performance measure to monitor the timeliness of district and division misconduct investigations, according to policy requirements. (Recommendation 5)

Agency: Department of Justice: United States Marshals Service
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 ATF should modify existing oversight mechanisms to include the monitoring of key internal controls related to employee misconduct investigations. (Recommendation 6)

Agency: Department of Justice: Bureau of Alcohol, Tobacco, Firearms and Explosives
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 the U.S. Marshals Service should modify existing oversight mechanisms to fully monitor key internal controls related to employee misconduct investigations. (Recommendation 7)

Agency: Department of Justice: United States Marshals Service
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 Agriculture should direct Departmental Administration to work with the mission areas to develop department-level outcome-oriented performance goals and related measures for the business centers, and use them to assess the effectiveness and impact of the business center reforms. (Recommendation 1)

Agency: Department of Agriculture
Status: Open

Comments: In January 2020, USDA officials agreed with our recommendation and stated that the department is evaluating options for the development of performance metrics and inclusion of these metrics and related information as part of the regular and recurring reviews by the department's Deputy Secretary who is identified as the Chief Operating Officer.

Recommendation: The Chairman of the NMB should document NMB's authorizations for its use of cloud services approved through FedRAMP and submit the authorizations to the FedRAMP Program Management Office. (Recommendation 1)

Agency: National Mediation Board
Status: Open

Comments: NMB agreed with this recommendation and said it would take action to address it, completing these actions by the end of fiscal year 2020.

Recommendation: The Chairman of the NMB should update NMB's security policies and procedures to include FedRAMP's authorization requirements. (Recommendation 2)

Agency: National Mediation Board
Status: Open

Comments: NMB agreed with this recommendation and said it would take action to address it, completing these actions by the end of fiscal year 2020.

Recommendation: The Chairman of the NMB should develop a written plan to document NMB's process for reviewing and monitoring the agency's annual appropriation to ensure that funds are used effectively. (Recommendation 3)

Agency: National Mediation Board
Status: Open

Comments: NMB agreed with this recommendation. Agency officials said they would take action to address it, but did not provide a time frame for completion.

Recommendation: The Chairman of the NMB should establish a process for the Board to effectively monitor and evaluate NMB's adherence to audit protocols and implementation of actions to address audit recommendations. (Recommendation 4)

Agency: National Mediation Board
Status: Open

Comments: NMB agreed with this recommendation. Agency officials said they would take action to address it, but did not provide a time frame for completion.

Recommendation: The TSA Administrator should direct T&D and Security Operations to monitor for instances of TSO non-compliance by individual commercial airports across fiscal years that could potentially warrant corrective action at the headquarters level. (Recommendation 2)

Agency: Department of Homeland Security: Transportation Security Administration
Status: Open

Comments: In January 2020, TSA's formal comment letter in response to our draft report stated that T&D will begin recording instances of noncompliance and work with Security Operations to monitor trends at individual airports and with specific courses. TSA also reported that T&D had developed a repository in its iShare database for this information at the end of 2019 and the agency is currently testing various options for reporting and pulling data. Once options are chosen and incorporated into its standard operating procedures, TSA reports that T&D will begin sharing the reports with Security Operations on a monthly basis. In July 2020, TSA officials told us that T&D had begun sharing training compliance reports from their database with Security Operations and discussing the results with them on a monthly basis. This database allows T&D to recognize trends at individual airports and specific courses throughout the fiscal year. Going forward, this process will enable T&D to identify noncompliance trends across fiscal years. We will continue to montior these efforts to verify that the T&D is montioring trends across fiscal years and work with TSA towards closure of this recommendation.

Recommendation: The Commissioner of Internal Revenue should update the FAQs issued in 2019 to include a statement that the FAQs may serve as a source of general information but cannot be relied upon by taxpayers as authoritative since they are not binding on IRS. (Recommendation 1)

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

Comments: IRS disagreed with this recommendation. In an August 2020 letter, IRS stated that the 2019 currency FAQs are illustrative of how longstanding tax principles apply to property transaction and IRS does not take positions contrary to public FAQs. However, if IRS intends the public FAQs on virtual currency to be binding on IRS it could address our recommendation by publishing the FAQs in the Internal Revenue Bulletin. Doing so would render a disclaimer statement unnecessary and would satisfy the intent of the recommendation. We will continue to follow up with IRS on this recommendation and will provide an update if IRS takes action.

Recommendation: The Commissioner of Internal Revenue should take steps to increase third-party reporting on taxable transactions involving virtual currency, which could include clarifying IRS's interpretation of existing third-party reporting requirements under the Internal Revenue Code and Treasury Regulations, or pursuing statutory or regulatory changes. (Recommendation 2)

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

Comments: IRS agreed with this recommendation. In August 2020, IRS informed us that IRS's Office of Chief Counsel and the Department of the Treasury are developing guidance that will address third-party reporting on certain taxable transactions involving virtual currency. IRS expects that this guidance will also propose rules to avoid duplicate reporting under other information reporting regimes that may apply to transactions involving virtual currency. We will continue to monitor IRS's efforts to increase third-party reporting on taxable transactions involving virtual currency.

Recommendation: The Commissioner of Internal Revenue should clarify the application of reporting requirements under FATCA to virtual currency. (Recommendation 3)

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

Comments: IRS disagreed with this recommendation. In an August 2020 letter, IRS said it intends to focus on developing guidance regarding information reporting on certain virtual currency transactions involving U.S. businesses instead of clarifying the application of reporting requirements under FATCA to virtual currency. IRS stated that additional guidance on FATCA requirements may be appropriate in the future as the workings of foreign virtual currency exchanges become more transparent over time. We found that many virtual currency stakeholders were uncertain about how, if at all, FATCA requirements apply to virtual currency and would benefit from clarifications to the guidance. We will continue to follow up with IRS on this recommendation and will provide an update if IRS takes action.

Recommendation: The Director of FinCEN, in coordination with IRS as appropriate, should make a statement about the application of foreign account reporting requirements under the Bank Secrecy Act to virtual currency readily available to the public. (Recommendation 4)

Agency: Department of the Treasury: Financial Crimes Enforcement Network
Status: Open

Comments: FinCEN agreed with this recommendation. When we can confirm that FinCEN has taken action we will provide updated information.

Recommendation: The Executive Director should ensure the development and implementation of policies and procedures for incorporating key cybersecurity activities into IT project planning, including scheduling, requirements management, and risk management. (Recommendation 1)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: In January 2020, OCWR noted that it was in the process of revising its IT systems project planning to ensure the development and implementation of policies and procedure incorporating key cybersecurity activities. The agency also stated that it plans to hire an IT Security Project Manager in order to acquire the necessary cybersecurity expertise needed to implement this recommendation and to ensure that sufficient time and resources can be dedicated to the development and implementation of these policies and procedures. We will continue to monitor OCWR's progress in addressing this recommendation.

Recommendation: The Executive Director should ensure the development and implementation of oversight procedures for each externally-operated system that include (1) establishing security and privacy requirements, (2) planning the assessment of security controls, (3) conducting the assessment, and, (4) reviewing the assessment. (Recommendation 2)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: In January 2020, OCWR noted that it was beginning to plan for developing and implementing oversight procedures for each externally-operated system. We will continue to monitor OCWR's progress in addressing this recommendation.

Recommendation: The Executive Director should ensure the establishment of roles and responsibilities for a risk executive function. (Recommendation 3)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: In January 2020, OCWR noted that it had expanded the office's IT Director's role to formally include the functions of an IT Risk Executive and was in the process of establishing the roles and responsibilities. We will continue to monitor OCWR's progress in addressing this recommendation.

Recommendation: The Executive Director should ensure the development and implementation of a cybersecurity risk management strategy. (Recommendation 4)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: In January 2020, OCWR noted that it was beginning to plan for developing and implementing a cybersecurity risk management strategy. We will continue to monitor OCWR's progress in addressing this recommendation.

Recommendation: The Executive Director should ensure commitment to a time frame for developing and implementing policies and procedures for managing cybersecurity risk. (Recommendation 5)

Agency: Office of Congressional Workplace Rights
Status: Open

Comments: In January 2020, OCWR noted that, once the position of IT Security Project Manager is filled and the IT Risk Executive functions are formalized, the agency is planning to commit to a time frame for developing and implementing policies and procedures for managing cybersecurity risk. We will continue to monitor OCWR's progress in addressing this recommendation

Recommendation: The Secretary of Homeland Security should develop a strategy to independently validate selected agencies' self-reported actions on meeting binding operational directive requirements, where feasible, using a risk-based approach. (Recommendation 2)

Agency: Department of Homeland Security: Office of the Secretary
Status: Open

Comments: DHS has drafted a preliminary strategy to independently validate agencies' actions, using a risk-based approach. However, this strategy has not yet been finalized and needs to more clearly align to the existing directive development process, to which it serves as an addendum. The strategy should include when and how primary and secondary sources of information for independent validation are selected within the directive development process.

Recommendation: The Secretary of Homeland Security should develop a schedule and plan for completing the high value asset program reassessment and addressing the outstanding issues on completing the required high value asset assessments, identifying needed resources, and finalizing guidance for Tier 2 and 3 HVA systems. (Recommendation 4)

Agency: Department of Homeland Security: Office of the Secretary
Status: Open

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

Recommendation: The Assistant Administrator for EPA's Office of Enforcement and Compliance Assurance should clearly document in guidance to the regional offices how they should use the definition of informal enforcement actions to collect data on these actions. (Recommendation 1)

Agency: Environmental Protection Agency
Status: Open

Comments: In written comments reproduced in appendix I of this report, EPA stated that it agreed with this recommendation. In July 2020, EPA stated that in a September 30, 2019 guidance document, the agency defined an informal enforcement action. However, on March 24, 2020, the Office of Enforcement and Compliance Assurance (OECA) suspended the September guidance because informal enforcement actions as defined appear to be inconsistent with Section 6 of the White House's Executive Order (EO) 13892, Promoting the Rule of Law Through Transparency and Fairness in Civil Administrative Enforcement and Adjudication, issued on October 9, 2019. EPA said that it would amend the September 2019 guidance to be consistent with the Executive Order. Our recommendation focused on guidance on how regional offices should use the definition of informal enforcement action and we will continue to monitor EPA's implementation of this recommendation.

Recommendation: The Assistant Administrator for EPA's Office of Enforcement and Compliance Assurance should clearly document in guidance to the regional offices that they should collect data on compliance assistance activities and specify which mechanism to use to maintain the data, such as ICIS. (Recommendation 2)

Agency: Environmental Protection Agency
Status: Open

Comments: In written comments reproduced in appendix I of this report, EPA stated that it agreed with this recommendation and would collect data on compliance assistance for each of the National Compliance Initiatives and maintain those data in ICIS. Specifically, in July 2020, the agency stated that in order to further its compliance assistance efforts, the Office of Enforcement and Compliance Assistance (OECA) is including a compliance assistance tool as an important part of each of EPA's National Compliance Initiatives. According to EPA, data on compliance assistance efforts that are part of the NCI will be collected and tracked for management review in the Integrated Compliance Information System. In addition, EPA stated it has collected data in the past on webpage visits related to its national Compliance Assistance Centers and would continue to do so in the future. We will continue to monitor the status of EPA's implementation of this recommendation.

Recommendation: The Assistant Administrator for EPA's Office of Enforcement and Compliance Assurance should include the known limitations of data in its annual reports and provide information on the intended use of EPA's data. (Recommendation 3)

Agency: Environmental Protection Agency
Status: Open

Comments: In written comments reproduced in appendix I of this report, EPA stated that it agreed with this recommendation and acknowledged the importance of providing information about a dataset to facilitate proper interpretation. For that reason, EPA said that, in time for its fiscal year 2020 report, the agency will create a webpage to describe how best to interpret the data presented in its "Fiscal Year EPA Enforcement and Compliance Annual Results" report and include a reference to that webpage in the report itself as well as the "Year in Review" report. In July 2020, EPA reiterated its written comments on the report. We will update the status of EPA's implementation of this recommendation upon the release of its annual reports.

Recommendation: The DEA Administrator should develop and implement additional ways to use algorithms in analyzing ARCOS and other data to more proactively identify problematic drug transaction patterns. (Recommendation 1)

Agency: Department of Justice: Drug Enforcement Administration
Status: Open
Priority recommendation

Comments: DOJ agreed with this recommendation and DEA stated it will continue to examine a variety of technologies to analyze ARCOS and other data and implement additional ways to use algorithms to more proactively identify problematic drug transaction patterns.

Recommendation: The DEA Administrator, in coordination with the department-wide efforts on data strategy, should establish and document a data governance structure to ensure DEA is maximizing its management of industry-reported drug transaction data. (Recommendation 2)

Agency: Department of Justice: Drug Enforcement Administration
Status: Open
Priority recommendation

Comments: DOJ agreed with this recommendation. As of September 2019, DEA officials stated that its Office of Information Systems' Chief Data Officer just recently started to work with DOJ and other components to develop a data strategy in response to the recently released department wide strategy, and has begun efforts to develop a governance structure. In November, 2019 DEA indicated it will continue to mature its data governance structure. The intent of this recommendation is for DEA to establish a formalized data governance structure to manage its collection and use of data used to support the Diversion Control Division's mission.

Recommendation: The DEA Administrator should establish outcome-oriented goals and associated measurable performance targets related to opioid diversion activities, using data it collects, to assess how the data it obtains and uses supports its diversion control activities. (Recommendation 3)

Agency: Department of Justice: Drug Enforcement Administration
Status: Open
Priority recommendation

Comments: DOJ neither agreed nor disagreed with this recommendation but DEA stated in November 2019, that it recognizes that measurable performance targets related to opioid diversion activities can serve as leading practices at different organizational levels including the program, project, or activity level. Our recommendation is intended to ensure that DEA can demonstrate the usefulness of the data it collects and uses to support its opioid diversion control activities.

Recommendation: The DEA Administrator, in consultation with industry stakeholders, should identify solutions to address the limitations of the ARCOS Enhanced Lookup Buyer Statistic Tool, to ensure registrants have the most useful information possible to assist them in identifying and reporting suspicious orders to DEA. (Recommendation 4)

Agency: Department of Justice: Drug Enforcement Administration
Status: Open
Priority recommendation

Comments: DOJ agreed with this recommendation and in November 2019, stated it has consulted with industry stakeholders and identified solutions to address the limitations of the tool.

Recommendation: The IRS Commissioner should develop specific instructions within the Internal Revenue Manual, the Nonqualified Deferred Compensation Audit Techniques Guide, or other IRS training material to aid examiners in obtaining and evaluating information they can use to determine whether there exists a restricted period with respect to a company with a single-employer defined benefit plan and if a company with a single-employer defined benefit plan has, during a restricted period, set aside assets for the purpose of paying deferred compensation under an executive retirement plan. (Recommendation 1)

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

Comments: IRS stated that they would review and consider developing further specific instructions within the Internal Revenue Manual, the Nonqualified Deferred Compensation Audit Techniques Guide or other IRS training material to aid examiners. We believe that implementing this recommendation will help ensure that IRS is aware of when companies with at-risk single-employer defined benefit plans are reporting assets set aside to pay deferred compensation to key executives while in a restricted period as income for those employees

Recommendation: The Secretary of Labor should review and determine whether its reporting requirements for executive retirement plans should be modified to provide additional information DOL could use to oversee whether these plans are meeting eligibility requirements. (Recommendation 2)

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

Comments: DOL stated that it does not have plans to issue guidance or regulations regarding executive retirement plans, citing, among other considerations, existing resource constraints and priority regulatory and guidance projects in development, and that it would not be advisable to shift resources from other projects. GAO continues to maintain that DOL's one-time single page alternative reporting for executive retirement plans lacks important information sufficient to help the agency identify whether companies may be including ineligible employees in its plan and DOL's current data on executive retirement plans has limited usefulness due to the age and limits of the original data submitted.

Recommendation: The Secretary of Labor should explore actions the agency could take to help companies prevent the inclusion of rank-and-file employees in executive retirement plans and determine which, if any, actions should be implemented. (Recommendation 3)

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

Comments: DOL stated that the agency has not encountered evidence of systematic abuses involving executive retirement plans or that ERISA's claims procedure rules and judicial remedies are inadequate to protect participants' benefit rights. However, we reported that industry surveys indicate that some companies may be extending employee eligibility to high percentages of their workforce who are lower-paid and lower-ranked employees who may not be considered a part of a select group. Industry experts also told us that plan eligibility requirements for executive retirement plans are not clearly defined and that companies are unclear on how to establish eligibility, and they identified court cases that contribute to the confusion regarding plan eligibility. Implementing this recommendation will help ensure that only executives who can bear the risks inherent in these plans are participating.

Recommendation: The Secretary of Labor should provide specific instructions for companies to follow to correct eligibility errors that occur when rank-and-file employees are found to be participating in executive retirement plans, and should coordinate with other federal agencies on these instructions, as appropriate. (Recommendation 4)

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

Comments: DOL suggested a remedy in an amicus brief for companies to follow to correct eligibility errors in these plans could have unintended consequences for participants because, according to IRS officials, it could result in violations of federal tax law and additional tax for participants. We urge DOL to develop instructions to correct eligibility errors, in coordination with other federal agencies, as needed, in a way that does not adversely affect rank-and-file employees participating in these plans.

Recommendation: The Commissioner of Internal Revenue should assess options for updating Publications 590-A and 590-B to either include more information or direct taxpayers to other resources for IRA owners with investments in unconventional assets. Such information could include: storage requirements for IRA investments in certain precious metals; valuation methods for hard-to-value IRA assets; the Department of Labor's process for granting exemptions to IRA prohibited transactions rules; and IRA investments with the potential to create unrelated business income tax liabilities. (Recommendation 1)

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

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

Recommendation: The Commissioner of Internal Revenue, building on forthcoming compliance research using new IRA asset data, should evaluate the feasibility of requiring disclosure for high-risk IRA asset types associated with abusive schemes as transactions of interest. (Recommendation 2)

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

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

Recommendation: The Commissioner of Internal Revenue should develop resources (such as training materials or job aids) for Small Business/Self-Employed examiners conducting IRA owner audits that explain how IRAs with unconventional assets can generate unrelated business income tax liability, and how examiners can refer cases to unrelated business income experts in IRS for assistance. (Recommendation 3)

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

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

Recommendation: FirstNet's Chief Executive Officer should take steps to ensure that the integrated master schedule for the program is developed and maintained in accordance with the best practices provided in GAO's Schedule Assessment Guide. (Recommendation 1)

Agency: Department of Commerce: National Telecommunications and Information Administration: First Responder Network Authority
Status: Open

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

Recommendation: FirstNet's Chief Executive Officer should identify additional information about the program, including FirstNet's oversight and monitoring activities, that can be shared with public-safety stakeholders and periodically communicate and report this information to them. (Recommendation 2)

Agency: Department of Commerce: National Telecommunications and Information Administration: First Responder Network Authority
Status: Open

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

Recommendation: FirstNet's Chief Executive Officer should share relevant portions of the accepted state-specific commitment reports with the states, as specified in the contract. (Recommendation 3)

Agency: Department of Commerce: National Telecommunications and Information Administration: First Responder Network Authority
Status: Open

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

Recommendation: FirstNet's Chief Executive Officer should, in consultation with public-safety stakeholders and its contractor, as appropriate, identify and obtain periodic information or meaningful indicators on end-users' satisfaction that would serve as a metric to gauge performance quality, including the effect of the FirstNet network and products on public-safety operations. (Recommendation 4)

Agency: Department of Commerce: National Telecommunications and Information Administration: First Responder Network Authority
Status: Open

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

Recommendation: The Administrator of CMS should determine the extent to which state Medicaid programs are in compliance with federal requirements to cover MAT medications in all formats and take actions to ensure compliance, as appropriate. (Recommendation 1)

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

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

Recommendation: The Administrator of CMS should ensure that state Medicaid programs have written policies and procedures that specify the extent to which covered entities can use 340B drugs for Medicaid beneficiaries, are designed to effectively identify if 340B drugs were used, and if so, how they should be excluded from Medicaid rebate requests. The policies and procedures should be made publically available and cover FFS, managed care, and all of the dispensing methods for outpatient drugs. (Recommendation 1)

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

Comments: HHS concurred with this recommendation and in August 2020 stated that it is developing guidance to state Medicaid programs directing them to strengthen policies and procedures related to 340B drugs for Medicaid beneficiaries.

