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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation: The Director of 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 VA should improve the completeness and accuracy of use of force data in Report Executive by addressing (1) incomplete categorization of the type of force used, (2) inaccurate data on the highest level of force used, and (3) the potential for duplicate data entries. (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 Secretary of VA should implement plans to include analytical features in Report Executive that will position the agency to analyze use of force data at VA medical centers nationwide, including by officer; type of force used; and facility, among other variables. (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 Secretary of VA should ensure that medical centers submit records of all locally initiated use of force investigations and any resulting disciplinary action to VA headquarters office(s) with responsibility for police oversight. (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 Secretary of VA should implement plans for obtaining a quality database to collect all locally initiated use of force investigations at medical centers. (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: Once positioned to do so, the Secretary of VA should analyze all use of force investigations and any resulting disciplinary action by facility; officer; and outcome, among other variables. (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 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 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 Homeland Security should direct the Director of ICE to develop a strategy for the TTU program to ensure that ICE has a plan to guide its efforts to effectively partner with existing TTUs, and to expand the program, where appropriate, into additional countries. (Recommendation 1)

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 Secretary of Homeland Security should direct the Director of ICE to develop a performance monitoring framework for the TTU program that would enable the agency to systematically track program results and how effectively it is achieving the program's goals. (Recommendation 2)

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 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 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 Homeland Security should identify the information about family members apprehended together that its components collectively need to process those family members and communicate that information to its components. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: According to DHS, in June 2020, DHS's Office of Immigration Statistics launched a Family Status Data Standards Community of Interest (COI) under the purview of the DHS Immigration Data Integration Initiative. In August 2020, DHS reported that the Family Status COI includes subject matter experts and data system managers from DHS components, the Department of Health and Human Services, and the Executive Office for Immigration Review. The COI's mandate includes drafting common DHS-wide and interagency data standards (common codes, common definitions, common formats) for all topics related to family status, including codes to identify the reasons for family separation, members apprehended together, and unaccompanied children. DHS expects to complete these actions by September 30, 2020. Identifying and communicating department-wide information needs with respect to family members who have been apprehended together should help provide DHS with greater assurance that its components are identifying all individuals who may be eligible for relief from removal from the United States based on their family relationships.

Recommendation: The Secretary of Homeland Security should ensure that, at the time of apprehension, CBP collects the information that DHS components collectively need to process family members apprehended together. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: In commenting on a draft of our report, DHS reported that its Office of Immigration Statistics (OIS) will work with relevant components and offices to ensure all required information is collected at the time of apprehension on the Form I-213 when processing family members apprehended together. As of August 2020, DHS reported that DHS OIS continues to work with relevant components and offices to ensure all required information is collected at the time of apprehension on Form I-213 when processing family members apprehended together. DHS expects to complete these actions by September 30, 2020. Collecting information about the relationships between family members apprehended together and documenting that information on the Form I-213 could help address fragmentation among DHS components and improve the information available to other agencies.

Recommendation: The Secretary of Homeland Security should ensure that CBP documents the information that DHS components collectively need to process family members apprehended together on the Form I-213. (Recommendation 3)

Agency: Department of Homeland Security
Status: Open

Comments: In commenting on a draft of our report, DHS reported that, upon implementation of the steps the department plans to take in response to our second recommendation, CBP will issue guidance to the field to ensure that CBP agents and officers document the information that DHS components collectively need to process family members. In August 2020, DHS reported that component agencies continue to collaborate to define the process of family members apprehended together, as will be reflected on CBP Form I-213. DHS estimates issuing this guidance by March 31, 2021. Collecting information about the relationships between family members apprehended together and documenting that information on the Form I-213 could help address fragmentation among DHS components and improve the information available to other agencies.immigration or other proceedings.

Recommendation: The Secretary of Homeland Security should evaluate options for developing a unique identifier shared across DHS components' data systems to link family members apprehended together. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: In commenting on a draft of our report, DHS reported that its Office of Immigration Statistics (OIS) plans to work with relevant components to develop a unique shared identifier linking family members apprehended together. According to DHS, DHS OIS launched the Family Status Community of Interest (COI) in June 2020, and the COI has since established a bi-weekly meeting schedule. The COI's initial focus is on standard codes describing the reasons for family separations. Upon completing the family separation reason standard, DHS reported that the COI will prioritize developing common codes to identify family members apprehended together. DHS estimates completing these actions by March 31, 2021. Evaluating options for developing a shared unique family member identifier across components that would allow each component access to certain information about family members apprehended together would help bridge the information gaps about family relationships between components caused by DHS's fragmented data systems.

Recommendation: The FEC, in consultation with DOJ, should review guidance addressing coordination with DOJ, to include the MOU, and once a quorum of commissioners is in place, update that guidance as appropriate based on the review. (Recommendation 1)

Agency: Federal Election 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 Attorney General, in consultation with the FEC, should review guidance addressing coordination with the FEC, to include the MOU, and once a quorum of commissioners is in place, update that guidance as appropriate based on the review. (Recommendation 2)

Agency: Department of Justice: Office of the Attorney General
Status: Open

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

Recommendation: The 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 Director of the Secret Service should identify which types of investigations and activities best prepare special agents for protective responsibilities. (Recommendation 1)

Agency: Department of Homeland Security: United States Secret Service
Status: Open

Comments: The agency has submitted a 180-day letter describing actions it is planning to take in response to this recommendation.

Recommendation: The Director of the Secret Service should develop a framework to help ensure special agents have an opportunity to work, to the extent possible, investigations and activities that best prepare them for protection. (Recommendation 2)

Agency: Department of Homeland Security: United States Secret Service
Status: Open

Comments: The agency has submitted a 180-day letter describing actions it is planning to take in response to this recommendation.

Recommendation: The Director of the Secret Service should establish a documented process to ensure that Office of Investigations resources are aligned with priority criminal threats. The process should outline key information to be included in plans for addressing priority threats. (Recommendation 3)

Agency: Department of Homeland Security: United States Secret Service
Status: Open

Comments: The agency has submitted a 180-day letter describing actions it is planning to take in response to this recommendation.

Recommendation: The Director of the Secret Service should identify investigations that address priority criminal threats agencywide and collect data on the resources expended to investigate the threats. (Recommendation 4)

Agency: Department of Homeland Security: United States Secret Service
Status: Open

Comments: The agency has submitted a 180-day letter describing actions it is planning to take in response to this recommendation.

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 Securities and Exchange Commission's Co-Directors of Enforcement should develop written procedures for generating Enforcement's public reports, including procedures for compiling and verifying statistics used in the reports and documenting their implementation. (Recommendation 1)

Agency: United States Securities and Exchange Commission: Division of 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 Attorney General should ensure that relevant DOJ offices update information about religious-based hate crimes on college campuses, practices to address them, and available DOJ resources to help colleges, campus law enforcement, and other stakeholders monitor and address these crimes. (Recommendation 1)

Agency: Department of Justice
Status: Open

Comments: DOJ has taken a number of steps to address this recommendation, including creating a campus-specific brochure that highlights the Community Relations Service's (CRS) hate crimes prevention and response resources for campus stakeholders. CRS is also in the process of developing a comprehensive guide with best practices for and tools to aid in the planning and implementation of Campus SPIRIT programs and a "spotlight" article for the Department's hate crimes website. DOJ noted that the Office of Community Oriented Policing Services (COPS) is developing hate crimes-specific training curriculum to provide technical assistance to law enforcement agencies, including those on campus. These are important steps to implement this recommendation, but because these resources are currently under development, this recommendation remains open.

Recommendation: The Attorney General should ensure that relevant DOJ offices share more information about available DOJ resources with colleges, campus law enforcement, and other stakeholders to help them monitor and address religious-based hate crimes on college campuses. (Recommendation 3)

Agency: Department of Justice
Status: Open

Comments: DOJ outlined steps it will take to work with campus-based law enforcement organizations such as the International Association of Campus Law Enforcement Administrators, the International Association of Chiefs of Police's University and College Police Section, and the National Association of Student Affairs Professionals. This includes participating in a conference in June 2020 and contacting the groups to increase awareness of its hate crimes website. GAO has requested documentation to demonstrate this outreach has occurred.

Recommendation: The Director of USCIS should plan and conduct regular fraud risk assessments of the self-petition program to determine a fraud risk profile, as provided in GAO's Fraud Risk Framework. (Recommendation 1)

Agency: Department of Homeland Security: United States Citizenship and Immigration 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 Director of USCIS should develop and implement an antifraud strategy with specific control activities, based upon the results of fraud risk assessments and a corresponding fraud risk profile, as provided in GAO's Fraud Risk Framework. (Recommendation 2)

Agency: Department of Homeland Security: United States Citizenship and Immigration 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 Director of USCIS should develop and implement data analytics capabilities for the self-petition program, as a means to prevent and detect fraud, as provided in GAO's Fraud Risk Framework. (Recommendation 3)

Agency: Department of Homeland Security: United States Citizenship and Immigration 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 Director of BLM should develop a plan to conduct all required facility security assessments agency-wide, taking into consideration the agency's organizational structure, available resources, and training needs. (Recommendation 1)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM agreed with our recommendation and stated it intends to revise its policy and develop a plan to complete required facility security assessments. As of November 2019, BLM had not yet completed its plan.

Recommendation: The Director of the Park Service should develop a plan to conduct all required facility security assessments agency-wide, taking into consideration the agency's organizational structure, available resources, and training needs. (Recommendation 3)

Agency: Department of the Interior: National Park Service
Status: Open

Comments: Park Service agreed with our recommendation and cited its efforts to develop a plan that includes training and tools so that park unit staff can conduct the required assessments. As of November 2019, Park Service had not yet completed its plan.

Recommendation: The Director of the Park Service should update the agency's facility security assessment methodology to comply with requirements in the ISC Standard, including a step to consider the consequence of each undesirable event. (Recommendation 4)

Agency: Department of the Interior: National Park Service
Status: Open

Comments: Park Service agreed with our recommendation to update its facility security assessment methodology to comply with requirements in the ISC Standard. As of November 2019, Park Service had not yet updated its methodology.

Recommendation: The Director of BLM should develop a facility security assessment methodology that complies with requirements in the ISC Standard to assess all undesirable events and consider all three factors of risk for each undesirable event. (Recommendation 5)

Agency: Department of the Interior: Bureau of Land Management
Status: Open

Comments: BLM agreed with our recommendation and said it would revise its policy and develop a facility security assessment methodology that complies with requirements in the ISC Standard. As of November 2019, BLM had not yet developed its methodology.

Recommendation: The Director of FWS should develop a facility security assessment methodology that complies with requirements in the ISC Standard to assess all undesirable events and consider all three factors of risk for each undesirable event. (Recommendation 6)

Agency: Department of the Interior: United States Fish and Wildlife Service
Status: Open

Comments: FWS agreed with our recommendation and cited its efforts to develop a facility security assessment methodology that complies with requirements in the ISC Standard. As of November 2019, FWS had not yet developed its methodology.