Recommendation: The Administrator of HRSA should incorporate assessments of covered entities' compliance with state Medicaid programs' policies and procedures regarding the use and identification of 340B drugs into its audit process, working with CMS as needed to obtain states' policies and procedures. (Recommendation 2)

Agency: Department of Health and Human Services: Public Health Service: Health Resources and Services Administration
Status: Open

Comments: HHS did not concur with this recommendation and, as of August 2020, did not plan to take any actions to implement the recommendation. As noted in our report, covered entities' compliance with state Medicaid programs' policies and procedures is fundamental to preventing duplicate discounts. Thus, we continue to believe that HRSA's audit process should include an assessment of covered entities' compliance with state Medicaid programs' policies and procedures related to 340B drugs as it is necessary to identify potential duplicate discounts and to ensure covered entities' compliance with 340B Program requirements.

Recommendation: The Administrator of HRSA should require covered entities to work with affected drug manufacturers regarding repayment of identified duplicate discounts in Medicaid managed care. (Recommendation 3)

Agency: Department of Health and Human Services: Public Health Service: Health Resources and Services Administration
Status: Open

Comments: HHS did not concur with this recommendation and, as of August 2020, did not plan to take any actions to implement the recommendation. As noted in our report, HRSA officials told us that covered entities' obligations for preventing duplicate discounts are the same for Medicaid fee-for-service and managed care. Thus, we continue to believe that when duplicate discounts related to Medicaid managed care have been identified, the agency should require covered entities to work with manufacturers to remedy them as they do for duplicate discounts related to Medicaid fee-for-service to help ensure compliance with 340B Program requirements.

Recommendation: The Commissioner of the Social Security Administration should clarify policies and procedures to remind staff that a diagnosis of a substance use disorder is not necessary to conduct a Drug Addiction and Alcoholism evaluation. (Recommendation 1)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. The agency stated that it had revised related policies in February 2020, and had planned to issue guidance and video-on-demand training to further clarify policies and procedures in this area. However, SSA said its efforts to maintain mission critical activities amid the COVID-19 pandemic have delayed further implementation of this recommendation and a specific implementation date could not be provided at this time.

Recommendation: The Commissioner of the Social Security Administration should ensure that staff document their rationale for decisions involving the Drug Addiction and Alcoholism evaluation process. (Recommendation 2)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. The agency said it had planned to issue guidance reinforcing its policy on properly documenting decisions involving the Drug Addiction and Alcoholism evaluation process. However, SSA said its efforts to maintain mission critical activities amid the COVID-19 pandemic have delayed implementation of this recommendation and a specific implementation date could not be provided at this time.

Recommendation: The Secretary of Agriculture should direct the Office of Property and Fleet Management to consistently monitor property provided to non-federal recipients within 1 year of receipt, and to ensure property is being used for its intended purpose 1 year after initial monitoring. (Recommendation 1)

Agency: Department of Agriculture
Status: Open

Comments: USDA concurred with this recommendation. As of April 2020, USDA's 180-day letter has not been received.

Recommendation: The Secretary of Energy should direct the Office of Asset Management to resume monitoring the Economic Development Property program, including property provided to non-federal recipients. (Recommendation 2)

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

Comments: As of March 2020, DOE indicated in its 180-day letter that the agency concurred with the recommendation, and will update their annual personal property reporting requirements. DOE anticipates having this recommendation implemented by September 30, 2020. GAO will continue to monitor DOE's efforts to implement this recommendation.

Recommendation: The Secretary of Labor should direct the Employment and Training Administration to take steps, such as reconciling data between Job Corps centers and the Job Corps National Office, to ensure that the entities responsible for overseeing and monitoring the Job Corps Program have accurate data on the excess property provided to non-federal recipients. (Recommendation 3)

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

Comments: As of February 2020, DOL indicated in its 180-day letter that they concurred with the recommendation, and have taken steps to improve the monitoring and oversight of Job Corps Property. This includes modifying the GSAXcess approval process by elevating review of all GSAXcess requests made by Job Corps Centers to DOL's Employment Training Administration's (ETA) national office. ETA is also working with DOL's Office of the Assistant Secretary for Administration and Management (OASAM) to develop a process for GSAXcess review that includes identifying approval levels for each category of property, identifying categories of property requiring additional review and approvals, and coordinating and streamlining access request procedures. These changes will be reflected in DOL's Office of Job Corps standard operating procedures (SOP), which is expected to be issued at the end of fiscal year 2020. DOL expects to provide training to Job Corps staff and Job Corps Centers in support of the SOP that will be provided annually. GAO will continue to monitor DOL's efforts to implement this recommendation.

Recommendation: The Secretary of Agriculture should direct the Office of Property and Fleet Management to establish clear processes to oversee property programs, including excess property provided to non-federal recipients across the agency. (Recommendation 4)

Agency: Department of Agriculture
Status: Open

Comments: USDA concurred with this recommendation. As of April 2020, USDA's 180-day letter has not been received.

Recommendation: The Secretary of Energy should direct the Office of Asset Management to update its regulations and guidance on programs that provide property to non-federal recipients to ensure regulations are current and establish a process to regularly communicate information about non-federal recipient programs to DOE program offices. (Recommendation 5)

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

Comments: As of March 2020, DOE indicated in its 180-day letter that the agency concurred with the recommendation, and will update internal policies, and provide personal property information on DOE's internal informational website known as Powerpedia. DOE anticipates implementing this recommendation by September 30, 2020. GAO will continue to monitor DOE's efforts to implement this recommendation.

Recommendation: The GSA Administrator should direct the Office of Government-wide Policy to revise the Personal Property Reporting Tool by updating the authorities agencies can select. (Recommendation 6)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of February 2020, GSA indicated in its 180-day letter that it concurred with the recommendation, and has taken steps to revise the Personal Property Reporting Tool (tool). GSA has added relevant authorities to the tool as recently as July 2019, and will continue to contact agencies to ensure relevant authorities are included in the tool. GSA is also evaluating technical updates to the tool to ensure that reporting agencies select an appropriate authority when reporting personal property. GSA plans to complete these actions by July 31, 2020, and inform agencies of these changes in their guidance by the end of fiscal year 2020. GAO will continue to monitor GSA's efforts to implement the recommendation.

Recommendation: The GSA Administrator should direct the Office of Government-wide Policy to document in what circumstances excess property loaned to non-federal recipients should be reported and what property GSA is reporting on behalf of agencies, for example, by updating GSA guidance. (Recommendation 7)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of February 2020, GSA indicated in its 180-day letter that it concurred with the recommendation. GSA will better communicate with agencies to better understand the confusion of reporting on loaned excess property, as reporting requirements are in statute, regulations, and guidance. GSA also plans to review and update by July 31, 2020, relevant regulations and guidance in this area including Federal Management Regulation Bulletin B-27, "Annual Executive Agency Reports on Excess and Exchange/Sale Personal Property." GAO will continue to monitor GSA's efforts to implement this recommendation.

Recommendation: The SEC Chair should direct the Directors of the Division of Corporation Finance, Division of Enforcement, Office of Compliance Inspections and Examinations, and Office of Credit Ratings to develop written policies and processes to systematically assess the effectiveness of staff procedures (procedures applicable to staff who perform examinations of registered entities, enforcement investigations, and reviews of corporate financial securities filings). Examples of elements SEC could include in the policies and processes are the steps necessary to conduct such assessments, including time frames in which the assessments should be performed and reviewed; assignment of responsibilities related to the assessments; requirements for documenting assessments; and steps for staff to take to mitigate and report deficiencies identified as a result of the assessments. (Recommendation 1)

Agency: United States Securities and Exchange Commission
Status: Open

Comments: As of May 2020, SEC updated its Reference Guide for Compliance with Section 961 of the Dodd-Frank Act to require the Division of Corporation Finance, Division of Enforcement, Office of Compliance Inspections and Examinations, and Office of Credit Ratings to develop and maintain written policies and processes for conducting systematic assessments of the effectiveness of procedures applicable to the staff who perform examinations of registered entities, enforcement investigations, and reviews of corporate financial securities filings. The added requirement for each division and office to develop policies and processes is a positive step toward addressing this recommendation. However, until the divisions and offices establish such policies and processes, this recommendation remains open. SEC staff stated that the divisions and offices are currently working on developing their individual frameworks for assessing staff procedures and will likely be done by the end of fiscal year 2020. We will continue to monitor these efforts.

Recommendation: The Director of the Division of Corporation Finance should ensure that all internal supervisory controls include documentation requirements, detailed procedures, identified follow-up actions, implementation time frames, and assignment of control execution responsibility, in accordance with SEC guidance and federal internal control standards for implementing control activities through documented policies. (Recommendation 2)

Agency: United States Securities and Exchange Commission: Division of Corporation Finance
Status: Open

Comments: As of May 2020, SEC staff said that the Division of Corporation Finance is working to address this recommendation through its normal Risk and Control Matrix review process. Staff said that SEC would have an update for GAO in the Fall 2020. We will update the status of the recommendation when the Division of Corporation Finance provides documentation showing the implementation of responsive actions.

Recommendation: The Director of the Division of Enforcement should ensure that all internal supervisory controls include documentation requirements, detailed procedures, identified follow-up actions, implementation time frames, and assignment of control execution responsibility, in accordance with SEC guidance and federal internal control standards for implementing control activities through documented policies. (Recommendation 3)

Agency: United States Securities and Exchange Commission: Division of Enforcement
Status: Open

Comments: As of May 2020, SEC staff said that the Division of Enforcement is working to address this recommendation through its normal Risk and Control Matrix review process. Staff said that SEC would have an update for GAO in the Fall 2020. We will update the status of the recommendation when the Division of Enforcement provides documentation showing the implementation of responsive actions.

Recommendation: The Director of the Office of Compliance Inspections and Examinations should ensure that all internal supervisory controls include documentation requirements, detailed procedures, identified follow-up actions, implementation time frames, and assignment of control execution responsibility, in accordance with SEC guidance and federal internal control standards for implementing control activities through documented policies. (Recommendation 4)

Agency: United States Securities and Exchange Commission: Office of Compliance Inspections and Examinations
Status: Open

Comments: As of May 2020, SEC staff said that the Office of Compliance Inspections and Examinations is working to address this recommendation through its normal Risk and Control Matrix review process. Staff said that SEC would have an update for GAO in the Fall 2020. We will update the status of the recommendation when the Office of Compliance Inspections and Examinations provides documentation showing the implementation of responsive actions.

Recommendation: The Director of the Office of Credit Ratings should ensure that all internal supervisory controls include documentation requirements, detailed procedures, identified follow-up actions, implementation time frames, and assignment of control execution responsibility, in accordance with SEC guidance and federal internal control standards for implementing control activities through documented policies. (Recommendation 5)

Agency: United States Securities and Exchange Commission: Office of Credit Ratings
Status: Open

Comments: As of May 2020, SEC staff said that the Office of Credit Ratings is working to address this recommendation through its normal Risk and Control Matrix review process. Staff said that SEC would have an update for GAO in the Fall 2020. We will update the status of the recommendation when the Office of Credit Ratings provides documentation showing the implementation of responsive actions.

Recommendation: The Secretary of State should direct the Department's relevant bureaus to work with Embassy Beirut to establish, as appropriate, and consolidate targets for each of the security-related performance indicators. (Recommendation 1)

Agency: Department of State: Office of the Secretary
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 State should direct the Department's relevant bureaus to work with Embassy Beirut to collect and review performance data for key security-related performance indicators. (Recommendation 2)

Agency: Department of State: Office of the Secretary
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 DSCA to revise the inspection due dates it establishes for items requiring enhanced EUM for the Office of Defense Cooperation in Beirut to align with DOD's standards for EUM by considering the date of last inspection. (Recommendation 3)

Agency: Department of Defense: Office of the Secretary 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 Administrator of the Federal Aviation Administration should develop and implement a process to ensure that information on UAS-related costs is complete and reliable as capabilities and related regulations evolve. (Recommendation 1)

Agency: Department of Transportation: Federal Aviation Administration: Office of the Administrator
Status: Open

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

Recommendation: The Administrator of the Federal Aviation Administration, as part of UAS integration-planning efforts, should use available guidance on effective fee design to incorporate steps that will inform future fee-design considerations. For example, FAA may choose to incorporate these additional steps into its annual UAS implementation plan so that—as existing activities are adapted for UAS users or new regulations, services, or systems are introduced—costs and fee design options are considered. (Recommendation 2)

Agency: Department of Transportation: Federal Aviation Administration: Office of the Administrator
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 the Office of Foreign Assets Control provides its partner agencies more specific guidance regarding Kingpin Act–related expenditure data to improve the consistency of data submitted by these agencies. This could include, for example, how agencies account for expenditures that support Kingpin Act investigations when they are not the lead and for what types of activities resource expenditure data are required. (Recommendation 1)

Agency: Department of the Treasury: Office of the Secretary
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 the Office of Foreign Assets Control discloses information about limitations in the consistency and reliability of the agency expenditure data in its annual reports to Congress. (Recommendation 2)

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

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

Recommendation: The Assistant Secretary of Labor for the Employee Benefits Security Administration should evaluate whether targeted oversight in response to information received is effective for ensuring compliance with MH/SU parity requirements. If this evaluation determines the current targeted oversight approach results in significant program risks, the Employee Benefits Security Administration should develop a plan to more effectively enforce MH/SU parity requirements and if necessary seek additional oversight authority, as warranted. (Recommendation 1)

Agency: Department of Labor: Employee Benefits Security Administration
Status: Open

Comments: DOL agreed with this recommendation. In February 2020, DOL reported that its Employee Benefits Security Administration plans to evaluate its targeted approach to MH/SU parity enforcement. When we confirm what actions DOL has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator of CMS should evaluate whether targeted oversight in response to information received is effective for ensuring compliance with MH/SU parity requirements for non-federal governmental plans. If this evaluation determines the current targeted oversight approach results in significant program risks, CMS should develop a plan to more effectively enforce MH/SU parity requirements and if necessary seek additional oversight authority, as warranted. (Recommendation 2)

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

Comments: HHS agreed with this recommendation. In August 2020, HHS reported that CMS has developed a two-part evaluation to determine whether targeted oversight of non-federal governmental plans is effective for enforcing MH/SU parity requirements. According to HHS, this evaluation will include (1) a review of non-federal governmental plan documents for compliance with MH/SU parity requirements and (2) a survey of state enforcement authority and regulatory best practices for ensuring MH/SU parity compliance. As of August 2020, HHS reported that the first part of the CMS evaluation is underway.

Recommendation: The Director of OMB should establish a process for monitoring and holding agencies accountable for authorizing cloud services through FedRAMP. (Recommendation 1)

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

Comments: OMB neither agreed nor disagreed with this recommendation and as of September 2020, the office has not provided information on its actions to implement our recommendation. To fully implement this recommendation, OMB needs to collect data on the extent to which federal agencies are using cloud services authorized outside of FedRAMP and oversee agencies' compliance with using the program. According to an OMB Associate General Counsel, the agency does not have a mechanism for enforcing agencies' compliance with its guidance on FedRAMP. However, we believe that OMB can and should hold agencies accountable for complying with its policies. By implementing this recommendation, OMB could substantially improve participation in the FedRAMP program, which is intended to standardize security requirements for federal agencies' authorizations of cloud services. We will update the status of this recommendation when OMB provides information on its corrective actions.

Recommendation: The Administrator of GSA should direct the Director of FedRAMP to clarify guidance to agencies and cloud service providers on program requirements and responsibilities. (Recommendation 2)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should direct the Director of FedRAMP to improve the program's continuous monitoring process by allowing more automated capabilities, including for agencies to review documentation. (Recommendation 3)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should update security plans for selected systems to include the description of security controls and reviews and approvals plan. (Recommendation 4)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should update the security assessment report for the selected system to identify the summarized results of control effectiveness tests. (Recommendation 5)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should update the list of corrective actions for selected systems to identify the responsible office and estimated funding required and anticipated source of funding. (Recommendation 6)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should develop guidance requiring that cloud service authorization letters be provided to the FedRAMP program management office. (Recommendation 7)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of CDC to update the security plan for the selected system to identify the authorization boundary, the system operational environment and connections, a description of security controls, and the individual reviewing and approving the plan and date of approval. (Recommendation 8)

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

Comments: In June 2020, CDC stated it has taken actions to address our recommendations, but we have not received evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CDC provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of CDC to update the security assessment report for the selected system to identify the summarized results of control effectiveness tests. (Recommendation 9)

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

Comments: In June 2020, CDC stated it has taken actions to address our recommendations, but we have not received evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CDC provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of CDC to update the list of corrective actions for the selected system to identify the specific weaknesses, funding source, changes to milestones and completion dates, identified source of weaknesses, and status of corrective actions. (Recommendation 10)

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

Comments: In June 2020, CDC stated it has taken actions to address our recommendations, but we have not received evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status once CDC provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Administrator of CMS to update the system security plans for selected systems to identify a description of security controls. (Recommendation 11)

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

Comments: In June 2020, HHS stated CMS took actions to close this recommendation, but CMS has not yet provided evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CMS provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Administrator of CMS to update the security assessment report for selected system to identify the summarized results of control effectiveness tests. (Recommendation 12)

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

Comments: In June 2020, HHS stated CMS took actions to close this recommendation, but CMS has not yet provided evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CMS provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Administrator of CMS to update and document the CMS remedial action plan for the selected system to identify the anticipated source of funding. (Recommendation 13)

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

Comments: In June 2020, HHS stated CMS took actions to close this recommendation, but CMS has not yet provided evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CMS provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Administrator of CMS to prepare letters authorizing the use of cloud services for the selected systems and submit the letters to the FedRAMP program management office. (Recommendation 14)

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

Comments: In June 2020, HHS stated CMS took actions to close this recommendation, but CMS has not yet provided evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CMS provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of NIH to update security plans for selected systems to identify the authorization boundary, system operation in terms of mission and business processes, operational environment and connections, and a description of security controls. (Recommendation 15)

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

Comments: In June 2020, NIH stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. NIH stated it will provide an update in December 2020. We will continue to monitor the agency's progress and update the recommendation's status when NIH provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of NIH to update the security assessment report for selected systems to identify summarized results of control effectiveness tests. (Recommendation 16)

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

Comments: In June 2020, NIH stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. NIH stated it will provide an update in December 2020. We will continue to monitor the agency's progress and update the recommendation's status when NIH provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of NIH to update the NIH list of corrective actions for selected systems to identify estimated funding and anticipated source of funding, key milestones with completion dates, and changes to milestones and completion dates. (Recommendation 17)

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

Comments: In June 2020, NIH stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. NIH stated it will provide an update in December 2020. We will continue to monitor the agency's progress and update the recommendation's status when NIH provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of NIH to submit the division's letters authorizing the use of cloud services for the selected systems to the FedRAMP program management office. (Recommendation 18)

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

Comments: In June 2020, NIH stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. NIH stated it will provide an update in December 2020. We will continue to monitor the agency's progress and update the recommendation's status when NIH provides its corrective actions.

Recommendation: The Administrator of EPA should update security plan for the selected operational system to identify a description of security controls, and the individual reviewing and approving the plan and date of approval. (Recommendation 19)

Agency: Environmental Protection Agency
Status: Open

Comments: In June 2020, EPA stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Administrator of EPA should update the security assessment report for the selected operational system to identify the summarized results of control effectiveness tests. (Recommendation 20)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA did not concur with this recommendation and as of September 2020, the agency has not provided any evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Administrator of EPA should update the list of corrective actions for the selected operational system to identify the specific weakness, estimated funding and anticipated source of funding, key remediation milestones with completion dates, changes to milestones and completion dates, and source of the weaknesses. (Recommendation 21)

Agency: Environmental Protection Agency
Status: Open

Comments: In June 2020, EPA stated it is taking action to address this recommendation, but the agency did not provide evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Administrator of EPA should prepare the letter authorizing the use of cloud service for the selected operational system and submit the letter to the FedRAMP program management office. (Recommendation 22)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA did not concur with this recommendation and as of September 2020, the agency has not provided any evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Administrator of EPA should develop guidance requiring that cloud service authorization letter be provided to the FedRAMP program management office. (Recommendation 23)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA did not concur with this recommendation and as of September 2020, the agency has not provided any additional evidence. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Administrator of HRSA should ensure that the information it uses to verify nonprofit status for all nongovernmental hospitals that participate in the 340B Program is reliable—for example, by requiring and reviewing the submission of official documentation hospitals must already maintain or by ensuring the reliability of the data the agency uses. (Recommendation 1)

Agency: Department of Health and Human Services: Public Health Service: Health Resources and Services Administration
Status: Open

Comments: HHS concurred with this recommendation and in June 2020, reiterated that HRSA believes that the information it uses to determine nonprofit status is reliable, because hospital administrators attest to its accuracy. However, as discussed in our report, neither HRSA nor the agency that collects the data has evaluated the reliability of the data for verifying nonprofit status. Without ensuring it is using reliable information, HRSA cannot effectively determine if nongovernmental hospitals participating, or seeking to participate, in the 340B Program meet the statutory eligibility requirements.

Recommendation: The Administrator of HRSA should implement a process to verify that every nongovernmental hospital that participates in the 340B Program has a contract with a state or local government as required by statute. (Recommendation 2)

Agency: Department of Health and Human Services: Public Health Service: Health Resources and Services Administration
Status: Open

Comments: HHS did not concur with this recommendation and, as of June 2, 2020, did not plan to take any actions to implement the recommendation. HHS noted that requiring all covered entities to submit a state or local government contract would create a significant burden for covered entities. However, as we noted in our report, HRSA already requires hospitals to maintain copies of their state or local government contracts. Therefore, it is unclear how implementing a process to verify the existence of those contracts would represent a significant burden. Without this information, HRSA does not have reasonable assurance that nongovernmental hospitals have the statutorily required contracts to participate in the 340B Program.

Recommendation: The Administrator of HRSA should provide more specific guidance for 340B Program auditors on how to determine if nongovernmental hospitals' contracts with state and local governments require the provision of health care services to low-income individuals not eligible for Medicaid or Medicare. (Recommendation 4)

Agency: Department of Health and Human Services: Public Health Service: Health Resources and Services Administration
Status: Open

Comments: HHS concurred with this recommendation and in June 2020, indicated that HRSA had updated its audit guidance and procedures to more clearly specify that contracts must contain requirements for the provision of health care services to low-income individuals. However, these documents do not contain any specific guidance on how auditors are to evaluate whether contracts require these services. Without more specific guidance for auditors' review of contracts, HRSA lacks reasonable assurance that the audits are appropriately identifying deficiencies in nongovernmental hospitals' contracts with state or local governments.

Recommendation: The Administrator of HRSA should require nongovernmental hospitals participating in the 340B Program to demonstrate that they have contracts with state or local governments in effect prior to the beginning of their audits' periods of review and should apply consistent and appropriate consequences for hospitals that are unable to do so. (Recommendation 6)

Agency: Department of Health and Human Services: Public Health Service: Health Resources and Services Administration
Status: Open

Comments: HHS concurred with this recommendation. As noted in our report, HRSA updated its draft audit procedures for fiscal year 2020 audits in September 2019 to specify that auditors should look for effective dates that cover the entire audit period. While this is an important step, HRSA must also show that it has ceased accepting retroactive contract documentation, and has applied consistent and appropriate consequences when auditors find that nongovernmental hospitals did not have contracts in effect prior to the beginning of their audit periods. As of June 2020, HHS indicated that HRSA had not taken these actions. Allowing hospitals that are unable to demonstrate that they have contracts in place that cover their audits' periods of review to continue to participate without consequences undermines the effectiveness of HRSA's audit process and increases the risk that ineligible hospitals will receive discounts under the program.

Recommendation: The Board of Governors of the Federal Reserve System should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 1)

Agency: Federal Reserve System
Status: Open

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

Recommendation: The Comptroller of the Currency should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 2)

Agency: Department of the Treasury: Office of the Comptroller of the Currency
Status: Open

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

Recommendation: The Chairman of the Federal Deposit Insurance Corporation should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 3)

Agency: Federal Deposit Insurance Corporation
Status: Open

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

Recommendation: The Chairman of the National Credit Union Administration should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 4)

Agency: National Credit Union Administration
Status: Open

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

Recommendation: The Administrator of TSA should document which rule review process TSA I&A uses (exigent or standard) for each new rule or rule change; (Recommendation 2)

Agency: Department of Homeland Security: Transportation Security Administration
Status: Open

Comments: DHS concurred with this recommendation and agreed to document which rule review process TSA I&A uses (exigent or standard) for each new rule or rule change. In March 2020, TSA updated its SOP to require that the selected rule review process be documented for each new rule and rule change. TSA's policy change is a positive first step, but to fully address this recommendation, TSA will need to demonstrate that the selected rule review process is now being documented.

Recommendation: The Administrator of TSA should explore additional data sources measuring the effectiveness of Silent Partner and Quiet Skies rules. (Recommendation 3)

Agency: Department of Homeland Security: Transportation Security Administration
Status: Open

Comments: DHS concurred with this recommendation and, in May 2020, DHS officials stated that they are reviewing data sources and assessing potential ways to assess the effectiveness of Quiet Skies and Silent Partner screening rules. DHS officials stated that they plan to fully address this recommendation by December 2020.

Recommendation: The Director of OCS, in developing the new performance management approach for the CSBG program, should ensure that its performance framework includes information on (1) details for how the national measure is linked to and used to assess the three national program goals, (2) descriptions of how the updated state and local performance outcome measures align with national program goals, and (3) a written plan for how OCS will assess the reliability of state performance outcome data. (Recommendation 1)

Agency: Department of Health and Human Services: Office of Community Services
Status: Open

Comments: HHS agreed with this recommendation and and stated that it plans to take actions to better align its performance measures with the three national performance goals outlined in the new CSBG Theory of Change. We commend HHS for its plans to address this recommendation, but encourage the agency to focus on aligning its performance outcomes with the three national goals of the CSBG program as established by the CBBG Act, which are similar but not identical to the three goals outlined in the new CSBG Theory of Change. HHS also stated that it would implement additional actions to assess the reliability of state performance outcome data.

Recommendation: The Director of the Office of Financial Assistance should review and enhance guidance for the Microloan Program to ensure definitions of data collected, such as income, are clear and instructions are comprehensive for data needed, such as for borrower business outcomes and technical assistance. (Recommendation 1)

Agency: Small Business Administration
Status: Open

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

Recommendation: The Directors of the Office of Financial Assistance and Office of Program Performance, Analysis, and Evaluation should develop a performance target to assess the Microloan Program's progress in achieving its statutory purpose of assisting women, low-income, veteran, and minority entrepreneurs. (Recommendation 2)

Agency: Small Business Administration
Status: Open

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

Recommendation: The Directors of the Office of Financial Assistance and Office of Program Performance, Analysis, and Evaluation should ensure that appropriate advance planning occurs during the development of the new Microloan Program data reporting system by involving relevant offices within SBA in system design and considering data needed to assess program performance. (Recommendation 3)

Agency: Small Business Administration
Status: Open

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

Recommendation: The SBA Administrator should explore opportunities for additional interagency collaboration and information sharing with other federal agencies that engage in microlending activities, such as Treasury and USDA, and take steps to implement new collaborative efforts as warranted. (Recommendation 4)

Agency: Small Business Administration
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 the Office of Financial Assistance should examine ways to incorporate public reporting of additional Microloan Program information into the design of the new data reporting system. (Recommendation 5)

Agency: Small Business Administration
Status: Open

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

Recommendation: The Commissioner of FDA should establish a process to monitor whether the agency is meeting its audit goals and expectations for sampling and inspections to support its removal decisions for seafood import alerts. This could be done through regularly analyzing data that FDA collects, such as those in CMS, FACTS, and OASIS. (Recommendation 1)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

Comments: FDA agreed with our recommendation. In August 2020, FDA told us that the agency is working to review and modify appropriate sections of its Regulatory Procedures Manual to better reflect the importance of foreign suppliers' corrective actions when making decisions to remove a firm from an import alert and identify higher-risk problem areas where more robust information may be needed. In addition, a checklist for import alerts and associated Compliance Management System (database) functionality are under development. According to FDA, the agency is also working to refine internal communications to better assure that firms which have recently been removed from an import alert are also considered for an inspection. Additionally, in November 2019, FDA published a Notice of Proposed Rulemaking on accreditation of laboratories that conduct food testing to support removal from import alert and other purposes. We will continue to monitor FDA's planned actions to determine if they satisfy our recommendation.

Recommendation: The Commissioner of FDA should establish a time frame for developing performance goals and measures for its imported food safety program. (Recommendation 2)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

Comments: FDA agreed with this recommendation. In August 2020, FDA told us that the agency has published some performance metrics and plans to develop additional performance measures and outcome indicators for imported food safety, to support FDA's Strategy for the Safety of Imported Food (Strategy). In addition, after publishing these initial metrics for the Strategy, the agency will develop additional performance metrics. FDA stated that the COVID-19 situation is quite fluid and the agency is unable to project timelines for developing additional performance measures at this time. We will continue to monitor FDA's planned actions to determine if they satisfy our recommendation.

Recommendation: The Commissioner of FDA should, as the agency develops goals and measures for its imported food safety program, develop performance goals and corresponding performance measures specific to seafood import alerts. (Recommendation 3)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

Comments: FDA agreed with this recommendation. In August 2020, FDA told us that the agency remains committed to developing additional performance goals and measures for its imported food safety program. FDA is still reviewing the Import Alert Effectiveness Program and will consider metrics, as appropriate, based on the outcome of that review. FDA stated that the COVID-19 situation is quite fluid and the agency is unable to project timelines for developing additional performance measures at this time. We will continue to monitor FDA's planned actions to determine if they satisfy our recommendation.

Recommendation: The Executive Director of the Permitting Council should incorporate selected best practices we have identified (maintaining the baseline schedule and conducting a risk analysis) into the Permitting Council's process for developing performance schedules for the infrastructure sectors covered under FAST-41. (Recommendation 1)

Agency: Federal Permitting Improvement Steering Council
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 for Homeland Security should direct the Director of OTE to revise T&E policy or guidance as necessary to fully meet the key practice for programs to test that components and subsystems work together as a system in a controlled setting before finalizing a system's design. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: In providing comments on this report DHS concurred with our recommendation and stated that it planned to update its T&E policy to specify that acquisition programs demonstrate that components and subsystems work together before finalizing a system's design. In July 2020, DHS Test and Evaluation Division (TED) officials said they were in the process of updating the policy and that it was undergoing management review with an anticipated completion in fall 2020. Once finalized, GAO will evaluate the revised policy to determine whether DHS has met the intent of this recommendation.

Recommendation: The Secretary for Homeland Security should direct the Director of OTE, in coordination with OCPO, to develop an assessment process-including establishing performance measures-to help ensure T&E training achieves desired results. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: In providing comments on this report, DHS concurred with our recommendation and stated that it planned to assess the knowledge and skill requirements for the T&E workforce and establish performance goals for the training. DHS Test and Evaluation Division (TED), in coordination with OCPO, also plan to develop strategies to address any deficiencies with the current training that do not meet the identified requirements. In April 2020, TED officials said that they developed a new survey process to obtain recurring feedback from participants on the training's impact on their ability to perform T&E duties as assigned over time to inform the annual review of the T&E curriculum. However, this effort is still in a piloting stage so the extent to which this information is used to assess the training is still unknown at this time. As of July 2020, TED was still in the process of executing these efforts.

Recommendation: The Secretary for Homeland Security should direct the Director of OTE to revise T&E policy or guidance as necessary to specify when in the acquisition life cycle a major acquisition program manager should designate a level III certified T&E manager. (Recommendation 3)

Agency: Department of Homeland Security
Status: Open

Comments: In providing comments on this report DHS concurred with our recommendation and stated that it planned to update its T&E policy to specify when in the acquisition lifecycle acquisition program managers should designate a qualified T&E manager. In July 2020, DHS Test and Evaluation Division (TED) officials said they were in the process of revising the policy to include this specification and that it was undergoing management review with an anticipated completion in fall 2020. Once finalized, GAO will evaluate the revised policy to determine whether DHS has met the intent of this recommendation.

Recommendation: The Secretary for Homeland Security should direct the Director of OTE to establish an internal control process to ensure that data collected and maintained on major acquisition programs' T&E managers are reliable. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: In providing comments on this report, DHS concurred with our recommendation and stated that it planned to establish an internal control process to reliably collect and maintain data on acquisition programs' assigned test and evaluation managers. In April 2020, DHS Test and Evaluation Division (TED) reported taking steps to ensure the validity of this data including establishing points of contacts within each component to cross-check collected information for accuracy and having the Director review collected data on a quarterly basis beginning in third quarter fiscal year 2020. As of July 2020, TED was still in the process of improving its internal collection process, but had not completed these efforts.

Recommendation: The Secretary for Homeland Security should direct the Under Secretary for Science and Technology to assess OTE's workforce to ascertain the extent to which it has the appropriate number of staff with the necessary skills to fulfill its responsibilities. (Recommendation 5)

Agency: Department of Homeland Security
Status: Open

Comments: In providing comments on this report, DHS concurred with our recommendation and stated that it planned to assess the Test and Evaluation Division's (TED) workforce by reviewing current staffing levels and vacancies against the division's roles and responsibilities. The Senior Official Performing the Duties of the Under Secretary for Science and Technology plans to use the results of this review to inform strategic hiring in future years, if needed. In February 2020, DHS released its fiscal year 2020 strategic guidance memorandum for the Science and Technology (S&T) Directorate which included a statement pertaining to resourcing S&T's test and evaluation capabilities. However, as of July 2020, S&T had not yet conducted its review of TED's workforce.

Recommendation: Congress should consider giving CMS authority to establish additional enforcement remedies for hospices that do not meet federal health and safety requirements. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: In October 2019, we suggested that Congress should consider giving CMS authority to establish additional enforcement remedies for hospices that do not meet federal health and safety requirements. As of June 2020, Congress has not implemented this suggestion.

Recommendation: The Administrator of CMS should incorporate the use of additional information, such as quality measures or other information that could identify potential quality of care issues, into its survey process for overseeing hospice providers. (Recommendation 1)

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

Comments: HHS concurred with this recommendation. In May 2020, HHS said CMS is evaluating ways in which the Hospice Consumer Assessment of Health Providers and Systems (CAHPS) survey data can be used to inform surveys of hospice providers. HHS also said CMS intends to incorporate use of the current Hospice Quality Reporting Program (HQRP) measurement data into the survey process to provide additional items that inform a surveyor's evaluation of a hospice provider. HHS noted that these changes would be incorporated into a more comprehensive update to the survey process to target providers and areas where risk of noncompliance is greatest. HHS projected the updated process would be implemented by the end of the first quarter of calendar year 2021. In order for us to close the recommendation, CMS has to implement an updated survey process that incorporates the use of additional information that could identify potential quality of care issues, such as that described above.

Recommendation: The Commissioner of FDA should consult with TTB and CBP to determine and document—for example in Memorandums of Understanding or other written agreements—procedures and time frames for FDA to receive quality data from TTB and CBP that will allow FDA to complete its reconciliation process in a timely manner. (Recommendation 1)

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

Comments: According to HHS, FDA officials met with CBP officials in September, 2019, and with TTB officials in October, 2019, to discuss the development of procedures and time frames for FDA to receive data from the respective entities that will allow FDA to complete its reconciliation process in a timely manner . In August, 2020, FDA reported that the agency had provided a draft agreement to both CBP and TTB subsequent to these meetings, but that agreements had not yet been finalized. Because FDA is still in the process of developing written agreements with CBP and TTB, the recommendation remains open.

Recommendation: The Administrator of the FAA should identify existing or new data and information needed to evaluate oversight activities and develop a mechanism for capturing these data as needed. (Recommendation 3)

Agency: Department of Transportation: Federal Aviation Administration
Status: Open
Priority recommendation

Comments: FAA has concurred with this recommendation. As of April 2020, GAO was working to analyze and evaluate the actions the agency has taken in response.

Recommendation: The Administrator of CMS should expand its review of states' implementation of the provider screening and enrollment requirements to include states that have not made use of CMS's optional consultations. Similar to CMS's contractor site visits, such reviews should include any necessary steps to address areas of noncompliance for all types of enrolled providers, including those under contract with managed care organizations. (Recommendation 1)

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

Comments: CMS concurred with our recommendation. In February 2020, CMS told us that it plans to reach out to states that have not yet participated in its optional consultations to discuss their progress towards implementing provider screening and enrollment requirements, and outline steps that the states should take to come into full compliance with them. In order to fully address this recommendation CMS would need to review all states' implementation of the provider screening and enrollment requirements, including states that have not made use of CMS's optional consultations. As such, this recommendation remains open until CMS provides evidence that it has assessed the compliance of all states; we will continue to monitor CMS's progress.

Recommendation: The Administrator of CMS should annually monitor progress toward addressing any areas of noncompliance related to the provider screening and enrollment requirements for any state with one or more corrective action plans. (Recommendation 2)

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

Comments: As of February 2020, HHS officials have not informed us of any actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information

Recommendation: The Commissioner of the Social Security Administration should ensure that (a) the agency's policies and guidance are specific enough so field office staff know how to apply complex suitability criteria for assessing payee suitability, such as by providing a minimum set of specific questions; and (b) additional regional guidance that is made available to staff is centrally reviewed for compliance and completeness. (Recommendation 1)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation but did not specify plans to address it.

Recommendation: The Commissioner of the Social Security Administration should create safeguards in the Electronic Representative Payee System (eRPS) to ensure that field office staff fully document all required information, such as the rationale for their decision, before approving an application. (Recommendation 2)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and identified actions to address it. Specifically, SSA reported that, as part of implementing the Strengthening Protections for Social Security Beneficiaries Act of 2018, planned changes to eRPS will improve documentation of selection decisions. SSA also reported it will also consider additional enhancements to eRPS in the future. We will consider closing this recommendation when this effort is complete.

Recommendation: The Commissioner of the Social Security Administration should complete a plan, including timeframes, for comprehensively evaluating if and how to leverage external sources of information on organizations' suitability, such as by conducting background checks or credit checks on organizations or key staff that handle beneficiaries' funds or requiring organizations to conduct their own background checks on key staff. (Recommendation 3)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and identified actions to address it. SSA officials stated that it is first focusing on implementing provisions of the Strengthening Protections for Social Security Beneficiaries Act of 2018 related to background checks for certain individual payees. After completing this work, the agency plans to evaluate conducting criminal background checks and credit checks on organizational payees and their staff. While we agree that implementing background screening pursuant to the law should take precedence, SSA should seek opportunities to implement screening for organizational payees at the earliest opportunity.

Recommendation: The Commissioner of the Social Security Administration should develop and implement mechanisms to systematically obtain and review feedback from organizational payees and communicate findings to SSA management. (Recommendation 4)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation but did not identify plans to address it.