Recommendation: The Attorney General should develop and document goals that explain the common outcomes DOJ seeks to achieve through its elder justice efforts. (Recommendation 1)

Agency: Department of Justice
Status: Open

Comments: In its comments on a draft of our report in May 2019, DOJ did not explicitly state whether or not it concurred with the two recommendations we directed to the department, but stated that it is taking our recommendations under serious review. Specifically, DOJ stated that it planned to form a subcommittee within its Elder Justice Working Group to consider the development or clarification of goals and the development of outcome measures. In a follow-up response dated December 17, 2019, DOJ noted that the subcommittee had been formed, and had met to explore the development of additional---or clarification of present---goals, including those referenced in our report. We will continue to monitor DOJ's efforts towards implementing this recommendation.

Recommendation: The Attorney General should develop and document outcome measures to track the progress the agency is making toward achieving its elder justice goals. (Recommendation 2)

Agency: Department of Justice
Status: Open

Comments: In its comments on a draft of our report in May 2019, DOJ did not explicitly state whether or not it concurred with the two recommendations we directed to the department, but stated that it is taking our recommendations under serious review. Specifically, DOJ stated that it planned to form a subcommittee within its Elder Justice Working Group to consider the development or clarification of goals and the development of outcome measures. In a follow-up response dated December 17, 2019, DOJ noted that the subcommittee had been formed, and had met to begin developing and documenting appropriate outcome measures that can better track the Department's progress on its overall elder justice efforts. This will include consideration of the specific suggestions cited in our report, as well exploring opportunities for additional data collection to enhance the Department's efforts and better measure outcomes. We will continue to monitor DOJ's efforts towards implementing this recommendation.

Recommendation: The Secretary of the Army should develop the capability to present servicemembers' race and ethnicity data in its investigations and personnel databases using the same categories of race and ethnicity established in the December 2018 uniform standards for the military justice databases, either by (1) modifying the Army's investigations and personnel databases to collect and maintain the data in accordance with the uniform standards, (2) developing the capability to aggregate the data into the race and ethnicity categories included in the uniform standards, or (3) implementing another method identified by the Army. (Recommendation 2)

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

Comments: DOD concurred with this recommendation. In October 2019, Army officials said that the Army was working to implement the uniform standards for race and ethnicity and the ability to aggregate the data, in accordance with the criteria established by the General Counsel of the Department of Defense on December 17, 2018. They expected to implement these categories in December 2020.

Recommendation: The Secretary of the Air Force should develop the capability to present servicemembers' race and ethnicity data in its investigations and personnel databases using the same categories of race and ethnicity established in the December 2018 uniform standards for the military justice databases, either by (1) modifying the Air Force's investigations and personnel databases to collect and maintain the data in accordance with the uniform standards, (2) developing the capability to aggregate the data into the race and ethnicity categories included in the uniform standards, or (3) implementing another method identified by the Air Force. (Recommendation 3)

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

Comments: DOD concurred with this recommendation. In October 2019, Air Force officials said that the Air Force was working to implement uniform standards for collection of military justice data and records in accordance with the criteria established by the General Counsel of the Department of Defense on December 17, 2018. They expected to implement these standards in December 2020.

Recommendation: The Secretary of the Navy should develop the capability to present servicemembers' race and ethnicity data in its investigations and personnel databases using the same categories of race and ethnicity established in the December 2018 uniform standards for the military justice databases, either by (1) modifying the Navy's investigations and personnel databases to collect and maintain the data in accordance with the uniform standards, (2) developing the capability to aggregate the data into the race and ethnicity categories included in the uniform standards, or (3) implementing another method identified by the Navy. (Recommendation 4)

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

Comments: DOD concurred with this recommendation. In October 2019, Navy officials said that the Navy was working to implement the uniform standards for race and ethnicity in their new case management system which was currently under development, and may implement changes to interface with Navy investigations and personnel databases. They expected to implement these changes in December 2020.

Recommendation: The Secretary of Homeland Security should ensure that the Commandant of the Coast Guard develops the capability to present servicemembers' race and ethnicity data in its investigations and personnel databases using the same categories of race and ethnicity established in the December 2018 uniform standards for the military justice databases, either by (1) modifying the Coast Guard's investigations and personnel databases to collect and maintain the data in accordance with the uniform standards, (2) developing the capability to aggregate the data into the race and ethnicity categories included in the uniform standards, or (3) implementing another method identified by the Coast Guard. (Recommendation 5)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation. In May 2019, the Coast Guard stated that it would implement modifications to the Coast Guard's military justice database to support the tracking of race, ethnicity and gender information as part of a longer term initiative to capture all of the data elements required by the uniform standard adopted by the Department of Defense. They estimated this would be completed in September 2020.

Recommendation: The Secretary of Defense, in collaboration with the Secretaries of the military services and the Secretary of Homeland Security, should issue guidance that establishes criteria to specify when data indicating possible racial, ethnic, or gender disparities in the military justice process should be further reviewed, and that describes the steps that should be taken to conduct such a review. (Recommendation 7)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation, agreeing with the content, but requesting that we modify the recommendation to direct it to more appropriate entities. That change was made before the report was issued. In October 2019, DOD officials said that the department was exploring the feasibility of conducting relevant research to inform implementation of this recommendation. They said that this research will explore differences in military justice data, seek to identify potential factors that contribute to observed racial/ethnic disparities, and develop standardized tracking elements so trends can be monitored across DOD. They estimated that this research may be concluded in March 2021.