Recommendation: The Commissioner of the Social Security Administration should (a) establish a plan and time frame for periodically reviewing the predictive model's design; (b) consider additional data sources that would allow for additional screening or modeling of potentially high-risk organizational payees; and (c) ensure that subsequent design decisions are documented in sufficient detail so the development process can be more fully understood and replicated, either by SSA or a knowledgeable third party, with minimal further explanation. (Recommendation 5)

Agency: Social Security Administration
Status: Open
Priority recommendation

Comments: SSA agreed with this recommendation in 2019 and identified actions to address it. The agency stated that it would pursue other data sources to develop additional screening tools and models to identify potentially high-risk organizational payees, but that it is unable to incorporate additional data into the existing model. They reported they cannot use new data to modify the existing model, which was built from cases and transactions that occurred many years ago. We recognize that the current model, which focuses on misuse findings and is based on historical data, presents challenges for both updating and including new data sources. Therefore, as SSA considers additional screening tools and models to identify high-risk, low-volume organizational payees, SSA should develop a plan for revising the existing model that allows for more timely updates and results in documentation of related design decisions. In April 2020, SSA officials reported that the agency is finalizing a plan to revise the existing model and would pursue other data sources to develop additional screening tools and models to identify potentially high-risk organizational payees.

Recommendation: The Commissioner of the Social Security Administration should require field offices to contact payees about missing or problematic annual accounting forms within a specific time frame. (Recommendation 6)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation but did not identify plans to address it.

Recommendation: The Commissioner of the Social Security Administration should revise the annual accounting form to enhance its effectiveness. Such revisions could include (but not be limited to) more fully ascertaining the use of collective accounts, adopting stakeholders' recommendations on using the form to collect more meaningful data, and reflecting best practices from behavioral science insights in the design of the form. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation but did not identify plans to address it.

Recommendation: The Commissioner of the Social Security Administration should enhance the eRPS system to ensure that field offices are (a) alerted when collective accounts are due to be reviewed; and (b) able to take action on expired collective account information and thereby avoid payees' continued use of these accounts without oversight. (Recommendation 8)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and identified actions to address it. SSA officials reported that they would work with staff to ensure staff know where to find alerts for expiring accounts and enhance how eRPS displays information on collective accounts that have already expired. We agree with SSA's proposed actions. However, we adjusted our recommendation to clarify that SSA should enhance eRPS in a manner that ensures staff take action on expired accounts and that payees do not continue to use expired accounts without oversight.

Recommendation: The Commissioner of the Social Security Administration should, as it carries through with its plan to develop a risk assessment for the organizational payee program, ensure that that the plan reflects periodic consideration of findings from onsite reviews and audits. (Recommendation 9)

Agency: Social Security Administration
Status: Open
Priority recommendation

Comments: SSA agreed with this recommendation. In April 2020, SSA officials reported starting its Representative Payee Fraud Risk Assessment. We will consider closing this recommendation when SSA ensures that its risk assessment plan reflects periodic consideration of findings from onsite reviews and audits.

Recommendation: Congress should consider giving BLM the authority to obtain funds from operators to reclaim orphaned wells, and requiring BLM to implement a mechanism to obtain sufficient funds from operators for reclaiming orphaned wells. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: Congress has not taken action as of April 2020.

Recommendation: The Director of BLM should take steps to adjust bond levels to more closely reflect expected reclamation costs, such as by increasing regulatory minimums to reflect inflation and incorporating consideration of the number of wells on each bond and their characteristics. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In a August 2019 letter to GAO, BLM noted Instruction Memorandum 2019-014, "Oil and Gas Bond Adequacy Reviews", related to the agency's response to this recommendation. The Instruction Memorandum does not increase regulatory minimums to reflect inflation or incorporate the consideration of the number of wells on each bond and their characteristics, but BLM is collecting data to determine the effectiveness of this Instruction Memorandum. BLM noted any further action will depend on the results of the data analysis, expected to be continued through the first quarter of Fiscal Year 2021. As of April 2020 this recommendation remains open.

Recommendation: The Commissioner of Internal Revenue should undertake a risk assessment of tax-exempt entity Form 8886-T filings. Based on the findings of the risk assessment, IRS should then determine whether steps are needed to increase compliance, such as, for example, through increased outreach to tax-exempt entities or assessment of nonfiling penalties. (Recommendation 1)

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

Comments: IRS agreed with the recommendation. In a July 2020 letter to GAO, IRS said the Tax Exempt/Government Entities division is documenting the process for reviewing Form 8886-T filings and analyzing whether all tax-exempt entities that should file Form 8886-T are filing it as required. As of August 2020, IRS officials expected to complete their analysis in November 2020. GAO continues to monitor IRS's progress.

Recommendation: The Commissioner of Internal Revenue should link audit data on abusive tax schemes involving tax-exempt entities across operating divisions and use the linked data to assess emerging issues and develop policy responses. (Recommendation 2)

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

Comments: In July 2020, IRS officials said they were working to determine if database coding on abusive schemes involving tax-exempt entities can be added across the agency's audit divisions. As of August 2020, IRS officials said this work will be done by June 2021. GAO continues to monitor IRS's progress.

Recommendation: The Commissioner of Internal Revenue should test the ability of the Return Inventory Classification System to facilitate analysis and monitoring of audit data across the operating divisions and to support the IRS's enforcement objectives. (Recommendation 3)

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

Comments: In a July 2020 letter 2020, IRS officials said they agreed with this recommendation and have begun to analyze its feasibility. IRS's plans include determining if the Return Inventory Classification System (RICS) could support analysis and monitoring of audit data across IRS's operating divisions. To that end, IRS plans to host cross-divisions meetings to determine what data can be shared and how the data can be monitored with RICS. As of August 2020, IRS expected to complete its analysis by March 2022. GAO continues to monitor IRS's progress.

Recommendation: The Commissioner of Internal Revenue should use existing data analytic tools to further mine Form 8886 and Form 8918 data, which could be used to find audit leads on tax-exempt entity involvement in potentially abusive tax schemes. (Recommendation 4)

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

Comments: In a July 2020 letter, IRS said it will explore the use of existing data analytic tools to mine data and to identify undiscovered exempt-entity involvement in abusive tax schemes. As part of that effort, IRS plans to continue to evolve its text processing. IRS also plans to determine if optical character recognition can be used to identify keywords in disclosure reports that could help determine whether a tax-exempt entity was a party to a reportable transaction that warrants further investigation and whether that would be productive. As of August 2020, IRS expected to complete its analysis by March 2022. GAO continues to monitor IRS's progress.

Recommendation: The Commissioner of Internal Revenue should develop guidance to help managers ensure referrals about abusive schemes involving tax-exempt entities are made across operating divisions. This could be accomplished by, for example, adopting specific guidance for audit managers to look for referral accuracy in their reviews of case closings. (Recommendation 5)

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

Comments: In a July 2020 letter, IRS said it agreed with the recommendation and will develop guidance to assist mangers across the agency's divisions to ensure referrals involving tax-exempt entities are directed to the Tax Exempt/Government Entities (TE/GE) division. The letter also said IRS plans to provide training across examination units to instruct staff to make referrals appropriately and correctly. IRS expects to complete the TE/GE guidance and training material by June 2021. As of August 2020, TE/GE officials said the other examination divisions are expected to incorporate the forthcoming procedural guidance in their work processes by 2022. GAO continues to monitor IRS's progress.

Recommendation: The Administrator of CMS should work with states and relevant federal agencies to collect accurate and complete data on blood lead screening for Medicaid beneficiaries in order to ensure that CMS is able to monitor state compliance with its blood lead screening policy, and assist states with planning improvements to address states' compliance as needed. (Recommendation 1)

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

Comments: In June 2020, Centers for Medicare & Medicaid Services (CMS) officials said that obtaining complete data on blood lead screenings for children enrolled in Medicaid will not be possible, but that the agency is committed to improving the accuracy and completeness of the data. For example, in February 2020, CMS reported that the agency is planning to use a new data system-as states meet certain data quality and completeness benchmarks for the system-to generate the report that includes states' blood lead screening data. CMS stated that this will improve the agency's and states' ability to assess gaps in blood lead screening data. This is a positive step, yet any new data system will also need to consider how to help address known limitations in the current blood lead screening data, such as the under-counting of blood lead screening tests not paid for by Medicaid. To implement this recommendation, CMS should address limitations in blood lead screening data to better monitor compliance with the agency's blood lead screening policy.

Recommendation: The Administrator of CMS should regularly assess the appropriateness of performance measures and targets for the EPSDT benefit, and take any necessary actions to ensure their relevance and use, including adding, changing, or removing measures, or targets, and regularly communicating performance measures and targets to states. (Recommendation 2)

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

Comments: In June 2020, CMS officials reiterated that they do not concur with this recommendation, in part because the agency does not have the authority to set binding targets for every EPSDT measure. As we stated in our report, our recommendation does not assume that targets should be set for every measure--rather, that CMS needs to regularly assess the appropriateness of performance measures and targets for the EPSDT benefit and communicate them to states. This includes assessments of the CMS-416 performance measures, such as the participant and screening ratios. which CMS officials acknowledge have limitations.

Recommendation: The Administrator of CMS should conduct regular evaluations of state performance by comparing states' performance measurement data with CMS's EPSDT targets to identify gaps in states' performance and areas for improvement. (Recommendation 3)

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

Comments: In June 2020, CMS officials reiterated that they do not concur with this recommendation, in part because the agency provides states with information about their performance on ESPDT measures reported on the Child Core Set, including a state's performance relative to other states' performance. We noted the limitations of this approach in our report; descriptions of a state's performance relative to other states is subject to change over time. For example, because the median is the midpoint of all states' performance, it ensures that half of states will not meet it, regardless of their individual performance. A fixed target--or targeted improvement goal, such as the one developed as part of the Oral Health Initiative--would provide states with the opportunity to measure performance over prior years' results, which is a more meaningful measure that all states can strive to achieve.

Recommendation: The Administrator of CMS should assist states with planning needed improvements, including providing focused assistance, to resolve gaps in states' performance in meeting CMS's EPSDT targets. (Recommendation 4)

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

Comments: In June 2020, CMS officials reiterated that they do not concur with this recommendation, in part because the agency does not believe that it is productive or appropriate to set targets for every EPSDT measure. As we stated in our report, our recommendation does not assume that targets should be set for every measure. However, developing additional targets on performance measures critical to beneficiaries' health and well-being could help improve oversight of EPSDT. Targeted technical assistance could be valuable for CMS to provide to states after identifying gaps in states' performance relative to EPSDT targets. Doing so would allow CMS to share additional strategies to help states plan and implement needed improvements.

Recommendation: The Administrator of CMS should develop a plan with time frames and interim milestones for using T-MSIS data to generate the necessary data from the Child Core Set to improve EPSDT oversight and streamline state reporting. (Recommendation 6)

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

Comments: In June 2020, CMS officials said that they are currently exploring the feasibility of using T-MSIS data to generate certain Child Core Set measures. Specifically, the agency is conducting a pilot with five Child Core Set measures. CMS officials said that they will use the pilot's results to determine the timeline for generating the additional Child Core Set measures through T-MSIS. GAO will continue to follow the agency's progress on this activity.

Recommendation: The Secretary of Defense should direct the Director of the Defense Security Cooperation Agency to establish processes to ensure that information on the provision of Section 333 mandated human rights training is systematically and accurately entered into its tracking systems. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: In December 2019, DOD agreed with the recommendation and stated that the Defense Security Cooperation Agency needs to establish reporting procedures with geographic combatant commands and is working to determine the feasibility and requirements to modify existing systems to enable tracking of mandated human rights training. As of July 2020, DSCA was considering options for such changes.

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense for Policy to develop a timeline for implementing its activities to monitor and evaluate the effectiveness of human rights training for foreign security forces. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: In December 2019, DOD concurred with the recommendation and said it would monitor and evaluate human rights training as part of monitoring and evaluating its broader security assistance efforts. As of July 2020, DOD was considering how it would implement these changes.

Recommendation: The Secretary of State, in consultation with the Secretary of Defense, should develop a plan with a clear timeline for monitoring and evaluating the effectiveness of human rights training for foreign security forces provided under International Military Education and Training. (Recommendation 3)

Agency: Department of State
Status: Open

Comments: In December 2019, State wrote that it did not agree to separately conduct monitoring and evaluation of human rights training provided under the International Military Education and Training (IMET) program. GAO's recommendation does not call for a separate evaluation. State could meet the intent of the recommendation through evaluating the effectiveness of human rights training as part of its broader efforts to monitor and evaluate IMET. As of June 2020, State indicated they had no plans to evaluate the effectiveness of human rights training related to IMET.

Recommendation: The Commissioner of CBP should review and update policies related to land port of entry inspections in accordance with Office of Field Operations guidance. (Recommendation 1)

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

Comments: CBP concurred with the recommendation and stated that it intends to implement it by January 2021. We will continue to monitor CBP's ongoing efforts to do so.

Recommendation: The Commissioner of CBP should analyze the results of the Self-Inspection Program over time and at a level necessary to identify and address potentially reoccurring inspection deficiencies at individual ports of entry. (Recommendation 2)

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

Comments: CBP concurred with the recommendation and stated that it intends to implement it by November 2021. We will continue to monitor CBP's ongoing efforts to do so.

Recommendation: The Commissioner of CBP should implement a policy to conduct periodic comprehensive analyses of covert test findings. (Recommendation 3)

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

Comments: CBP concurred with the recommendation and, in March 2020, it provided information on its plans to conduct a comprehensive analysis after completing several covert tests. To fully address this recommendation, CBP should implement a policy to conduct periodic comprehensive analyses of covert test findings. We will continue to monitor CBP's ongoing efforts to do so.

Recommendation: The Commissioner of CBP should develop a new target for the land border interception rate for passengers in privately-owned vehicles with major violations that sets an ambitious and realistic goal based on past performance. (Recommendation 4)

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

Comments: CBP concurred with the recommendation and stated that it intends to implement it by January 2021. We will continue to monitor CBP's ongoing efforts to do so.

Recommendation: The Director of National Intelligence should establish and document results-oriented goals that include specific targets or milestones for the IC CAE program. (Recommendation 1)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: The Office of the Director of National Intelligence (ODNI) concurred with this recommendation. In its August 2020 response, ODNI noted that in preparation for the transition of the Intelligence Community Centers for Academic Excellence (IC CAE) program from the Defense Intelligence Agency to ODNI, the ODNI commissioned an independent study in 2019 to assess program performance and barriers to success. ODNI noted that this study, in conjunction with the GAO report, are informing the development of a program strategy and sound business practices that will prescribe goals and measurable objectives. These efforts are expected to be completed in late 2020, at which time ODNI plans to develop a companion Strategic Implementation Plan that will set the foundation for behavior and reporting criteria across all IC CAE grant-receiving institutions, legacy schools, and stakeholders. ODNI noted that the plan which is expected to be completed in the third quarter of fiscal year 2021, will include an annual evaluation process linked to survey results and documented lessons learned. We will continue to monitor the status of this recommendation.

Recommendation: The Director of National Intelligence should establish and document strategies to achieve the results-oriented goals that are established for the IC CAE program. (Recommendation 2)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: The Office of the Director of National Intelligence (ODNI) concurred with this recommendation. In its August 2020 response, ODNI noted that in preparation for the transition of the Intelligence Community Centers for Academic Excellence (IC CAE) program from the Defense Intelligence Agency to ODNI, the ODNI commissioned an independent study in 2019 to assess program performance and barriers to success. ODNI noted that this study, in conjunction with the GAO report, are informing the development of a program strategy and sound business practices that will prescribe goals and measurable objectives. These efforts are expected to be completed in late 2020, at which time ODNI plans to develop a companion Strategic Implementation Plan that will set the foundation for behavior and reporting criteria across all IC CAE grant-receiving institutions, legacy schools, and stakeholders. ODNI noted that the plan which is expected to be completed in the third quarter of fiscal year 2021, will include an annual evaluation process linked to survey results and documented lessons learned. We will continue to monitor the status of this recommendation.

Recommendation: The Director of National Intelligence should develop and document a process to identify and continuously evaluate external factors that could affect the program's ability to achieve identified goals. This should include, but not be limited to, a consideration of program branding and post-grant sustainment. (Recommendation 3)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: The Office of the Director of National Intelligence (ODNI) concurred with this recommendation. In its August 2020 response, ODNI noted that in preparation for the transition of the Intelligence Community Centers for Academic Excellence (IC CAE) program from the Defense Intelligence Agency to ODNI, the ODNI commissioned an independent study in 2019 to assess program performance and barriers to success. ODNI noted that this study, in conjunction with the GAO report, are informing the development of a program strategy and sound business practices that will prescribe goals and measurable objectives. These efforts are expected to be completed in late 2020, at which time ODNI plans to develop a companion Strategic Implementation Plan that will set the foundation for behavior and reporting criteria across all IC CAE grant-receiving institutions, legacy schools, and stakeholders. ODNI noted that the plan which is expected to be completed in the third quarter of fiscal year 2021, will include an annual evaluation process linked to survey results and documented lessons learned. We will continue to monitor the status of this recommendation.

Recommendation: The Director of National Intelligence should define and document comprehensive performance measures for the IC CAE program, collect and evaluate the completeness and reliability of information it receives from grant recipients and IC elements, and report this information on a regular basis. (Recommendation 4)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: The Office of the Director of National Intelligence (ODNI) concurred with this recommendation. In its August 2020 response, ODNI noted that it held virtual listening session in early fiscal year 2020 with Intelligence Community Centers for Academic Excellence (IC CAE) program managers and principal investigators to inform the development of meaningful performance measures and reporting criteria. ODNI noted that the criteria was collected using standardized, repeatable processes to ensure both accuracy and completeness during site visits and performance reviews for active grant recipients. ODNI further noted that it plans to integrate the criteria from the listening sessions into the Strategic Implementation Plan, which it expects to complete in the third quarter of fiscal year 2021. We will continue to monitor the status of this recommendation.

Recommendation: The Director of National Intelligence should establish a requirement for and develop a plan to periodically evaluate the IC CAE program's performance through objective measurement and systematic analysis. (Recommendation 5)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: The Office of the Director of National Intelligence (ODNI) concurred with this recommendation. In its August 2020 response, ODNI noted that it held virtual listening session in early fiscal year 2020 with Intelligence Community Centers for Academic Excellence (IC CAE) program managers and principal investigators to inform the development of meaningful performance measures and reporting criteria. ODNI noted that the criteria was collected using standardized, repeatable processes to ensure both accuracy and completeness during site visits and performance reviews for active grant recipients. ODNI further noted that it plans to integrate the criteria from the listening sessions into the Strategic Implementation Plan, which it expects to complete in the third quarter of fiscal year 2021. We will continue to monitor the status of this recommendation.

Recommendation: The Director of National Intelligence should develop a process for assessing why some IC elements are not participating in the IC CAE program and address these reasons in order to ensure the program is structured to meet the needs of IC elements. (Recommendation 6)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: The Office of the Director of National Intelligence (ODNI) concurred with this recommendation. In its August 2020 response, ODNI noted that was in the process of developing an engagement strategy for the reintegration of Intelligence Community Centers for Academic Excellence (IC CAE) legacy schools to ensure prior investments are capitalized on and to maximize outreach efforts. ODNI also noted that it is routinely leveraging multiple interagency IC-wide working groups to engage with IC elements and stakeholders to increase its understanding of barriers to engaging with IC CAE, as well as to develop a community-wide understanding of the benefits associated with engagement. ODNI plans to include the results in the Strategic Implementation Plan, which it expects to complete in the third quarter of fiscal year 2021, and noted that it will routinely update these efforts to ensure best practices are being implemented. The ODNI stated that it will use this ongoing process and dialogue to assess and seek to address such barriers and to improve ongoing IC element participation. We will continue to monitor the status of this recommendation.

Recommendation: The Director of National Intelligence should clearly define IC elements' roles and responsibilities for participation in the IC CAE program to better facilitate interagency collaboration in support of the program. (Recommendation 7)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: The Office of the Director of National Intelligence (ODNI) concurred with this recommendation. In its March 2020 response, ODNI noted that it was leveraging multiple interagency forums in an effort to improve IC element participation in the IC CAE program. ODNI also noted that it would and encourage the standardization and use of common practices by leveraging IC CAE schools for recruitment and hiring within diverse communities. Together, ODNI noted that it will use input from these efforts to shape a collaborative way ahead for increased and improved IC engagement based on community roles and responsibilities. These efforts will also be integrated into the program's Strategic Implementation Plan, which is expected to be completed in late 2021 and will set the foundation for behavior and reporting criteria across all IC CAE institutions and stakeholders. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Homeland Security should develop performance metrics for the department's EEO program including a mechanism for tracking progress towards eliminating barriers. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: On August 18, 2020, DHS informed us that the work it is undertaking to respond to this recommendation is ongoing.

Recommendation: DHS component EEO Directors, in consultation with the Deputy Officer for EEO and Diversity, should develop policies and procedures to help ensure that their component EEO programs have action plans for addressing deficiencies in their Management Directive 715 (MD-715) reports. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: On May 11, 2020, DHS provided GAO with copies of standard operating procedures for addressing EEO program deficiencies for seven out of eight operational components as well as DHS headquarters. Each of the components' standard operating procedures require that action plans are in place to address any outstanding EEO program deficiencies.

Recommendation: The Deputy Officer for EEO and Diversity should develop a formal staffing model for its EEO program. (Recommendation 3)

Agency: Department of Homeland Security
Status: Open

Comments: On August 18, 2020, DHS informed us that the work it is undertaking to respond to this recommendation is ongoing.

Recommendation: DHS component EEO Directors, in collaboration with the Deputy Officer for EEO and Diversity, should develop component formal staffing models. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: On August 18, 2020, DHS informed us that the work it is undertaking to respond to this recommendation is ongoing.

Recommendation: The Secretary of Homeland Security—in consultation with the Office for Civil Rights and Civil Liberties (CRCL) and EEOC, and other agencies and components, as relevant—should analyze options for granting additional authorities to the Deputy Officer for EEO and Diversity to ensure DHS components comply with MD-715 guidance, including the authority of the Deputy Officer for EEO and Diversity to certify components' MD-715 reports. (Recommendation 6)

Agency: Department of Homeland Security
Status: Open

Comments: On August 18, 2020, DHS informed us that the work it is undertaking to respond to this recommendation is ongoing.

Recommendation: The FTA administrator should ensure that FTA's cost estimating information for project sponsors is consistent with all 12 steps found in GAO's Cost Estimating and Assessment Guide and needed for developing reliable cost estimates. [Recommendation 1]

Agency: Department of Transportation: Federal Transit Administration
Status: Open

Comments: As of March 2020, FTA had posted GAO's Cost Estimating and Assessment Guide to its website. However, FTA has yet to update its cost estimating information, which does not align with GAO's best practices in five areas: (1) risk and uncertainty analysis; (2) sensitivity analysis; (3) identifying ground rules and assumptions; (4) obtaining the data; and (5) presenting cost estimates to management. GAO continues to believe that because FTA's cost estimating information does not align with all 12 steps found in GAO's Cost Estimating and Assessment Guide, FTA lacks reasonable assurance that sponsors have developed and communicated high-quality cost estimates. We will continue to monitor FTA's actions.

Recommendation: The FTA Administrator should provide a central, easily accessible source with all of FTA's cost estimating information to help project sponsors improve the reliability of their cost estimates. [Recommendation 2]

Agency: Department of Transportation: Federal Transit Administration
Status: Open

Comments: As of March 2020, FTA had developed a webpage with some cost estimating information for project sponsors. However, the website did not include key information for project sponsors which FTA had previously provided to GAO for its analysis of cost estimating information. We continue to believe that providing a centralized location to share existing FTA documentation with sponsors, and ensuring that the documentation incorporates best practices from GAO's Cost Estimating and Assessment Guide, such as sensitivity analyses, could improve the reliability of sponsors' cost estimates and could reduce the risk of cost overruns for Capital Investment Grant (CIG) New Starts applicants and grantees. We will continue to monitor FTA's actions to address this recommendation.

Recommendation: The Director of CFPB should communicate to CRAs its expectations regarding reasonable procedures for assuring maximum possible accuracy of consumer report information. (Recommendation 1)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: In a January 2020 update, CFPB reemphasized statements made in its comment letter, including its expectation for CRAs to fully comply with applicable federal consumer financial laws and the role of case law in providing guidance to CRAs. CFPB additionally noted that its publicly available examination procedures discuss factors that CFPB will consider in evaluating compliance with the reasonableness standard under the Fair Credit Reporting Act (FCRA). CFPB stated that since publication of the report, it has taken actions to convey expectations to CRAs, including holding a joint workshop with FTC in December 2019 on consumer reporting accuracy and publishing a Supervisory Highlights special edition focused on consumer reporting. More direct communication of CFPB's expectations can provide CRAs with clearer information on what actions might constitute a FCRA violation and how CRAs should comply with the reasonableness standard. We maintain that providing additional information to CRAs about its expectations for key FCRA requirements could help CFPB to promote consistency and transparency in its supervisory approach and that the recommendation should be addressed.

Recommendation: The Director of CFPB should communicate to CRAs its expectations regarding reasonable investigations of consumer disputes. (Recommendation 2)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: In a January 2020 update, CFPB restated the requirements for a reasonable investigation under the Fair Credit Reporting Act (FCRA) and noted that court cases have articulated what qualifies as a reasonable investigation. CFPB also noted that a 2011 FTC report summarizes how the courts and FTC have interpreted these obligations, and that CFPB issued a bulletin on reasonable investigations in September 2013. CFPB stated that it has and will continue to communicate its expectations to CRAs regarding applicable provisions of FCRA. We maintain that providing additional information to CRAs about its expectations for key FCRA requirements could help CFPB to promote consistency and transparency in its supervisory approach and that the recommendation should be addressed.

Recommendation: The Under Secretary of Health should require that all failures to meet quality standards are cited as deficiencies on SVH inspections. (Recommendation 2)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VA concurred with this recommendation and, as of July 2020, had taken some initial steps to address the recommendation such as modifying the SVH contractor's contract to stop the practice of using 'recommendations' for low-level deficiencies and beginning the process of revising a VA policy to address this practice.

Recommendation: The Under Secretary of Health should develop guidance for Veterans Affairs Medical Center staff conducting optional onsite CNH reviews. (Recommendation 3)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VA concurred in principle with this recommendation and indicated in January 2020 that it had begun taking actions to address this recommendation such as developing a memo of clarification and planning the release of additional guidance for staff.

Recommendation: The Under Secretary of Health should provide information on the quality of all SVHs that is comparable to the information provided on the other nursing home settings on its Access to Care website. (Recommendation 4)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VA concurred in principle and, as of July 2020, had begun taking some steps to address this recommendation such as exploring options for presenting SVH quality measure data.

Recommendation: The Commissioner of FHA should enhance the content and communication of FHA's policies and procedures on conveyance condition, including by considering the program stakeholder views discussed in this report and other stakeholder input. (Recommendation 1)

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

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

Recommendation: The Commissioner of FHA should develop a formal plan for evaluating the outcomes of the preconveyance inspection pilot that includes key elements of evaluation design—such as evaluation objectives and measures—and utilizes participant feedback and control groups, as appropriate. (Recommendation 3)

Agency: Department of Housing and Urban Development: Federal Housing Administration
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 for Health should develop a process to assess the overall performance of VISNs in managing and overseeing medical centers. (Recommendation 1)

Agency: Department of Veterans Affairs: Office of the Under Secretary for Health
Status: Open

Comments: VHA concurred with our recommendation. In December 2019, VHA reported efforts to modernize its governance structure with a newly created VHA Governance Board. In February 2020, VHA reported additional efforts to charter governance councils to support the VHA Governance Board and work continues to develop these councils and responsibilities, with a target completion date of September 2020. For closure, VHA will need to provide documentation that shows the process developed to assess the overall performance of VISNs in managing medical centers. Providing documentation explaining how these governance structures plan to assess overall VISN performance, including any metrics or tools that would be used as a part of this process, would be useful in determining if this recommendation can be considered for closure.

Recommendation: The Under Secretary for Health should establish a comprehensive policy that clearly defines VISN roles and responsibilities for managing and overseeing medical centers. (Recommendation 2)

Agency: Department of Veterans Affairs: Office of the Under Secretary for Health
Status: Open
Priority recommendation

Comments: VHA concurred in principle with our recommendation. In December 2019, VHA told us they were working to streamline reporting structures at all levels, focusing on governance and workflow, including defining consistent levels of authority. In February 2020, VHA told us they were realigning Central Office in addition to making changes to the governance structure to support clarity of roles and responsibilities. VHA plans to crosswalk existing policies to the new structure and organizations, with a target completion date of September 2020. Following completion of VHA's efforts to streamline Central Office and ensure reporting structures are in place, VHA will need to provide policy documentation that clearly outlines VISN roles and responsibilities, including how these governance structures plan to define the VISN's roles and responsibilities. While governance and reporting structures are a first step, it is important for roles and responsibilities to be clearly outlined in a policy vehicle, as VHA requires the use of policy to assign responsibilities for executing a course of action to individuals or groups.

Recommendation: The Under Secretary for Health should establish a process to routinely oversee VISN staffing, to include ensuring VISNs are consistent with VHA's standardized VISN staffing levels and positions, and documenting the rationale for approving staffing that does not adhere to VHA's standardized approach. (Recommendation 3)

Agency: Department of Veterans Affairs: Office of the Under Secretary for Health
Status: Open

Comments: VHA concurred with our recommendation. In December 2019, VHA reported its office for Manpower Management began reviewing changes to VISN organizational structure and positions. In February 2020, VHA provided GAO with the guidance for VISN staffing and a draft Manpower Management directive, with target completion date of May 2020 for approval. For closure, VHA should provide the approved VA Directive 5010 documentation outlining the process developed to routinely oversee VISN staffing, including efforts by the DUSHOM in partnership with Workforce Management and Consulting and Manpower and Management, such as policy directives, organizational charts, amongst others.

Recommendation: The Administrator of GSA should take steps to reconcile G-REX and the Federal Real Property Profile to the extent practical. (Recommendation 1)

Agency: General Services Administration
Status: Open

Comments: GSA is taking steps to implement this recommendation. GSA staff summarized the agency's approach to addressing the recommendation in a January 2020 meeting. GAO agreed to check progress with GSA in the summer of 2020.

Recommendation: The Administrator of GSA should develop a process for assessing at regular intervals, such as annually, agencies' policies and procedures for managing their delegated leasing activities. (Recommendation 2)

Agency: General Services Administration
Status: Open

Comments: GSA is taking steps to implement this recommendation. GSA staff summarized the agency's approach to addressing the recommendation in a January 2020 meeting. GAO agreed to check progress with GSA in the summer of 2020.

Recommendation: The Administrator of GSA should develop a process that would allow GSA to track agencies' progress in meeting GSA management goals, such as cost effective lease rates, and avoiding holdovers. (Recommendation 3)

Agency: General Services Administration
Status: Open

Comments: GSA is taking steps to implement this recommendation. GSA staff summarized the agency's approach to addressing the recommendation in a January 2020 meeting. GAO agreed to check progress with GSA in the summer of 2020.

Recommendation: The Administrator of GSA should develop a systematic, risk-based process for monitoring a selection of submitted post award documents. (Recommendation 4)

Agency: General Services Administration
Status: Open

Comments: GSA is taking steps to implement this recommendation. GSA staff summarized the agency's approach to addressing the recommendation in a January 2020 meeting. GAO agreed to check progress with GSA in the summer of 2020.

Recommendation: The Director of ONRR should establish an accuracy goal (e.g., identifying the number of companies or percentage of royalties subject to compliance activities over a set period of time) that aligns with the agency's mission of collecting, accounting for, and verifying royalty payments. In doing so, ONRR should track the extent to which each compliance activity (audits, compliance reviews, and data mining) contributes toward achieving this goal. (Recommendation 1)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by December 31, 2021.

Recommendation: The Director of ONRR should develop a documented case selection process that includes procedures for how to select all compliance cases. (Recommendation 2)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by April 30, 2021.

Recommendation: The Director of ONRR should develop performance measures (e.g., having a specified percentage of compliance cases identify findings of royalty noncompliance or total additional royalties) that assess whether the cases the agency is selecting are helping it achieve its compliance goals. (Recommendation 3)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by December 31, 2022.

Recommendation: The Director of ONRR should periodically analyze whether the risk model is effectively identifying potential royalty noncompliance and whether the model's results are being effectively used to assist in case selection, and should use this analysis to make changes to the model (e.g., updating it) or develop a new model. (Recommendation 4)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by June 30, 2021.

Recommendation: The Director of ONRR should include requirements in ONRR's agreements with State and Tribal Royalty Audit Committee (STRAC) members to develop a documented case selection process, including procedures for how to select compliance cases and how to document which factors were considered in selection decisions. (Recommendation 5)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by November 30, 2020.

Recommendation: The Director of ONRR should require STRAC members to describe in their annual work plans how their compliance activities would align with ONRR's current compliance goals. (Recommendation 6)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by November 30, 2020.

Recommendation: The Director of ONRR should track the performance of the compliance work of each state STRAC member and the contribution that each state makes to ONRR's compliance goals. (Recommendation 7)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by March 31, 2021.

Recommendation: The Director of the Division of Risk Management Supervision of FDIC should take steps to improve the completeness of matters requiring board attention (MRBA) data in its tracking system, in particular, by developing a structure that allows examiners to record MRBAs at progressively more granular levels (from a broad level such as examination area to more specific levels, including risk or concern type). (Recommendation 3)

Agency: Federal Deposit Insurance Corporation
Status: Open

Comments: FDIC agreed that a structure should be enhanced to allow staff to further categories MRBAs at the point of entry into the system. As of March 2020, no action has been taken on this recommendation. GAO will continue to monitor for any updates to FDIC procedures.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for the Special Operations and Low-Intensity Conflict updates existing guidance or develops new guidance to clarify the roles and responsibilities of the Assistant Secretary of Defense for SO/LIC and relationships with DOD components that have vested interests in the SOF enterprise—such as the military services, SOCOM, the Under Secretary of Defense for Personnel and Readiness, and the Under Secretary of Defense for Policy. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with GAO's May 2019 recommendation that ASD-SO/LIC update existing guidance or develop new guidance to clarify the roles and responsibilities of ASD-SO/LIC and relationships with DOD components that have vested interests in the SOF enterprise-such as the military services and SOCOM to name a few. In September 2020, ASD-SO/LIC officials stated that DOD is in the process of revising guidance that would help clarify ASD- SO/LIC's roles and responsibilities. DOD estimated that this will not be completed until January 2025.

Recommendation: The Director of OMB should ensure that information is collected regarding how centralized reporting of procurement requirements might reduce recipient reporting burden—including input from stakeholders such as contractors through an iterative and ongoing process—to inform OMB's planned expansion of the Central Reporting Portal.

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

Comments: In an October 2019 written response to the recommendation contained in GAO-19-299, OMB acknowledged the importance of collecting stakeholder input and described some steps that it has taken to do so in the past. The letter also stated OMB's intention to engage key stakeholders moving forward but was not specific regarding steps it planned to take related to the potential expansion of the Central Reporting Portal. GAO will continue to monitor this issue including what specific actions, if any, OMB takes in response to this recommendation.

Recommendation: The Secretary of the Army should ensure that Army Materiel Command establishes measures for its depots to track facility or equipment conditions that lead to maintenance delays. (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 the Army should ensure that Army Materiel Command implements tracking of the measures for identifying when facility or equipment conditions lead to maintenance delays at each Army depot. (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 the Navy should ensure that Naval Sea Systems Command and the Commander, Fleet Readiness Centers establish measures for their depots to track facility or equipment conditions that lead to maintenance delays. (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 the Navy should ensure that Naval Sea Systems Command and the Commander, Fleet Readiness Centers implement tracking of the measures for identifying when facility or equipment conditions lead to maintenance delays at each Navy depot. (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 the Air Force should ensure that Air Force Materiel Command establishes measures for its depots to track facility or equipment conditions that lead to maintenance delays. (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 the Air Force should ensure that Air Force Materiel Command implements tracking of the measures for identifying when facility or equipment conditions lead to maintenance delays at each Air Force depot. (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 Commandant of the Marine Corps should ensure that Marine Corps Logistics Command establishes measures for its depots to track facility or equipment conditions that lead to maintenance delays. (Recommendation 7)

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 Commandant of the Marine Corps should ensure that Marine Corps Logistics Command implements tracking of the measures for identifying when facility or equipment conditions lead to maintenance delays at each Marine Corp depot. (Recommendation 8)

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 the Army should ensure that Army Materiel Command incorporates in its depot optimization plan, key results-oriented elements including analytically-based goals, results-oriented metrics, identification of required resources, risks, and stakeholders, and regular reporting to decision makers on progress. (Recommendation 9)

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 the Navy should ensure that Commander, Fleet Readiness Centers incorporates in its depot optimization plan, key results-oriented elements including analytically-based goals, results-oriented metrics, identification of required resources, risks, and stakeholders, and regular reporting to decision makers on progress. (Recommendation 10)

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 the Air Force should ensure that Air Force Materiel Command incorporates in its depot optimization plan, key results-oriented elements including analytically-based goals, results-oriented metrics, identification of required resources, risks, and stakeholders, and regular reporting to decision makers on progress. (Recommendation 11)

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 Commandant of the Marine Corps should ensure that Marine Corps Logistics Command incorporates in its depot optimization plan, key results-oriented elements including analytically-based goals, results-oriented metrics, identification of required resources, risks, and stakeholders, and regular reporting to decision makers on progress. (Recommendation 12)

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 ensure that the Assistant Secretary of Defense for Sustainment develops an approach for managing service depot investments that includes management monitoring and regular reporting to decision makers and Congress on progress. (Recommendation 13)

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: CMS should evaluate state survey agency processes in all states to ensure all state survey agencies are meeting federal requirements that state survey agencies are responsible for investigating complaints and facility-reported incidents alleging abuse in nursing homes, and that the results of those investigations are being shared with CMS. (Recommendation 1)

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

Comments: HHS concurred with this recommendation. As of November 2019, HHS officials have not informed us of actions taken to complete implementation of this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: CMS should identify options for capturing information from Oregon's APS investigations of complaints and facility-reported incidents of abuse and incorporate this information into oversight of Oregon nursing homes. (Recommendation 2)

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

Comments: HHS concurred with this recommendation. As of November 2019, HHS officials have not informed us of actions taken to complete implementation of this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: Congress should consider amending the Internal Revenue Code, Bank Secrecy Act of 1970, and other statutes, as needed, to address overlap in foreign financial asset reporting requirements for the purposes of tax compliance and detection, and prevention of financial crimes, such as by aligning the types of assets to be reported and asset reporting thresholds, and ensuring appropriate access to the reported information.

Agency: Congress
Status: Open

Comments: No legislative action enacted as of January 2020. Congress has not amended the Internal Revenue Code, Bank Secrecy Act of 1970 and other statutes as needed to address overlap in foreign financial asset reporting requirements, as GAO suggested in April 2019. GAO continues to believe that if Congress were to modify these various statutes, the reporting burden created by navigating multiple reporting requirements will be reduced. Modifying these statutes will also allow for the use foreign financial asset information collected under the Foreign Account Tax Compliance Act to prevent and detect financial crimes.

Recommendation: The Commissioner of Internal Revenue should develop a plan to mitigate risks with compliance activities due to the lack of accurate and complete Taxpayer Identification Numbers of U.S. account holders collected from FFIs. (Recommendation 1)

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

Comments: The Internal Revenue Service (IRS) has taken several steps to improve collection of accurate and complete taxpayer identification numbers (TINs) from foreign financial institutions (FFIs). For example, in December 2019, IRS officials said they began identifying 2017 records submitted by FFIs without valid TIN fields or corresponding dates of birth for account holders. IRS also launched a campaign to identify FFIs that did not file a Form 8966 with IRS. While these steps can improve the quality of account data submitted by FFIs, IRS still faces ongoing risks that receiving inaccurate or incomplete TINs pose to efforts to identify and combat taxpayer and FFI noncompliance. Additionally, IRS has not yet developed a plan that elaborates on these risks and identifies steps to mitigate them, as we recommended in April 2019. Without such a strategy, IRS may fail to identify opportunities to adjust compliance programs to better enforce FFI reporting of valid TINs and identify U.S. persons who are not complying with FATCA reporting requirements.