Recommendation: The Secretary of the Army should consider the feasibility, to include the benefits and drawbacks, of collecting and maintaining complete information for all nonjudicial punishment cases in one of the Army's databases, such as information on the servicemembers' race, ethnicity, gender, offense, and punishment imposed. (Recommendation 8)

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

Comments: DOD concurred with this recommendation. In October 2019, Army officials said that the Army was developing the capability to collect data of race, ethnicity, gender, offense and punishment imposed for nonjudicial punishments in accordance with the criteria established by the General Counsel of the Department of Defense on December 17, 2018. They expected to complete this action in December 2020.

Recommendation: The Secretary of the Navy should consider the feasibility, to include the benefits and drawbacks, of collecting and maintaining complete information for all nonjudicial punishment cases in one of the Navy's databases, such as information on the servicemembers' race, ethnicity, gender, offense, and punishment imposed. (Recommendation 9)

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

Comments: DOD concurred with this recommendation. In October 2019, Navy officials said that the Navy was refining its processes to standardize the documentation and reporting requirements of all nonjudicial punishment cases. They further stated that the Marine Corps currently has the ability to capture this information, but in two different systems that could be extracted and assimilated with any system as required. They expected to implement these changes in December 2020.

Recommendation: The Secretary of Homeland Security should ensure that the Commandant of the Coast Guard considers the feasibility, to include the benefits and drawbacks, of collecting and maintaining complete information for all nonjudicial punishment cases in one of the Coast Guard's databases, such as information on the servicemembers' race, ethnicity, gender, offense, and punishment imposed. (Recommendation 10)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation. In May 2019, the Coast Guard stated that it would consider the feasibility of collecting and maintain complete information for all nonjudicial punishments cases through a military justice and personnel work group. The estimated completion date for this action was not yet determined.

Recommendation: The Secretary of Defense, in collaboration with the Secretaries of the military services and the Secretary of Homeland Security, should conduct an evaluation to identify the causes of any disparities in the military justice system, and take steps to address the causes of these disparities as appropriate. (Recommendation 11)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation, agreeing with the content, but requesting that we modify the recommendation to direct it to more appropriate entities. We made that change before the report was issued. In October 2019, DOD officials said that the department was exploring the feasibility of conducting a research project to delve into the differences in military justice data to inform implementation of this recommendation. They said that this research will explore differences in military justice data, seek to identify potential factors that contribute to observed racial/ethnic disparities, identify potential disparity indicators, and develop standardized tracking elements so trends can be monitored across DOD. They estimated that this research may be concluded in March 2021.

Recommendation: The Director of the Secret Service should develop and implement a plan to ensure that special agents assigned to Presidential Protective Division and Vice Presidential Protective Division reach annual training targets given current and planned staffing levels. (Recommendation 1)

Agency: Department of Homeland Security: United States Secret Service
Status: Open

Comments: In May 2019 we reported that the Secret Service had not met the established training target (25 percent of work time) and lacked a plan for achieving it. We therefore recommended that the Director of the Secret Service develop and implement a plan to ensure that special agents assigned to the Presidential Protective Division and the Vice Presidential Protective Division reach annual training targets given current and planned staffing levels. The agency concurred with our recommendation. Towards addressing this recommendation, in October 2019, the Secret Service reported that the Office of Protective Operations is currently soliciting training requirements from each internal operational division, including the Presidential and Vice Presidential Protective Divisions, to determine the appropriate amount of training and associated training hours for each division. They further reported that once reviewed, the training requirements are to inform the agency's revised Human Capital Strategic Plan. The revised Human Capital Strategic Plan is to include an overview of Office of Protective Operations' training requirements and corresponding staffing needs. The Secret Service anticipates a revised Human Capital Strategic Plan to be available by the end of January 2020. The Secret Service's efforts to reevaluate the training requirements and targets are a positive first step. However, Secret Service's actions are not fully consistent with the recommendation. Specifically, in its updated response, the Secret Service stated that training hours for Presidential Protective Division and Vice Presidential Protective Division special agents training will only increase once the agency nears its ultimate staffing target. This is inconsistent with our recommendation to establish a plan to ensure these special agents reach annual training targets given current staffing levels. In the interim, affected special agents may continue to lack training required to prevent security breaches, such as that of September 19, 2019, when an intruder jumped the north fence and entered the White House. We will continue to monitor the Secret Service's progress in implementing this recommendation.

Recommendation: The Director of the Secret Service should develop and implement a policy that documents the process for collecting complete Uniformed Division officer training data and establishes the types of information that should be collected. (Recommendation 2)

Agency: Department of Homeland Security: United States Secret Service
Status: Open

Comments: In May 2019 we reported that training data collected on the Secret Service's Uniform Division were incomplete and in certain cases unrelated to protection or lacked descriptions to clearly link the training to required skills. Further, the process used to capture the data was not consistently employed and did not include information on how or whether to capture internal on-the-job training instances, or instruction on the type of training to be captured to demonstrate that the training is protection-related training. We therefore recommended that the Director of the Secret Service develop and implement a policy that documents the process for collecting complete Uniformed Division officer training data and establishes the types of information that should be collected. The Secret Service, through DHS, concurred with our recommendation, stating that it would develop rigorous and uniform standards for collecting and reporting training data related to the Uniformed Division branch, and would work to capture additional training information. In response to our recommendation, in October 2019 the Secret Service reported that the Uniformed Division has worked with the Office of Training and Performance and Learning Management System (PALMS) team to capture Uniformed Division training requirements. The requirements are to include the 20 formalized on-the-job training programs for officers assigned to the Uniformed Division's White House, Foreign Missions, and Naval Observatory Branches, or one of the Special Operations Branch specialized units. In addition, the Secret Service stated that approximately 19 micro-training courses (also known as Roll Call Training) are currently captured within PALMS-the Department of Homeland Security's learning management system -and additional formalized on-the-job training programs are being reviewed for inclusion in PALMS. According to the Secret Service, use of PALMS should help ensure that the process for collecting and recording Uniformed Officer training is standardized and monitored. The Secret Service's efforts to capture additional training information in PALMS is a positive development. However, we have not yet observed progress towards the Secret Service's implementation of a policy that documents the process for collecting complete Uniformed Division officer training data and establishes the types of information that should be collected, as we recommended. We will continue to monitor the Secret Service's progress in implementing this recommendation.