Recommendation: The Commissioner of Internal Revenue should ensure that appropriate business units conducting compliance enforcement and research have access to consistent and complete data collected from individuals' electronic and paper filings of Form 8938 and elements of parent individual tax returns. As part of this effort, the Commissioner should ensure that IRS provides clear guidance to the business units for accessing such data in IRS's Compliance Data Warehouse. (Recommendation 2)

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

Comments: The Internal Revenue Service (IRS) has taken several steps to address this recommendation. According to IRS Information Technology division officials, as of December 2019, they deliver paper and electronically filed Form 8938 data to IRS's Research, Applied Analytics, and Statistics organization on a monthly basis, and makes such data available in the Compliance Data Warehouse (CDW) for use by agency officials. According to Large Business and International (LB&I) Division officials, IRS's enforcement functions also have access to this data. One outcome of this access, according to LB&I officials, is the use of FATCA data in the development of compliance examination leads. However, IRS has not yet developed clear guidance for business units to access relevant data from Forms 8938 and elements of parent individual tax returns in CDW, as we recommended. Without such guidance, CDW users may be less likely to effectively leverage CDW data for examination purposes.

Recommendation: The Commissioner of Internal Revenue should employ a comprehensive plan for managing efforts to leverage FATCA data in agency compliance efforts. The plan should document and track activities over time to
• ensure individuals and FFIs comply with FATCA reporting requirements;
• assess and mitigate data quality risks from FFIs;
• improve the quality, management, and accessibility of FATCA data for compliance, research, and other purposes; and
• establish, monitor, and evaluate compliance efforts involving FATCA data intended to improve voluntary compliance and address noncompliance with FATCA reporting requirements. (Recommendation 3)

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

Comments: In September 2019, IRS's Deputy Commissioner for Services and Enforcement said that IRS disagreed with our April 2019 recommendation. The Deputy Commissioner said that resources that would be dedicated to update a comprehensive plan unique to FATCA-such as the FATCA Compliance Roadmap-are better spent on enforcement activities. The Deputy Commissioner also said that IRS's strategy for FATCA compliance will instead be part of IRS's Large Business & International (LB&I) Division's overall portfolio management strategy. Implementing enforcement activities could increase taxpayers' and foreign financial institutions' (FFIs) compliance with FATCA reporting requirements. While IRS does not have to revise and reemploy its FATCA Compliance Roadmap, it can employ a comprehensive plan as part of LB&I's portfolio management strategy to evaluate FATCA enforcement activities already in place, and determine the extent to which these activities improve voluntary compliance and address noncompliance with FATCA reporting requirements. Without such a plan, IRS risks not maximizing efforts to manage and address the myriad of challenges it faces in effectively ensuring taxpayer compliance.

Recommendation: The Commissioner of Internal Revenue should assess factors contributing to unnecessary Form 8938 reporting and take steps, as appropriate, to address the issue. Depending on the results of the assessment, potential options may include:
• identifying and implementing steps to further clarify IRS Form 8938 instructions and related guidance on IRS's website on determining what foreign financial assets to report, and how to calculate and report asset values subject to reporting thresholds; and
• conducting additional outreach to educate taxpayers on required reporting thresholds, including notifying taxpayers that may have unnecessarily filed an IRS Form 8938 to reduce such filings. (Recommendation 4)

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

Comments: As of February 2020, IRS officials said the agency is in the process of obtaining 2017 and 2018 tax data to analyze the number of unnecessary filings of Form 8938. Completing this data analysis and identifying the full range of factors contributing to unnecessary Form 8938 reporting will allow IRS to better address such factors. These efforts, in turn, will reduce the risk that taxpayers file-and IRS processes-forms that taxpayers were not required to submit to IRS.

Recommendation: The Secretary of the Treasury should lead efforts, in coordination with the Secretary of State and Commissioner of Social Security, to establish a formal means to collaboratively address ongoing issues—including issues accessing financial services and employment and obtaining SSNs—that U.S. persons living abroad encounter from implementation of FATCA reporting requirements. (Recommendation 5)

Agency: Department of the Treasury
Status: Open

Comments: The Department of the Treasury (Treasury) has taken some steps to implement GAO's April 2019 recommendation. Specifically, Treasury proposed changes to the Internal Revenue Service (IRS) relief procedures to abate assessments for certain expatriating taxpayers and is working with IRS and the Department of State (State) to publicize the procedures. In addition, Treasury led efforts with IRS, State, and the Social Security Administration (SSA) to develop frequently asked questions that combine relevant guidance for individuals to obtain a Social Security number, renounce U.S. citizenship, and comply with U.S. tax obligations. However, as of December 2019, Treasury lacked a collaborative interagency mechanism to address ongoing issues U.S. persons living abroad continue to encounter from implementation of Foreign Account Tax Compliance Act (FATCA) reporting requirements. In November 2019, Treasury said it was not the appropriate agency to lead these coordination efforts. However, GAO continues to believe that because Treasury is ultimately responsible for effectively administering FATCA, it is in a better position than State or SSA to establish an effective collaborative mechanism. Doing so will help agencies address the ongoing issues Americans living abroad experience from FATCA.

Recommendation: The Secretary of State, in coordination with the Secretary of the Treasury and Commissioner of Social Security, should establish a formal means to collaboratively address ongoing issues—including issues accessing financial services and employment and obtaining SSNs—that U.S. persons living abroad encounter from implementation of FATCA reporting requirements. (Recommendation 6)

Agency: Department of State
Status: Open

Comments: The Department of State (State) has taken several steps to implement GAO's April 2019 recommendation. In September 2019, State worked with the Department of the Treasury (Treasury), the Internal Revenue Service (IRS), and Social Security Administration (SSA) to develop and post online frequently asked questions on how to obtain a Social Security number, renounce U.S. citizenship, and comply with U.S. tax obligations. Additionally, State officials participated in an October 2019 webinar hosted by IRS regarding newly approved tax relief procedures for certain former citizens who have renounced U.S. citizenship and seek to be federal tax compliant. State also established procedures with SSA for its embassies and consulates abroad to help U.S. citizens apply for a Social Security number during the passport application process without SSA permission, thus removing a significant barrier in serving U.S. citizens abroad. However, as of December 2019, State lacked a collaborative interagency mechanism with Treasury to address ongoing FATCA implementation issues related to access to foreign financial services and denial of employment and promotion opportunities overseas. Treasury is responsible for leading efforts to establish such a mechanism; however, State's participation in such a mechanism on a continuing basis will help agencies address remaining issues Americans living abroad experience from FATCA.

Recommendation: The Commissioner of Social Security, in coordination with the Secretaries of State and Treasury, should establish a formal means to collaboratively address ongoing issues—including issues accessing financial services and employment and obtaining SSNs—that U.S. persons living abroad encounter from implementation of FATCA reporting requirements. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: The Social Security Administration (SSA) has taken or plans to take steps to implement GAO's April 2019 recommendation. SSA worked with the Department of the Treasury (Treasury), the Internal Revenue Service, and the Department of State (State) to develop and post online frequently asked questions on how to obtain a Social Security number, renounce U.S. citizenship, and comply with U.S. tax obligations. Additionally, in October 2019, SSA said it plans to conduct outreach events for U.S persons living abroad who need Social Security numbers. However, as of December 2019, SSA lacked a collaborative interagency mechanism with Treasury and State to address ongoing FATCA implementation issues, such as recurring issues U.S. persons may have obtaining Social Security numbers. Treasury is responsible for leading efforts to establish such a mechanism; however, SSA's participation in such a mechanism on a continuing basis will help agencies address remaining issues Americans living abroad experience from FATCA.

Recommendation: The Director of OMB should clarify and document OMB's procedure for changing official data definition standards for DATA Act reporting, for example, by explicitly describing how change procedures developed for other government-wide initiatives apply to DATA Act definition standards in a public source of guidance or information. (Recommendation 1)

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

Comments: OMB has taken steps to restructure the federal data ecosystem, including issuing government-wide guidance covering all federal data and creating a Business Standards Council. However, given the complexity of recent changes, OMB needs to explicitly and publicly describe how those changes-developed in the context of other government-wide initiatives-apply to DATA Act data element definitions.

Recommendation: The Director of OMB should ensure that the June 2018 policy changes regarding DATA Act data definition standards are clearly identified and explained in the official repository or another authoritative public source of DATA Act standards and guidance, such as by including a revision history along with the current version of the definitions. (Recommendation 2)

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

Comments: In January 2020, OMB staff cited its Federal Spending Transparency Data Standards website and specifically notations on that site regarding the dates of revisions made to those standards as being responsive to this recommendation. However, the specific notations cited by OMB only show changes made back in 2015 and do not reflect nor explain some of the more recent revisions that led to GAO making this recommendation.

Recommendation: The Principal Deputy Assistant Attorney General for OJP should consistently document CEBR program-wide goals to clarify intended program results. (Recommendation 1)

Agency: Department of Justice: Office of Justice Programs
Status: Open

Comments: In September 2019, OJP reported that it is building a logic model for the CEBR program that will provide the basis for addressing this recommendation. According to OJP, this logic model will more clearly align CEBR program goals and objectives with permitted program activities and associated performance measures. OJP had originally planned to finalize this logic model by March 2020 and share it--including any resulting changes in how program goals are articulated--with the CEBR stakeholder community in advance of the fiscal year 2021 grant cycle, beginning October 1, 2020. In June 2020, OJP reported that the CEBR program was transferred from OJP's National Institute of Justice to OJP's Bureau of Justice Assistance. As a result, OJP reported that plans to finalize and communicate the CEBR logic model have been postponed. GAO will follow-up with OJP in the winter of 2020-2021 to obtain documentation on the logic model and how they are communicating it. This will enable GAO to determine if the model--and OJP's efforts to communicate it to stakeholders--meets the intent of the recommendation by consistently documenting CEBR program-wide goals and clarifying intended results.

Recommendation: The Principal Deputy Assistant Attorney General for OJP should ensure that performance measures for each CEBR program-wide goal fully reflect appropriate attributes of successful performance measures. (Recommendation 2)

Agency: Department of Justice: Office of Justice Programs
Status: Open

Comments: In September 2019, OJP reported that it is reviewing each CEBR program performance measure as part of its process for creating a CEBR program logic model. According to OJP, the purpose of this review is to ensure the measures are meaningful and have the right attributes. In June 2020, OJP reported that, as appropriate, updated performance measures will be included in the fiscal year 2021 CEBR grant program solicitation--which they anticipate releasing in early 2021. GAO will follow-up with OJP in the spring of 2021 to obtain documentation of changes to performance measures, and to determine whether updated performance measures meet the intent of the recommendation.

Recommendation: The Principal Deputy Assistant Attorney General for OJP should document which employee positions have been delegated certification (final signature) authority for confidential financial disclosure reports and specify required levels of review and approval. (Recommendation 3)

Agency: Department of Justice: Office of Justice Programs
Status: Open

Comments: In June 2020, OJP provided a memo sent by the Principal Deputy Assistant Attorney General for OJP to OJP components, dated March 2020. This memo states that supervisors are to review and sign reports, and notes that secondary supervisors may review and sign reports as Final Reviewing Officials, but it is not mandatory. This is a positive step, but does not fully meet the intent of the recommendation because it is not clear if immediate supervisors have been delegated final signature authority. Specifically, there are two places for signature on the reports (1) "Signature and Title of Supervisor/Other Intermediate Reviewer," and (2) "Signature and Title of Agency's Final Reviewing Official" (certification). According to Office of Government Ethics' regulation and guidance, review and signature of a supervisor or other intermediate reviewer is optional, but review and signature of a Final Reviewing Official-who has been delegated authority to certify reports-is required. OJP's memo states that secondary supervisors may sign as Final Reviewing Officials (i.e. have been delegated this authority), but OJP's memo is not clear if immediate supervisors have also been delegated authority to certify reports as Final Reviewing Officials. To address this discrepancy and enable GAO to close this recommendation as "implemented," OJP needs to clarify who has been delegated authority to certify reports as Final Reviewing Officials.

Recommendation: The Principal Deputy Assistant Attorney General for OJP should (1) clarify its guidance to grantees to specify what their requirements are under 28 C.F.R. pt. 69 with regard to obtaining lobbying certification documents, and obtaining and forwarding to OJP lobbying disclosure forms, from tiers beneath them; and (2) design a control to follow-up with grantees to help ensure they are meeting these requirements. (Recommendation 4)

Agency: Department of Justice: Office of Justice Programs
Status: Open

Comments: In September 2020, OJP reported that it plans to (1) issue guidance to all OJP funding recipients to remind them of lobbying disclosure requirements and provide instructions for how to submit the disclosures, and (2) implement an updated in-depth monitoring checklist whereby OJP can ensure applicable lobbying disclosure forms are collected and submitted to OJP. OJP stated that it plans to take these steps by October 1, 2020. GAO will follow-up in late 2020 to obtain and review all relevant documentation and ensure that these steps meet the intent of the recommendation.

Recommendation: Congress should consider legislation requiring comprehensive and timely information on political appointees serving in the executive branch to be collected and made publicly accessible. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of April 2020, no bills have been introduced related to this matter. When we determine what steps the Congress has taken, we will provide updated information.

Recommendation: The Administrator of the Small Business Administration should implement procedures to track and verify that required employees complete initial ethics training and that completion of this training is documented. (Recommendation 1)

Agency: Small Business Administration
Status: Open

Comments: SBA officials provided documentation, including internal operating procedures for certifying and tracking initial ethics training, to support that they have taken initial steps to address our recommendation. In a letter dated September 13, 2019, SBA's Designated Agency Ethics Official stated that, since February 2019, SBA has used those procedures to document the provision of initial ethics training to political appointees. In that letter, SBA stated that it planned to provide additional documentation to GAO to support this action. When we receive this documentation, we will assess the implementation of SBA;s new procedures to confirm that, in operation, these procedures meet the intent of our recommendation.

Recommendation: The Secretary of the Interior should direct the Departmental Ethics Office, in conjunction with the Chief Human Capital Officer, to develop, document, and implement a strategic workforce planning process that aligns with its ongoing departmental reorganization and that is tailored to the specific needs of the ethics program. As part of this process, Interior should monitor and assess the critical skills and competencies that its ethics program needs presently and is projected to need in the future. (Recommendation 2)

Agency: Department of the Interior
Status: Open

Comments: In a letter dated September 10, 2019, Interior's Assistant Secretary for Policy, Management and Budget stated that Interior concurred with this recommendation and is in the process of reorganizing the Department's ethics program, including working with the Chief Human Capital Officer to develop and implement strategic workforce planning. Interior expects to complete this action by December 31, 2021. When we can confirm what actions Interior has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Interior should ensure that the department's ethics program policies and procedures are documented and easily accessible to program staff. (Recommendation 3)

Agency: Department of the Interior
Status: Open

Comments: In a letter dated September 10, 2019, Interior's Assistant Secretary for Policy, Management and Budget stated that Interior concurred with this recommendation and is in the process of developing ethics program policies and procedures. Interior expects to complete this action by December 31, 2021. Once finalized, Interior plans to make ethics program policies and procedures easily accessible to the program staff. When we can confirm what actions Interior has taken in response to this recommendation, we will provide updated information.

Recommendation: The SBA Administrator should establish a process that ensures documentation of states' compliance with the total match requirement before grant closeout. (Recommendation 1)

Agency: Small Business Administration
Status: Open
Priority recommendation

Comments: SBA generally agreed with GAO's findings and concurred with our recommendations. In response to our draft report, agency officials said SBA will establish a process that ensures documentation of state recipients' compliance with the total match requirement before grant closeout. In September 2019, officials told us this process will include assigning SBA program office responsibilities for ensuring recipient compliance related to the cost match. In March 2020, SBA officials said they were still working on implementing changes to address our recommendation. GAO will continue to monitor the agency's implementation of this process.

Recommendation: The SBA Administrator should develop a process to determine states' compliance with the cash match requirement. (Recommendation 2)

Agency: Small Business Administration
Status: Open
Priority recommendation

Comments: SBA generally agreed with our findings and concurred with our recommendations. In response to our draft report, agency officials said they would develop a process to determine state's compliance with the cash match requirement. In September 2019, officials told us the process will apply to both grants specialists and program officers, and ensure the cost match is appropriately applied. In March 2020, SBA officials said they were still working on implementing changes to address our recommendation. GAO will continue to monitor the agency's implementation of this process.

Recommendation: The Director of the DOE Office of Acquisition Management should clearly define—in guidance or other documents—which subcontracts should be audited, how an audit is defined, and how to meet subcontract audit requirements if Defense Contract Audit Agency is unable to conduct the audit.(Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: In its comments on a draft of the report, DOE partially concurred with the recommendation, but stated that there is no government-wide requirement that defines an audit or prescribes the auditing of subcontracts. According to officials, DOE reviewed existing regulations, guidance, and contract provisions on audit requirements and determined that a need exists for additional guidance or contract provisions on audits for major contracts. As of June 2020, DOE was working with the Civilian Agency Acquisition Council to recommend a government-wide requirement to define audit and prescribe when to obtain audits of subcontracts. Additionally, DOE included in its Acquisition Guide information on audit options when the Defense Contract Audit Agency is unable to conduct an audit.

Recommendation: The Director of the DOE Office of Acquisition Management should require local officials to independently review subcontractor ownership information as part of DOE consent reviews and assess potential conflicts of interest to ensure contractors are mitigating them. (Recommendation 4)

Agency: Department of Energy
Status: Open
Priority recommendation

Comments: DOE did not concur with our recommendation; instead, they plan to issue guidance emphasizing the importance of contracting officers reviewing contractors' disclosing and dealing with issues created by close working relationships, conflicts of interest, or ownership affiliations between prime and subcontractor. We have identified complex relationships among DOE contractors and subcontractors that were not documented by DOE, as well as incidents involving subcontractors related to conflicts of interest that were not disclosed to DOE. We noted that DOE officials--including those in local offices--have access to several databases and other sources of information that would allow them to independently verify ownership information that could allow the local offices to identify potential conflicts of interest that were not disclosed. In July 2020, DOE issued guidance summarizing and reiterating existing regulations, policy and procedures that require DOE contracting officers to perform independent analyses when reviewing subcontract consent packages, contractor purchasing systems, and potential organizational conflicts of interest. However, this is the same as previous guidance and it does not include direction to review subcontractor ownership information.

Recommendation: The Director of the DOE Office of Acquisition Management should require contracting officers to include assessments of the contractors' management of subcontractors as part of annual Performance Evaluation and Measurement Plans, as appropriate. (Recommendation 6)

Agency: Department of Energy
Status: Open

Comments: DOE partially concurred with the recommendation and agreed to review existing guidance and determine if additional guidance is needed to conduct an assessment of the contractors' management of subcontractors in annual Performance Evaluation and Measurement Plans. As of June 2020, DOE officials said they have reviewed existing federal and departmental policies, procedures, and available tools and determined sufficient guidance exists for contracting officers to make informed decisions on whether to include contractor management of subcontractors in annual Performance Evaluation and Measurement Plans based on the characteristics, circumstances, and requirements of a specific contract. DOE's Performance Evaluation and Measurement Plan template provides a subcontractor management evaluation factor for use by contracting officers who have determined it is appropriate for their contracts. Although we recognize the value in deferring to contracting officers to determine whether the factor is appropriate based on the characteristics, circumstances, and requirements of the contract, we continue to believe that DOE should place additional emphasis on the contractors' oversight of subcontracts by assessing the contractors on this factor.