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: 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: 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 Commissioner of CBP should revise policy or guidance to ensure documentation of required control activities in its case management system, such as legal review of adverse actions, and data verification (Recommendation 1).

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

Comments: In February 2020, CBP provided documentation of a data verification checklist used by its Office of Professional Responsibility for the Joint Integrity Case Management System. However, CBP also needs to develop a similar tool or method to verify case management data contained in its Human Resource Business Engine system. And to fully implement this recommendation, CBP needs to revise policy or guidance to ensure documentation of control activities (data verification and legal review of adverse actions) in its case management systems. We are continuing to follow-up on the actions taken by CBP to implement this recommendation.

Recommendation: The Commissioner of CBP should monitor the duration of all cases beginning-to-end by stage and by case type (Recommendation 4).

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

Comments: In October 2018, CBP told us that it is currently updating one of its case management systems to better monitor cases beginning-to-end by stage and by case type. Once implemented, CBP's Office of Professional Responsibility will develop an internal management report that includes information on caseload and associated timelines. The estimated completion date for this recommendation is September 30, 2019. As of September 2020, we are continuing to follow up with CBP on its actions to implement this recommendation.

Recommendation: The Commissioner of CBP should monitor the timeliness of misconduct cases according to established targets for management inquiries, administrative inquiries, and criminal and non-criminal investigations using case management system data (Recommendation 5).

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

Comments: In October 2018, CBP stated that it is currently updating one of its case management systems to better monitor the timeliness of misconduct cases according to established targets. Once updated, CBP's Office of Professional Responsibility will develop an internal management report that includes information on caseload and associated timelines. The estimated completion date for this recommendation is September 30, 2019. As of September 2020, we are continuing to follow up with CBP on its actions to implement this recommendation.

Recommendation: The Commissioner of CBP should define and document the case management system data fields to be used for monitoring all established performance targets and provide related guidance to staff (Recommendation 6).

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

Comments: In October 2018, CBP stated that its Office of Professional Responsibility will define the case management system data fields used to measure established performance targets, and it will provide the appropriate guidance to staff. The estimated completion date of this recommendation is September 30, 2019. As of September 2020, we are continuing to follow up with CBP on its actions to implement this recommendation.

Recommendation: The Director of ICE should require staff to document the investigative findings (case resolution codes) of management inquiries in the case management system (Recommendation 8).

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

Comments: In November 2018, ICE provided documentation of related communication provided to staff. However, this documentation did not include revised policy or guidance documents that requires staff to document the investigative findings in the employee misconduct case management system. As of September 2020, we are continuing to follow-up on ICE's actions to implement this recommendation.

Recommendation: The Director of ICE should modify ICE's annual self-inspection program to track the status of related corrective actions to ensure they are implemented in a timely manner (Recommendation 9).

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

Comments: In October 2018, ICE stated that it is revising its policy for its self-Inspection program to track the status of related corrective actions. ICE also stated that it will review three program offices for compliance with these revised policies and procedures during fiscal year 2019. The estimated completion date of this recommendation is June 28, 2019. As of September 2020, we are continuing to follow-up on ICE's actions to implement this recommendation.

Recommendation: The Director of ICE should monitor the duration of all cases beginning-to-end by stage and by case type (Recommendation 10).

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

Comments: In October 2018, ICE stated that beginning in fiscal year 2019, a project team will develop the capability to monitor the duration of all employee misconduct cases beginning-to-end by stage and by case type. The estimated completion date of this recommendation is June 28, 2019. As of September 2020, we are continuing to follow-up on ICE's actions to implement this recommendation.

Recommendation: The Director of ICE should monitor the timeliness of misconduct cases according to established targets for management inquiries and Employee Relations specialist review of proposal and decision of disciplinary outcomes using case management system data (Recommendation 11).

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

Comments: In October 2018, ICE stated that its Office of Professional Responsibility developed guidance regarding established targets for the completion of management inquiries and will distribute the guidance to applicable staff. ICE also stated that it is developing timeliness targets for Employee Relations specialist review of proposals and decisions of disciplinary outcomes and will also distribute this guidance to applicable staff. The estimated completion date for this recommendation is June 28, 2019. As of September 2020, we are continuing to follow-up on ICE's actions to implement this recommendation.

Recommendation: The Director of ICE should define and document the case management system data fields and methodology to be used for monitoring all established performance targets and provide related guidance to staff (Recommendation 12).

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

Comments: In October 2018, ICE stated that it will work to define and document the case management system data fields and methodology to be used for monitoring all established performance targets and will provide related guidance to applicable staff. The estimated completion date for this recommendation is June 28, 2019. As of September 2020, we are continuing to follow-up on ICE's actions to implement this recommendation.

Recommendation: The Administrator of TSA should monitor the duration of all cases beginning-to-end by stage and case type (Recommendation 16).

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

Comments: In September 2020, TSA provided documentation of internal reports that measure duration. However, the reports do not provide management information on the duration of all case types from beginning-to-end and, by stage. TSA needs to provide evidence that it monitors the duration of all cases, including a description of which process stages are measured and which data fields are used to measure the total duration from beginning-to-end and by stage. We are continuing to follow up on the actions taken by TSA to implement this recommendation.

Recommendation: The Administrator of TSA should monitor the timeliness of misconduct cases according to established targets for management inquiries (fact finding) and administrative inquiries, and the proposal and decision stages, using case information system data (Recommendation 17).

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

Comments: In September 2020, TSA provided evidence of reports it uses to measure duration. However, these reports do not show how TSA performs with regards to established targets. TSA needs to provide evidence of how it monitors the timeliness of all established targets , including which specific data fields are used to measure these targets. We are continuing to follow up on the actions taken by TSA to implement this recommendation.

Recommendation: The Administrator of TSA should define and document the case management system data fields and methodology to be used for monitoring all established performance targets and provide related guidance to staff (Recommendation 18).

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

Comments: In May 2019, TSA provided guidance to its staff related to monitoring performance targets. However, these documents do not specify which system data should be used as part of the methodology for monitoring all established performance targets. TSA needs to provide documentation of guidance to staff that defines and documents all the specific case management system data field names (in the various databases, as applicable) and methodology staff should use to monitor all established timeliness targets. We are continuing to follow up on the actions taken by TSA to implement this recommendation.

Recommendation: The Department of Veterans Affairs (VA) Inspector General should revise its policy to include a requirement to verify whether evidence produced in senior-official case referrals demonstrates that the six elements required in VA Directive 0701 have been addressed. (Recommendation 6)

Agency: Department of Veterans Affairs
Status: Open

Comments: The VA Office of the Inspector General updated VA Directive 0701 to require a written or electronic signature from the person preparing the response that the specific requirements of the directive were met. The updated version of the directive was submitted to the Department, the concurrence was signed on November 16, 2018. As of January 2019, the VA OIG was working with the VA to finalize and publish the directive. On February 15, 2019, the VA OIG contacted GAO with revised language for VA Directive 0701. The language clarified the requirement to include a signature and attestation by the person preparing the response. As of June 2020, the VA OIG is in the process of working with the VA administration to finalize and publish the directive. In September 2020, GAO requested an update from the VA OIG on the status of publishing the directive.

Recommendation: The Administrator of CMS should consider and take steps to mitigate the program risks that are not measured in the PERM, such as overpayments and unallowable costs; such an effort could include actions such as revising the PERM methodology or focusing additional audit resources on managed care. (Recommendation 1)

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

Comments: CMS concurred with this recommendation. In October 2018, it reported that it was developing a plan to address the recommendation. CMS also reported that it has published several guidance documents and is in the process of finalizing others. In addition, it reported that it continues to develop educational strategies (such as a recent course managed care offered by CMS' Medicaid Integrity Institute) and oversight and audit strategies and mechanisms related to managed care. CMS communicated that it initiated 32 audits involving Medicaid managed care network providers in 6 states and an audit of a managed care plan in another state in FY 2018. For FY 2019, CMS stated that it will be establishing a medical loss ratio examination process and initiating such audits of managed care organizations in California. CMS also stated that it will be developing guidance for states and managed care plans on managed care delivery and oversight to develop program integrity capacity and reduce program risks. As of December 2019, CMS has not taken any additional steps; we will continue to monitor CMS's progress to mitigate the managed care program risks not measured in the PERM.

Recommendation: The Director of National Intelligence, in his capacity as Security Executive Agent, and in coordination with the other Security, Suitability, and Credentialing Performance Accountability Council Principals--the Deputy Director for Management of Office of Management and Budget (OMB) in his capacity as Chair of the PAC, the Director of OPM, and the Under Secretary of Defense for Intelligence--should establish a milestone for the completion of government-wide performance measures for the quality of investigations. (Recommendation 1)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI stated that it non-concurred with many of the report's recommendations, but did not state with which recommendations it did not concur. In August 2019, ODNI officials pointed to the Quality Assessment Reporting Tool as the mechanism to measure the quality of background investigations. However, officials also stated that they had not finalized collection of all required data to establish performance measures and, while QART contains a significant data sample size, the data call issued in January 2019 will provide additional information for comparative analysis to develop performance measures for the entire Executive Branch. Officials agreed that since DOD does not use QART, there needed to be ongoing discussions with them to ensure quality standards are met. We will continue to follow-up on the status of this recommendation.

Recommendation: The Director of National Intelligence, in his capacity as Security Executive Agent, and in coordination with the other Security, Suitability, and Credentialing Performance Accountability Council Principals--the Deputy Director for Management of OMB in his capacity as Chair of the PAC, the Director of OPM, and the Under Secretary of Defense for Intelligence--should conduct an evidence-based review of the investigation and adjudication timeliness objectives for completing the fastest 90 percent of initial secret and initial top secret security clearances.(Recommendation 2)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI stated that it non-concurred with many of the report's recommendations, but did not state with which recommendations it did not concur. ODNI officials stated in August 2019 that Trusted Workforce 2.0 is specifically developing timeliness goals which are achievable and based on empirical evidence. We will continue to follow-up on the status of this recommendation.

Recommendation: The Director of National Intelligence, in his capacity as Security Executive Agent, and in coordination with the other Security, Suitability, and Credentialing Performance Accountability Council Principals--the Deputy Director for Management of OMB in his capacity as Chair of the PAC, the Director of OPM, and the Under Secretary of Defense for Intelligence--should develop a government-wide plan, including goals and interim milestones, to meet those timeliness objectives for initial personnel security clearance investigations and adjudications. (Recommendation 3)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI stated that it non-concurred with many of the report's recommendations, but did not state with which recommendations it did not concur. In its August 2019 response on the status of this recommendation, ODNI officials stated that the transfer of background investigations from NBIB to DOD will provide an opportunity for the Executive Agents to reassess and address investigative timeliness issues and strengthen management of sensitive information. Moreover, they stated that Trusted Workforce 2.0 will give them the ability to significantly reduce the timelines required to deliver a Secret and Top Secret clearance. We will continue to follow-up on the status of this recommendation.