Recommendation: OMB's Shared Services Policy Officer should work with GSA to finalize a plan for monitoring the implementation of NewPay. The plan should include:
• implementation goals, a timeline, and milestones for agencies to transition from one provider to another;
• transparent reporting mechanisms on key milestones; and
• a process for capturing and communicating lessons learned.
(Recommendation 1)

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

Comments: OMB staff did not agree or disagree with GAO's March 2019 recommendation. As of January 2020, OMB had not addressed this recommendation. According to OMB staff, they are still deliberating goals and milestones for NewPay. In addition, OMB is working on a knowledge library to capture lessons learned for shared services initiatives. However, OMB staff did not provide a timeline for when they will complete these efforts. Without a detailed monitoring plan that includes goals, transparent reporting mechanisms on key milestones, and a process for capturing and communicating lessons learned, it will be more difficult for OMB and GSA to provide oversight of the transition and its effects on providers and customers, including whether there are interruptions to delivery of services. Additionally, this information could help OMB and GSA avoid gaps in service or costly delays as agencies transition to the new model for obtaining payroll and work management services.

Recommendation: OMB's Shared Services Policy Officer should work with GSA to document key roles and responsibilities, including which agency will be the NewPay Service Management Offices (SMO), who will be assigned to the NewPay Task Order Review Board, how the SMO, the Review Board, and other key stakeholders will work together, and which agency will be responsible for interpreting payroll rules and regulations. (Recommendation 2)

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

Comments: OMB staff did not agree or disagree with GAO's March 2019 recommendation. As of January 2020, OMB had taken some steps to address this recommendation. OMB designated GSA as the Quality Service Management Office (QSMO) for NewPay. As QSMO, GSA will be responsible for managing the payroll marketplace. However, OMB has not documented how GSA and other key stakeholders will work together. For example, OMB has not documented which agency will review and approve task orders. Until OMB and GSA clearly identify, communicate, and document key roles and responsibilities, they run the risk of not achieving their objectives. They also risk repeating past problems associated with the delivery of shared services, such as the inconsistent implementation and interpretation of standards and migrations that encounter costly delays should agencies not follow available guidance.

Recommendation: OMB's Shared Services Policy Officer should work with GSA to update provider information on services offered, pricing, and performance and share that information with prospective customers. (Recommendation 3)

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

Comments: OMB staff did not agree or disagree with GAO's March 2019 recommendation. As of January 2020, OMB had not addressed this recommendation. Without up-to-date information on providers -- such as the services OMB and GSA plan to offer, their level of performance, and their costs -- it will be time- consuming and difficult for potential customers to compare providers. This lack of information could slow the rate of shared services adoption.

Recommendation: OMB's Shared Services Policy Officer should work with GSA to implement a process for collecting and tracking cost-savings data that would allow them to assess progress toward the shared services cost-savings goal of an estimated $2 billion over 10 years. (Recommendation 4)

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

Comments: OMB staff did not agree or disagree with GAO's March 2019 recommendation. As of January 2020, OMB had not addressed this recommendation. According to OMB officials, OMB will collect cost-savings data via the integrated data collection process, which requires agencies to publicly post their cost savings and avoidance data. However, OMB has not demonstrated how it plans to use data from the IT Integrated Data Collection Instrument to track cost savings specifically related to shared services overall and for individual projects. Until OMB and GSA finalize a plan for collecting the needed data and evidence to effectively measure cost-savings goals, it will be difficult to demonstrate progress -- a recurring challenge associated with previous shared services efforts.

Recommendation: The Director of OMB should make available more disaggregated data on fees, fines, and penalties that it maintains in its OMB MAX database. For example, OMB could report data on fee collections by agency in Analytical Perspectives. (Recommendation 1)

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

Comments: The Office of Management and Budget (OMB) did not provide comments on our draft report and therefore neither agreed nor disagreed with this recommendation. As of October 2020, OMB had not provided evidence of any actions taken to implement this recommendation.

Recommendation: The Director of OMB should instruct agencies to regularly review the application of the user fee designation in the OMB MAX data and update the designation, as needed, to meet the criteria in OMB Circular No. A-11. (Recommendation 3)

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

Comments: OMB did not provide comments on our draft report and therefore neither agreed nor disagreed with this recommendation. As of October 2020, OMB had not provided evidence of any actions taken to implement this recommendation.

Recommendation: The Assistant Secretary of Labor for Occupational Safety and Health should explore the feasibility of requiring a corporate identification number in its inspection database and enabling its website to be searched by that number. This should include exploring the following issues: (1) which corporate identification number would be most appropriate to require; (2) options for obtaining this number from employers; and (3) options for entering this number in its database that would prevent or minimize delays in closing inspection records. (Recommendation 1)

Agency: Department of Labor: Occupational Safety and Health Administration
Status: Open

Comments: OSHA did not state whether it agreed with this recommendation. The agency acknowledged the potential utility of obtaining a unique identifier from each employer and said it will continue to promote the collection of Employer Identification Numbers (EIN) or Tax Identification Numbers (TIN) whenever possible by issuing a revised memorandum to field staff to reinforce the importance of collecting this information. OSHA stated that it does not view EINs as confidential or protected from disclosure. However, it expressed concerns about protecting TINs and Social Security Numbers from disclosure, and noted that it would not be able to make a data field available for public search if it contained either of these numbers. OSHA also raised concerns about the financial cost associated with redesigning the agency's data system. We encourage OSHA to explore options for addressing these concerns as it further considers how to implement this recommendation.

Recommendation: The Secretary of Defense should provide information to contracting officials to advise them that the OSHA website is a resource for information about contractors' workplace safety and health records. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation and identified implementation timelines. We will monitor the agency's progress.

Recommendation: The Secretary of Defense should explore the feasibility of requiring a safety performance rating for contracts in industries that have relatively high rates of occupational injuries, such as manufacturing, construction, and ship building and repairing. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation and identified implementation timelines. We will monitor the agency's progress.

Recommendation: The Director of CFPB should identify additional sources of information, such as through registering CRAs or leveraging state information, that would help ensure the agency is tracking all CRAs that meet the larger participant threshold. (Recommendation 1)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: In July 2020, CFPB staff noted that they have reviewed state CRA registration information available to them, are working to obtain additional state registration information, and are exploring additional ways to leverage the information. GAO will continue to monitor CFPB's progress in leveraging additional sources of information that would help identify larger participant CRAs.

Recommendation: The Director of CFPB should assess whether its process for prioritizing CRA examinations sufficiently incorporates the data security risks CRAs pose to consumers, and take any needed steps identified by the assessment to more sufficiently incorporate these risks. (Recommendation 2)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: In July 2020, CFPB staff noted that they were assessing whether, and if so, how and when, to incorporate data security risks into their supervisory prioritization. As part of that evaluation, CFPB is assessing whether those processes should incorporate data security risks CRAs pose to consumers in light of the agency's statutory authorities, supervisory responsibilities, and resources. GAO will continue monitoring CFPB's assessment of prioritization of CRA data security risks.

Recommendation: Congress should consider providing the Federal Trade Commission with civil penalty authority for the privacy and safeguarding provisions of the Gramm-Leach-Bliley Act to help ensure that the agency has the tools it needs to most effectively act against data privacy and security violations. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of July 2020, Congress has not passed legislation to provide FTC with civil penalty authority for the privacy and safeguarding provisions of the Gramm-Leach-Bliley Act.

Recommendation: The Assistant Secretary of DOE's Office of Environmental Management should update EM's policies and procedures to establish a standard definition of milestones and specify requirements for both including and updating information on milestones across the complex. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation, but as of March 2020, DOE has not fully implemented this recommendation. DOE officials told us that they established an Integrated Project Team (IPT) to review GAO's recommendation. The IPT recommended that DOE continue to use DOE's Integrated Planning, Accountability and Budgeting System (IPABS) for tracking compliance with milestones, accompanied by a new policy providing direction to the field to use IPABS, a new data dictionary for the use of IPABS, guidance, and training. Using recommendations from the IPT, DOE has drafted policy and guidance documents for tracking compliance and is in the process of testing the draft policy using a pilot site. DOE officials told us that they plan to update the schedule for completing the final policy and guidance by September 30, 2020.

Recommendation: The Assistant Secretary of DOE's Office of Environmental Management should track original milestone dates as well as changes to its cleanup milestones. (Recommendation 2)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation, but as of March 2020, DOE has not fully implemented the recommendation. DOE officials told us they have completed an options analysis to identify the costs and benefits of conducting root cause analyses of historical milestone changes. DOE officials said they recognized a benefit to a developing a more complete root cause analysis and considered whether an analysis of historical milestone changes could provide best practices in negotiating milestone changes. DOE said they have initiated a pilot project with a major DOE site to determine the benefit of additional analyses and that the analysis of historical milestone changes will be completed by December 2020.

Recommendation: The Assistant Secretary of DOE's Office of Environmental Management should comply with the requirements in the National Defense Authorization Act by reporting annually to Congress on the status of its cleanup milestones and including a complete list of cleanup milestones for all sites required by the act. The annual reports should also include, for each milestone, the original date along with the currently negotiated date. (Recommendation 3)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation, but as of March 2020, DOE has not fully implemented the recommendation. DOE officials told us that DOE completed an options analysis to identify the costs and benefits of conducting root cause analyses of historical milestone changes. DOE officials added that they will identify what historical analyses are appropriate to conduct based on value to the government. According to DOE officials, the results of this analysis are being incorporated into a pilot project, and they plan to complete a final reporting methodology by the end of that pilot project.. DOE officials noted that they have analyzed options for reporting on regulatory compliance and the results will be part of DOE policy and guidance to be issued by June 2021.

Recommendation: The Assistant Secretary of DOE's Office of Environmental Management should conduct root cause analyses of missed or postponed milestones. (Recommendation 4)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with the recommendation, but as of March 2020, DOE has not fully implemented the recommendation. DOE officials told us that they established an Integrated Project Team (IPT) to review GAO's recommendation. DOE officials told us that the IPT identified root causes for missed or delayed milestones, which according to DOE officials, will be used in a pilot test of the draft policy. DOE officials told us that they plan to develop an appropriate list of root causes after the pilot project is completed, and officials noted that they plan to revisit the list of root causes on a recurring basis to verify that the options are still valid. According to DOE officials, DOE plans to issue a final policy and guidance, which will include the list of root causes that sites will input into the tracking system (the Integrated Planning, Accountability and Budgeting System, or IPABS) when milestones are modified or cancelled. DOE plans to issue this guidance no later than June 30, 2021.

Recommendation: The Director of BLM should identify the reasons internal control reviews were not completed (e.g., human capital and workforce), develop and implement a plan to address those reasons, and monitor state offices' progress toward completing required reviews. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. Specifically, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook or Instruction Memorandum. BLM also wrote that it is establishing teams to conduct internal control reviews, monitoring the status of any past-due reviews and actively engaging across its multiple state offices to ensure timely resolution. In late August 2020, BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: The Director of BLM should develop and document procedures for implementing internal control reviews under the July 2012 oversight policy. (Recommendation 2)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In responding to our report, BLM stated that its July 2012 oversight policy, which expired in September 2013, should not have been allowed to lapse and given the importance of internal control reviews, the bureau will continue to use the July 2012 policy to conduct future reviews. In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. In addition, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook, or Instruction Memorandum. In late August 2020. BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: The Director of BLM should implement a risk-informed approach to scheduling and conducting internal control reviews that takes into account the risks to BLM's mission, such as those inherent in field offices' workload and workforce. (Recommendation 3)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. Specifically, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook, or Instruction Memorandum. In addition, BLM noted that the guidance will help ensure that the bureau completes internal control reviews in a timely manner using a consistent risk-based approach. In late August 2020. BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: CMS should take action to ensure South Dakota's Medicaid state plan provides coverage for abortions in cases of rape and in cases of incest, in addition to life endangerment, to comply with federal law, which currently requires such coverage. (Recommendation 1)

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

Comments: In June 2019, HHS officials reported they were reviewing agency processes and would determine the best course of action moving forward. Officials said they would provide an update on actions by 12/20/2019. As of April 6, 2020, this recommendation remains open.

Recommendation: CMS should determine the extent to which state Medicaid programs are in compliance with federal requirements regarding coverage of Mifeprex and take actions to ensure compliance, as appropriate. (Recommendation 2)

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

Comments: In June 2019, HHS officials reported they were reviewing agency processes and would determine the best course of action moving forward. Officials said they would provide an update on actions by 12/20/2019. As of April 6, 2020, this recommendation remains open.

Recommendation: CMS should determine the extent to which state Medicaid programs are accurately reporting fee-for-service abortions on line 14 of the CMS-64 and take actions to ensure accuracy, as appropriate. (Recommendation 3)

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

Comments: In June 2019, HHS officials reported they were developing written instructions for states to reiterate fee-for-service reporting requirements for abortions provided in their Medicaid programs. Officials said they would provide an update on actions by 12/20/2019. As of April 6, 2020, this recommendation remains open.

Recommendation: The Secretary of Energy, in coordination with DOE's Office of Project Management and NNSA's Office of Acquisition and Project Management, should develop requirements that clearly define how and where project management lessons learned for capital asset projects should be documented and saved to make them readily accessible across the department. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: DOE concurred with the recommendation and as of July 2020, continues to work on developing a policy memorandum in advance of revising DOE Order 413.3B, Program and Project Management for the Acquisition of Capital Assets, to identify the project management lessons learned and outline the kinds of information the repository will collect. We will monitor DOE's effort and evaluate the action once it is complete.

Recommendation: The Secretary of Energy, in coordination with DOE's Office of Project Management and NNSA's Office of Acquisition and Project Management, should develop requirements for sharing project management lessons learned for capital asset projects from the beginning of a project (i.e., prior to the start of construction at CD-3) routinely and in a timely manner to improve DOE's ability to identify and evaluate problematic practices and positive experiences. (Recommendation 2)

Agency: Department of Energy
Status: Open

Comments: DOE concurred with the recommendation and as of July 2020, continues to work on developing a policy memorandum in advance of revising DOE Order 413.3B, Program and Project Management for the Acquisition of Capital Assets, to have those conducting peer reviews elicit project management lessons learned with department-wide applicability and submit any discerned, as well as replace the order's definition of project management lessons learned with a standard industry definition. We will monitor DOE's efforts and evaluate the actions once they are complete.

Recommendation: The Secretary of Energy, in coordination with DOE's Office of Project Management and NNSA's Office of Acquisition and Project Management, should develop requirements for evaluating the effectiveness of corrective actions taken in response to project management problems for capital asset projects, with a focus on those lessons that necessitate the need for department-wide improvements. (Recommendation 3)

Agency: Department of Energy
Status: Open

Comments: DOE concurred with the recommendation and as of July 2020, plans to revise the Project Management Risk Committee charter by assigning it the responsibility to qualitatively evaluate the effectiveness of corrective actions taken in response to project management lessons learned from projects with a total project cost greater than $750 million having department-wide implications. This action, however, may not fully address the recommendation, in part because there may be some lessons learned with applicability department-wide from projects that do not meet this cost threshold. We will monitor DOE's effort and evaluate the action once it is complete.

Recommendation: The Assistant Secretary for Financial Institutions should annually collect and evaluate HFAs' risk assessments, which include HFAs' risk levels. (Recommendation 1)

Agency: Department of the Treasury
Status: Open

Comments: According to Treasury, as of March 2019, the agency had requested that each Housing Finance Agency evaluate its controls and update its Risk and Control Matrix to ensure that it reflects the risk assessment level of each control that has been assessed and to provide this information to Treasury. Treasury stated that it would evaluate the risk assessments to verify that the appropriate risk level had been assessed and that proper segregation of duties exists. As of August 2020, Treasury had not demonstrated that it had annually collected or evaluated HFA's risk assessments.

Recommendation: The Director of OMB should determine a government-wide baseline level of progress in meeting physical access control system requirements, including implementation of GSA-approved systems, and should monitor progress in meeting these requirements. (Recommendation 1)

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

Comments: In August 2019, GAO contacted OMB to determine if any progress has been made implementing this recommendation. GAO is awaiting OMB's response.

Recommendation: The Secretary of Homeland Security should direct the ISC, in collaboration with member agencies, to assess the extent of, and develop strategies to address, government-wide challenges to implementing physical access control systems. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: In August 2019, GAO learned that DHS has recently completed the "Physical Access Control System (PACS) Modernization Working Group Charter." This charter was created under the direction of the Co-Chairs of the Federal Chief Information Security Officer Council, Identity, Credentialing and Access Management Subcommittee, and the Program Director of the DHS Interagency Security Committee. The purpose of the PACS Modernization Working Group is to facilitate the implementation and use of the technology and processes related to modernizing electronic-PACS within the federal government, thereby increasing security, coordination, and compliance with national-level policies and standards. GAO is following up with DHS to obtain additional information about this effort and to determine whether it addresses this recommendation.

Recommendation: The Administrator of FNS should present the uncertainty around its retailer trafficking estimates in future reports by, for example, including the full range of the estimates in the report body and executive summary. (Recommendation 1)

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

Comments: FNS generally agreed with this recommendation, and stated that it will present the uncertainty around the retailer trafficking estimates in the executive summary and main body of all future trafficking reports, instead of presenting the information in appendices, as it did in past reports. In August 2020, FNS stated that it has made this change to the next trafficking report, which is in clearance at USDA. GAO will consider this recommendation implemented when FNS issues its this report.

Recommendation: The Administrator of FNS should continue efforts to improve the agency's retailer trafficking estimates by evaluating (1) whether the factors used to identify stores for possible investigation could help address the bias in its sample, and (2) the accuracy of its assumption of the percentage of SNAP benefits that are trafficked by different types of stores. (Recommendation 2)

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

Comments: FNS generally agreed with this recommendation. FNS stated that it will evaluate whether incorporating additional factors, such as the Watch List score used to identify stores for possible investigation, could improve its estimation methodology. FNS also stated that it will work with the USDA OIG to better understand the methodology the OIG uses to estimate the share of benefits that are trafficked by a retailer who is prosecuted for trafficking, and determine whether it is feasible to apply a similar methodology to the transaction data maintained by FNS in order to improve the accuracy of its assumptions about the percentage of SNAP benefits that are trafficked. In August 2020, FNS noted that it will evaluate the feasibility of this revised methodology for the trafficking estimates covering years 2018 through 2020. GAO will consider this recommendation implemented when FNS provides information on the results of this evaluation.

Recommendation: The Administrator of FNS should assess the benefits and costs of reauthorizing a sample of high-risk stores more frequently than other stores, use the assessment to determine the appropriate scope and time frames for reauthorizing high-risk stores moving forward, and document this decision in policy and on its website. (Recommendation 3)

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

Comments: FNS generally agreed with this recommendation. In August 2020, FNS stated that it included a sample of 471 high-risk stores that had not yet reached their 5-year reauthorization cycle in its fiscal year 2020 reauthorization pool. Once fiscal year 2020 reauthorizations are complete, FNS will analyze the outcomes of these reauthorizations to determine the benefits and costs of reauthorizing some high-risk stores more frequently. At that point, FNS will determine the appropriate scope and time frames for reauthorizing high-risk stores moving forward. GAO will consider this recommendation implemented when FNS completes this work.

Recommendation: The Administrator of FNS should move forward with plans to increase penalties for retailer trafficking. (Recommendation 4)

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

Comments: FNS generally agreed with this recommendation. In August 2020, FNS reported that it has developed a proposed rule to accomplish this change. The agency expects the proposed rule to be published in December 2020.

Recommendation: The Administrator of FNS should establish performance measures for its trafficking prevention activities. (Recommendation 5)

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

Comments: FNS generally agreed with this recommendation. In August 2020, FNS reported that the agency has assessed existing data to develop strategies for trafficking prevention, and is taking a two-pronged approach. First, the agency stated that it has updated training materials and guidance to make them more accessible for staff. Second, the agency stated that it is continuing to assess store applications and reauthorizations for business integrity, including prior fraud and other criminal offenses by store owners or managers, as described in regulations and policy. However, FNS did not indicate whether the agency currently has plans to establish performance measures for its trafficking prevention activities.

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 Office of the Secretary should assess the feasibility and cost of updating its airline case management system to address data and reporting limitations, and to undertake those updates that are cost effective and feasible. (Recommendation 2)

Agency: Department of Transportation
Status: Open

Comments: DOT concurred with this recommendation and said it would take steps to update its case management tracking system. As of June, 2020, DOT has not provided an update regarding the status of its efforts to implement this recommendation. DOT indicated the agency would provide a response in the coming months, citing delays with workloads due to COVID-19. Once DOT provides a response to this recommendation, we will provide updated information.