Recommendation: The Director of National Intelligence should develop a plan for monitoring continuous evaluation performance, to include assessing continuous evaluation at various phases of implementation. (Recommendation 3)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI generally concurred with this recommendation. As of November 2019, ODNI has provided information that may allow us to close this recommendation. We are currently evaluating that information and will update this recommendation once that evaluation is complete.

Recommendation: The Director of National Intelligence should develop performance measures for continuous evaluation that agencies must track and determine a process and schedule for agencies to regularly report those measures to ODNI. At minimum, these performance measures should be clear, quantifiable, objective, and linked to measurable goals. (Recommendation 4)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI generally concurred with this recommendation. As of November 2019, ODNI provided information that may allow us to close this recommendation. We are currently evaluating this information and once that evaluation is complete, we will update the status.

Recommendation: The Director of National Intelligence should, in coordination with the Deputy Director for Management of the Office of Management and Budget in the capacity as Chair of the Security, Suitability, and Credentialing Performance Accountability Council, conduct an evidence-based review of the timeliness goal of 195 days for completing the fastest 90 percent of periodic reinvestigations and the associated goals for the different phases of periodic reinvestigations, and adjust the goal if appropriate, taking into consideration available resources, the additional workload of continuous evaluation, and the risks associated with individuals retaining access to classified information without determining their continued eligibility. (Recommendation 5)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI generally concurred with this recommendation. As of November 2019, ODNI stated that with the advent of Trusted Workforce 2.0, discussions are being held about timeliness goals and the periodic reinvestigation model writ large. Once we confirm what actions have been taken, we will update the status of this recommendation.

Recommendation: The Director of National Intelligence should, once ODNI has further defined the continuous evaluation program, to include issuing a Security Executive Agent Directive and developing an implementation plan, in coordination with the Deputy Director for Management of the Office of Management and Budget in the capacity as Chair of the Security, Suitability, and Credentialing Performance Accountability Council, assess the potential effects of continuous evaluation on agency resources and develop a plan, in consultation with implementing agencies, to address those effects, such as modifying the scope of periodic reinvestigations, changing the frequency of periodic reinvestigations, or replacing periodic reinvestigations for certain clearance holders. (Recommendation 6)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI generally concurred with this recommendation. As of November 2019, ODNI provided information that may allow us to close this recommendation. We are currently evaluating that information and once that evaluation is complete, we will update the status of this recommendation.

Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To enhance its investigative capabilities, BSEE should establish a capability to review investigation policy and collect and analyze incidents to identify trends in safety and environmental hazards.

Agency: Department of the Interior
Status: Open

Comments: According to BSEE documentation, the Safety and Incident Investigations Division (SIID) is working closely with the Office of Policy and Analysis and the Records, Delegations, and Directives Team to implement the requirements specified in the BSEE Directives System Manual Chapter and to convert a number of Bureau Interim Directives into Bureau Manual Chapters. In May 2018, BSEE provided the results of an internal control review it had conducted to assess compliance with the tiering process outlined in the National Investigations Handbook. In particular, the Internal Control Review recommended that BSEE (1) continue revision of its National Investigations Handbook, (2) evaluate investigation tier designation, and (3) develop additional investigative training. In July 2019, BSEE provided documentation that it had converted four Bureau Interim Directives into Bureau Manual Chapters and that, in response to the Internal Control Review, it had (1) revised its National Investigations Handbook, (2) evaluated investigative tier designation, and (3) implemented additional training. As of August 2020, BSEE leadership and SIID personnel are considering changes to improve the quality and consistency of its investigative tier designation with a planned completion date of December 31, 2020.

Recommendation: To enhance its ability to effectively oversee offshore oil and gas development, the Secretary of the Interior should direct the Director of the Bureau of Safety and Environmental Enforcement to continue to implement its restructuring effort. To enhance its environmental compliance capabilities, BSEE should develop a plan to address documented environmental oversight staffing needs.

Agency: Department of the Interior
Status: Open

Comments: According to BSEE documentation, the BSEE Director has ordered an assessment. In the meantime, inspectors are being trained to assist with environmental oversight responsibilities as appropriate. BSEE informed us during the first quarter of fiscal year 2018 that it expected to develop a plan to address documented environmental oversight staffing needs by 2020. Officials said that the timeline was pushed out to allow time to finish policy and complete a work risk assessment. In September 2019, BSEE indicated that it had identified three corrective actions based on its evaluation of risks associated with the organizational structure of the bureau's environmental compliance program that will address this recommendation. As of August 2020, BSEE anticipates implementing these actions by the end of fiscal year 2021.

Recommendation: To help ensure that agencies' policies and oversight are fully consistent with The Attorney General's Guidelines Regarding the Use of Confidential Informants, the Assistant Secretary of ICE and the Commandant of USCG should update their respective agencies' informant policies and corresponding monitoring processes to explicitly address the Guidelines' provisions on oversight of informants' illegal activities.

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

Comments: In December 2016, ICE issued a memo regarding changes to its policies for the registration and suitability of confidential informants. The memo included updated forms to oversee those aspects of confidential informant oversight. In April 2017, ICE officials informed GAO that the agency planned for a working group to update the Informants Handbook and the Undercover Operations Handbook. As of October 2018, ICE reported that officials had made draft updates to the handbooks and that these updates were undergoing review. In June 2019, ICE reported that the updates were expected to be finalized in July 2019. The handbook updates had not been finalized as of February 2020, and, at that time, ICE officials reported that the handbooks were undergoing additional updates related to a separate effort unrelated to GAO's recommendation. As of June 2020, ICE officials did not have an estimated completion date for finalizing revisions to the handbooks. When the updated handbooks are available for GAO's review, we will assess the extent to which they address our recommendation.

Recommendation: In order to strengthen DEA's communication with and guidance for registrants and associations representing registrants, as well as supporting the Office of Diversion Control's mission of preventing diversion while ensuring an adequate and uninterrupted supply of controlled substances for legitimate medical needs, the Deputy Assistant Administrator for the Office of Diversion Control should solicit input from distributors, or associations representing distributors, and develop additional guidance for distributors regarding their roles and responsibilities for suspicious orders monitoring and reporting.

Agency: Department of Justice: Drug Enforcement Administration: Operations Division: Office of Diversion Control: Deputy Assistant Administrator for the Office of Diversion Control
Status: Open
Priority recommendation

Comments: In September 2019, DEA told us that the agency had refocused its efforts on revising draft regulations in line with the SUPPORT for Patients and Communities Act, and that the revised draft was undergoing internal DEA and Department of Justice review. The agency noted that it expected the rule to codify existing legal obligations related to due diligence and suspicious order reporting and provide additional guidance regarding the nature and timing of the suspicious order reporting requirement, but also indicated that it was not possible to be certain of the precise nature of the draft rule. While DEA has reported taking some actions to address this recommendation, as noted above, until the regulations are finalized we cannot determine if these changes will fully address the recommendation. We will continue to monitor DEA's progress in addressing our recommendation.

Recommendation: In order to strengthen DEA's communication with and guidance for registrants and associations representing registrants, as well as supporting the Office of Diversion Control's mission of preventing diversion while ensuring an adequate and uninterrupted supply of controlled substances for legitimate medical needs, the Deputy Assistant Administrator for the Office of Diversion Control should solicit input from pharmacists, or associations representing pharmacies and pharmacists, about updates and additions needed to existing guidance for pharmacists, and revise or issue guidance accordingly.

Agency: Department of Justice: Drug Enforcement Administration: Operations Division: Office of Diversion Control: Deputy Assistant Administrator for the Office of Diversion Control
Status: Open

Comments: In April 2016, DEA reported that it had worked with the National Association of Boards of Pharmacy regarding issues raised during stakeholder discussions, which resulted in a March 2015 consensus document published by stakeholders entitled "Stakeholders' Challenges and Red Flag Warning Signs Related to Prescribing and Dispensing Controlled Substances." Additionally, in December 2016 DEA also described other ways in which the agency had been working with pharmacists or associations representing pharmacists to discuss their responsibilities, such as during regional one-day Pharmacy Diversion Awareness Conferences, and quarterly meetings with two pharmacy associations. In February 2018, DEA reported that following input from pharmacists, and representatives of pharmacies and pharmacists, it had revised its existing Pharmacist's Manual. DEA reported in September 2019 that the manual was currently in the final approval process for publication, and that when published, DEA would provide the manual to GAO. Until the updated Pharmacist's Manual is published and we have a chance to review the revisions, we cannot fully assess DEA's actions in this area. Therefore, the recommendation remains open.

Recommendation: To systematically gauge the extent to which deficiencies identified by individual AIBs may be occurring throughout VHA; and to maximize opportunities for sharing information across VHA to improve its overall operations, the Secretary of Veterans Affairs should direct the Under Secretary for Health to establish a process to collect and analyze aggregate data from AIB investigations, including the number of investigations conducted, the types of matters investigated, whether the matters were substantiated, and systemic deficiencies identified.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and noted that it would explore any new processes for collecting and analyzing aggregate data from AIB investigations. In September 2015, VA reported that VHA had established a workgroup to review this recommendation and also had created a database to collect and analyze aggregate data from AIB investigations into senior executive service (SES) employees. Based on the results of an informal survey as well as its analysis of AIB data for SES employees, VA stated that central office oversight of the AIB process is not needed and that several systems already in place capture data on system-wide risks (e.g., sexual assault reporting, Issue Briefs, and National Center for Patient Safety Patient Safety Information System Program). In December 2016, VA reported that it convened another workgroup in September 2016 to re-examine this recommendation. That workgroup ultimately determined that oversight of AIBs at the national level continues to not be warranted. In April 2018, VA reported that it does not intend to take any further action in response to this recommendation, and it reaffirmed this position in March 2020.

Recommendation: To systematically gauge the extent to which deficiencies identified by individual AIBs may be occurring throughout VHA; and to maximize opportunities for sharing information across VHA to improve its overall operations, the Secretary of Veterans Affairs should direct the Under Secretary for Health to establish a process for sharing information about systemic changes, including policies and procedures implemented in response to the results of AIB investigations, which may have broader applicability throughout VHA.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and noted that it would explore any new processes for collecting and analyzing aggregate data from AIB investigations. In September 2015, VA reported that it had established a working group to review this recommendation. In addition, VA also had created a database to collect and analyze aggregate data from AIB investigations into senior executive service (SES) employees to identify trends and address deficiencies. Based on an informal survey of its working group and its analysis of AIB data for SES employees, VA stated that VISNs currently provide adequate oversight of the AIB process and notify VA central office when appropriate and that a comprehensive review of its AIB data for SES employees identified no system-wide issues. Ultimately, VA stated that it could not justify the resources needed to implement this recommendation. In April 2018, VA reported that it does not intend to take any further action in response to this recommendation, and it reaffirmed this position in March 2020.