Recommendation: The Office of the Secretary should establish performance measures for each of its objectives for its five key airline-compliance activities. (Recommendation 3)

Agency: Department of Transportation
Status: Open

Comments: DOT concurred with this recommendation and said it would take steps to establish appropriate performance measures. As of June, 2020, DOT has not provided an update regarding the status of its efforts to implement this recommendation. DOT indicated the agency would provide a response in the coming months, citing delays with workloads due to COVID-19. Once DOT provides a response to this recommendation, we will provide updated information.

Recommendation: The Office of the Secretary should capture feedback directly from airline passengers or identify other mechanisms to capture passengers' perspectives to inform DOT's education efforts. (Recommendation 4)

Agency: Department of Transportation
Status: Open

Comments: DOT concurred with this recommendation and said it would take steps to capture feedback directly from consumers. As of June, 2020, DOT has not provided an update regarding the status of its efforts to implement this recommendation. DOT indicated the agency would provide a response in the coming months, citing delays with workloads due to COVID-19. Once DOT provides a response to this recommendation, we will provide updated information.

Recommendation: The Office of the Secretary should develop performance measures for DOT's efforts to educate airline passengers. (Recommendation 6)

Agency: Department of Transportation
Status: Open

Comments: DOT concurred with this recommendation and said it would take steps to develop appropriate performance measures for DOT's efforts to educate airline passengers. As of June, 2020, DOT has not provided an update regarding the status of its efforts to implement this recommendation. DOT indicated the agency would provide a response in the coming months, citing delays with workloads due to COVID-19. Once DOT provides a response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Energy should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that establish department-wide policy for the level of detail of planned expenditure reporting to the CIO for all transactions that include IT resources. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with our recommendation. The department has provided documentation regarding its IT budget procedures. However, DOE has not yet developed procedures that explicitly require that all transactions with an IT component be included in the expenditure reporting to the CIO. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Secretary of Energy should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that include the CIO in the planning and budgeting stages for all programs that are fully or partially supported with IT resources. (Recommendation 2)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with our recommendation. The department has provided documentation regarding its IT budget procedures. However, DOE has not yet documented procedures for ensuring the CIO is included in budget decisions for all programs with IT resources, including those within NNSA and the national laboratories. We will continue to monitor the agency's progress in implementing our recommendation.

Recommendation: The Secretary of Energy should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that include the CIO as a member of governance boards that inform decisions regarding all IT resources, including component-level boards. (Recommendation 3)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with our recommendation. The department has provided charters that included the CIO as a member of department-level governance boards that inform IT decisions. However, DOE has not provided charters that include the CIO as a member of component-level IT governance boards. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Secretary of Energy should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the processes by which program leadership works with the CIO to plan an overall portfolio of IT resources. (Recommendation 4)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with our recommendation. The department has provided IT governance board and budget procedures. However, DOE has not documented procedures by which the CIO is to work with program leadership in planning IT resources for all programs, including those within NNSA and the national laboratories. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Secretary of Energy should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the process for the CIO's review and approval of the major IT investments portion of the budget request. (Recommendation 5)

Agency: Department of Energy
Status: Open

Comments: The department has provided IT budget procedures. However, DOE has not documented procedures by which the CIO is to review and approve all major IT investments, including those within NNSA and the national laboratories. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Secretary of Energy should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the CIO's role in reviewing IT resources that are to support major program objectives and significant increases and decreases in IT resources. (Recommendation 6)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with our recommendation. The department has provided IT budget procedures. However, DOE has not documented procedures for the CIO's review of IT resources that are to support major program objectives and significant increases and decreases in IT resources for department and component agency budget requests. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Secretary of Energy should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the steps the CIO is to take to ensure whether the IT portfolio includes appropriate estimates of all IT resources included in the budget request. (Recommendation 7)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with our recommendation. The department has provided IT budget procedures. However, DOE has not developed procedures for documenting steps the CIO is to take to ensure that the IT portfolio includes appropriate estimates of all IT resources. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Secretary of Energy should direct the Office of the CIO and other offices, as appropriate, to take steps to ensure that the actions taken to comply with OMB's common baseline for implementing FITARA on individual investments are adequately documented. (Recommendation 8)

Agency: Department of Energy
Status: Open

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

Recommendation: The Secretary of Energy should ensure that the Office of the CIO and other offices, as appropriate, establish quality assurance processes--such as data quality checks, reviews of estimation methods, linkages between the IT portfolio and procurement system data, and linkages between the IT portfolio and financial system data--for ensuring the annual IT budget is informed by complete and reliable information on anticipated government labor, contract, and other relevant IT expenditures. (Recommendation 9)

Agency: Department of Energy
Status: Open

Comments: DOE agreed with our recommendation and is planning to take steps towards implementing it. Specifically, DOE plans to implement the Technology Business Management Framework by December 2021. Additionally, the department is coordinating internally to update its financial and procurement systems to better identify IT spending. DOE anticipates that its updates will allow the agency to compare actual IT spending against estimates in the portfolio. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Administrator of NNSA should ensure that the Office of the CIO and other offices, as appropriate, develop and implement policies and procedures that establish agency-wide policy for the level of detail with which planned expenditures for all transactions that include IT resources are to be reported to the CIO. (Recommendation 10)

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

Comments: NNSA agreed with this recommendation and plans to develop relevant policies and procedures by June 2020. We will continue to monitor the agency's progress towards implementing our recommendation.

Recommendation: The Administrator of NNSA should ensure that the Office of the CIO and other offices, as appropriate, develop and implement policies and procedures that include the CIO in the planning and budgeting stages for all programs that are fully or partially supported with IT resources. (Recommendation 11)

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

Comments: NNSA agreed with this recommendation and plans to develop relevant policies and procedures by June 2020. We will continue to monitor the agency's progress towards implementing our recommendation.

Recommendation: The Administrator of NNSA should ensure that the Office of the CIO and other offices, as appropriate, develop and implement policies and procedures that include the CIO as a member of governance boards that inform decisions regarding all IT resources. (Recommendation 12)

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

Comments: NNSA agreed with this recommendation and plans to develop relevant policies and procedures by June 2020. We will continue to monitor the agency's progress towards implementing our recommendation.

Recommendation: The Administrator of NNSA should ensure that the Office of the CIO and other offices, as appropriate, develop and implement policies and procedures that document the process for the CIO's review and approval of the major IT investments portion of the budget request. (Recommendation 13)

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

Comments: NNSA agreed with this recommendation and plans to develop relevant policies and procedures by June 2020. We will continue to monitor the agency's progress towards implementing our recommendation.

Recommendation: The Administrator of NNSA should ensure that the Office of the CIO and other offices, as appropriate, develop and implement policies and procedures that document the CIO's role in reviewing IT resources that are to support major program objectives and significant increases and decreases in IT resources. (Recommendation 14)

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

Comments: NNSA agreed with this recommendation and plans to develop relevant policies and procedures by June 2020. We will continue to monitor the agency's progress towards implementing our recommendation.

Recommendation: The Administrator of NNSA should direct the Office of the CIO and other offices, as appropriate, to take steps to ensure that the actions taken to comply with OMB's common baseline for implementing FITARA on individual investments are adequately documented. (Recommendation 15)

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

Comments: NNSA agreed with this recommendation and plans to develop relevant policies and procedures by June 2020. We will continue to monitor the agency's progress towards implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that establish department-wide policy for the level of detail of planned expenditure reporting to the CIO for all transactions that include IT resources. (Recommendation 16)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with this recommendation and is planning to take steps to implement it. Specifically, the agency intends to update its IT investment planning policy to include requirements for reporting expenditures that apply to all transactions with an IT component. We will continue to monitor the department's progress towards implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that include the CIO in the planning and budgeting stages for all programs that are fully or partially supported with IT resources. (Recommendation 17)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with the recommendation and is planning to take steps to implement it. Specifically, the agency intends to update its IT investment planning policy to amplify the CIO's role in the planning and budgeting stages for all programs with IT resources. Also, HHS intends to document procedures for ensuring that all delegated authorities are carried out. We will continue to monitor the department's progress towards implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that include the CIO as a member of governance boards that inform decisions regarding all IT resources, including component-level boards. (Recommendation 18)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with the recommendation. The department has provided charters that included the CIO as a member of department-level governance boards that inform IT decisions. However, HHS has not provided charters that include the CIO as a member of component-level IT governance boards. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the processes by which program leadership works with the CIO to plan an overall portfolio of IT resources. (Recommendation 19)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with the recommendation and is planning to take steps to implement it. For example, HHS plans to develop an asset management policy and introduce a pilot program to manage inventories across the agency. However, the department has not developed policies and procedures that incorporate the processes by which the program leadership are planning the IT portfolio with the CIO for existing investments greater than or equal to $20 million annually and for investments delegated to components. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the process for the CIO's review and approval of the major IT investments portion of the budget request. (Recommendation 20)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with the recommendation and is planning to take steps to implement it. Specifically, the department intends to update its IT investment planning policy to amplify the CIO's role in reviewing major investments. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the CIO's role in reviewing IT resources that are to support major program objectives and significant increases and decreases in IT resources. (Recommendation 21)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with this recommendation and has taken steps towards implementing it. Specifically, HHS documented procedures that require the CIO to hold annual IT investment review meetings with components to review changes in IT resources. However, HHS has not documented procedures for the CIO's role in reviewing major program objectives. We will continue to monitor the department's progress toward implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the steps the CIO is to take to ensure whether the IT portfolio includes appropriate estimates of all IT resources included in the budget request. (Recommendation 22)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with the recommendation and is planning to take steps to implement it. Specifically, the department intends to assess and update its existing policies and procedures to document the steps the CIO is to take to review the IT portfolio for appropriate estimates of all IT resources. We will continue to monitor the department's progress toward implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should direct the department CIO to establish, for any OMB common baseline requirements that are related to IT budgeting that have been delegated, a plan that specifies the requirement being delegated, demonstrates how the CIO intends to retain accountability for the requirement, and ensures through quality assurance processes that the delegated official will execute such responsibilities with the appropriate level of rigor. (Recommendation 23)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with the recommendation and is planning to take steps to implement it. Specifically, the department intends to develop an IT governance policy to define the accountability of the CIO over all IT projects and establish processes detailing quality reviews and the level of rigor that should be applied by its IT governance board. We will continue to monitor the department's progress towards implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should direct the Office of the CIO and other offices, as appropriate, to take steps to ensure that the actions taken to comply with OMB's common baseline for implementing FITARA on individual investments are adequately documented. (Recommendation 24)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with the recommendation and is planning to take steps to implement it. Specifically, the agency intends to update its IT acquisition program policy and related processes. HHS also plans to document standard operating procedures for agency wide dissemination to ensure the effectiveness and efficiency of IT investment governance through transparent and repeatable procedures. We will continue to monitor the agency's progress in implementing our recommendation.

Recommendation: The Secretary of Health and Human Services should ensure that the Office of the CIO and other offices, as appropriate, establish quality assurance processes--such as data quality checks, reviews of estimation methods, linkages between the IT portfolio and procurement system data, and linkages between the IT portfolio and financial system data--for ensuring the annual IT budget is informed by complete and reliable information on anticipated government labor, contract, and other relevant IT expenditures. (Recommendation 25)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS agreed with the recommendation and are planning to take steps towards implementing it. Specifically, HHS established a working group and developed a roadmap for implementing the Technology Business Management Framework by fiscal year 2022. The agency anticipates that its strategy and approach will enable HHS to, among other things, link IT portfolio data, procurement system data, and financial system data. We will continue to monitor the department's progress towards implementing our recommendation.

Recommendation: The Administrator of CMS should ensure that the Office of the CIO and other offices, as appropriate, develop and implement policies and procedures that include the CIO in the planning and budgeting stages for all programs that are fully or partially supported with IT resources. (Recommendation 26)

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

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

Recommendation: The Administrator of CMS should ensure that the Office of the CIO and other offices, as appropriate, develop and implement policies and procedures that document the processes by which program leadership works with the CIO to plan an overall portfolio of IT resources. (Recommendation 27)

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

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

Recommendation: The Administrator of CMS should ensure that the Office of the CIO and other offices, as appropriate, develop and implement policies and procedures that document the CIO's role in reviewing IT resources that are to support major program objectives and significant increases and decreases in IT resources. (Recommendation 28)

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

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

Recommendation: The Administrator of CMS should direct the Office of the CIO and other offices, as appropriate, to take steps to ensure that the actions taken to comply with OMB's common baseline for implementing FITARA on individual investments are adequately documented. (Recommendation 29)

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

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

Recommendation: The Attorney General should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that include the CIO as a member of governance boards that inform decisions regarding all IT resources, including component-level boards. (Recommendation 31)

Agency: Department of Justice
Status: Open

Comments: The department agreed with the recommendation and has taken steps towards implementing it. Specifically, in October 2019, the DOJ CIO issued a memorandum requiring component CIOs to establish a process for providing IT investment information to the DOJ CIO. The component CIO's process is to either include the DOJ CIO as a member of component investment review boards or provide an alternative mechanism for obtaining the DOJ CIO's input on component IT investments. We will continue to monitor the department's progress in implementing our recommendation.

Recommendation: The FBI Director should direct the Office of the CIO and other offices, as appropriate, to take steps to ensure that the actions taken to comply with OMB's common baseline for implementing FITARA on individual investments are adequately documented. (Recommendation 34)

Agency: Department of Justice: Federal Bureau of Investigation
Status: Open

Comments: FBI agreed with our recommendation. 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 the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that establish department-wide policy for the level of detail of planned expenditure reporting to the CIO for all transactions that include IT resources. (Recommendation 35)

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Secretary of the Treasury should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that include the CIO in the planning and budgeting stages for all programs that are fully or partially supported with IT resources. (Recommendation 36)

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Secretary of the Treasury should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that include the CIO as a member of governance boards that inform decisions regarding all IT resources, including component-level boards. (Recommendation 37)

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Secretary of the Treasury should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the process for the CIO's review and approval of the major IT investments portion of the budget request. (Recommendation 38)

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Secretary of the Treasury should ensure that the Office of the CIO and other offices, as appropriate, address gaps in the department's FITARA plans by developing and implementing policies and procedures that document the steps the CIO is to take to ensure whether the IT portfolio includes appropriate estimates of all IT resources included in the budget request. (Recommendation 39)

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Secretary of the Treasury should direct the department CIO to establish, for any OMB common baseline requirements that are related to IT budgeting that have been delegated, a plan that specifies the requirement being delegated, demonstrates how the CIO intends to retain accountability for the requirement, and ensures through quality assurance processes that the delegated official will execute such responsibilities with the appropriate level of rigor. (Recommendation 40)

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Secretary of the Treasury should direct the Office of the CIO and other offices, as appropriate, to take steps to ensure that the actions taken to comply with OMB's common baseline for implementing FITARA on individual investments are adequately documented. (Recommendation 41)

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Secretary of the Treasury should ensure that the Office of the CIO and other offices, as appropriate, establish quality assurance processes--such as data quality checks, reviews of estimation methods, linkages between the IT portfolio and procurement system data, and linkages between the IT portfolio and financial system data--for ensuring the annual IT budget is informed by complete and reliable information on anticipated government labor, contract, and other relevant IT expenditures. (Recommendation 42)

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Acting Commissioner of the Bureau of Labor Statistics should, upon completion of the pilot Household Survey of Occupational Injuries and Illnesses, evaluate the feasibility of measuring injuries and illnesses to certain worker populations--specifically, children aged 17 and under, child household workers, and those employed on farms with 10 or fewer workers--in any final survey scope, or determine a way to gather information on these populations. (Recommendation 1)

Agency: Department of Labor
Status: Open

Comments: BLS noted that it had completed the pilot Household Survey of Occupational Injuries and Illnesses (HSOII) in December of 2018 and stated that BLS will be analyzing the quality of the data in the second and third quarters of 2019 and publishing a report at the end of 2019. To evaluate the feasibility of measuring injuries and illnesses to workers under 18, BLS stated it will conduct a literature review on questionnaire design for respondents under age 18, and reviewing the evidence on the quality of data collected through proxy reporting, e.g. adults reporting on injuries/illnesses for their children. The agency also reported that it will issue an assessment of the suitability of the existing HSOII instrument to gather data on working children at the end of fiscal year 2019. We will consider closing this recommendation after receipt and review of this final assessment report.

Recommendation: The Administrator of the Wage and Hour Division should establish specific metrics and associated targets for child labor-related outreach in agriculture. (Recommendation 2)

Agency: Department of Labor
Status: Open

Comments: The agency agreed with this recommendation. The agency noted that it has existing performance measures that separately track the number of employer outreach events and the number of events involving child labor. The agency stated that, in response to GAO's recommendation, it will introduce a new measure in FY2020 that is specific to child labor-related outreach in the agricultural industry. The agency said that for the remainder of FY2019, the agency will develop the new measure, establish a baseline, and set an appropriate target for child labor-related outreach in the agricultural industry. The agency also said staff would be trained on the new measure in early 2020. We will close this recommendation once the agency institutes this new metric.

Recommendation: The Administrator of the Wage and Hour Division should develop performance metrics or other measures specific to its child labor enforcement approach, such as whether WHD investigations are conducted at establishments where children are likely to be working. (Recommendation 3)

Agency: Department of Labor
Status: Open

Comments: WHD agreed that it could develop either an internal performance metric or new planning guidance and reporting requirements to ensure that WHD's child labor enforcement efforts focus on industries, establishments, and time periods in which children are likely to be working or injured. Although planning guidance and reporting requirements can encourage field office staff to focus more on child labor, we believe it is important to include a measurement of WHD's overall child labor enforcement approach as part of any new planning guidance and reporting requirements. We will consider closing this recommendation when WHD develops such performance metrics.

Recommendation: The Administrator of the Wage and Hour Division and the Assistant Secretary of the Occupational Safety and Health Administration should update and routinely monitor the 1990 WHD and Occupational Safety and Health Administration memorandum of understanding and establish documented procedures for monitoring the exchange of and actions taken on referrals. (Recommendation 4)

Agency: Department of Labor
Status: Open

Comments: To implement this recommendation, WHD and OSHA have agreed to establish a working group by the second quarter of FY2019, which will aim to maximize efficient information sharing between the two agencies. Specifically, this working group will update the existing WHD-OSHA Memorandum of Understanding, assess the results of referrals between WHD and OSHA, and make recommendations regarding the need for data collection and review. We will close this recommendation when these efforts are complete and supporting documentation has been provided.

Recommendation: The Director of the Departmental Enforcement Center and the Assistant Secretary for Community Planning and Development should develop written guidance for CPD's field offices to use when determining whether to make a referral to the Departmental Enforcement Center. (Recommendation 1)

Agency: Department of Housing and Urban Development
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 the Departmental Enforcement Center and the Assistant Secretary for Public and Indian Housing should develop written guidance for PIH's field offices to use when determining whether to make a referral to the Departmental Enforcement Center. (Recommendation 2)

Agency: Department of Housing and Urban Development
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 the Departmental Enforcement Center and the Assistant Secretary for Community Planning and Development should develop targets for the number of referrals that CPD should make to DEC that are based on program risk. (Recommendation 3)

Agency: Department of Housing and Urban Development
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 the Departmental Enforcement Center and the Assistant Secretary for Public and Indian Housing should develop targets for the number of referrals that PIH should make to DEC that are based on program risk. (Recommendation 4)

Agency: Department of Housing and Urban Development
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 the Departmental Enforcement Center should develop and implement performance measures that assess the outcomes, or desired results, of its enforcement activities. (Recommendation 5)

Agency: Department of Housing and Urban Development
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 the Departmental Enforcement Center should develop and implement performance measures of its timeliness in completing oversight reviews. (Recommendation 6)

Agency: Department of Housing and Urban Development
Status: Open

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