Recommendation: The Commandant of the Coast Guard should ensure that the Deputy Commandant for Mission Support assesses and addresses the causes of data errors and inconsistent entries in MISLE as identified by program offices and MISLE users, including reviewing MISLE training and data validation processes. (Recommendation 1)

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

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

Recommendation: The Commandant of the Coast Guard should ensure that the Deputy Commandant for Mission Support uses the results of its 2019 Standardization Team assessment of command centers to develop a plan for improving the consistency and accuracy of MISLE data identified in its report. (Recommendation 2)

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

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

Recommendation: The Commandant of the Coast Guard should ensure that the Deputy Commandant for Mission Support and the Deputy Commandant for Operations use the processes outlined in the SELC to identify needed enhancements across the MISLE system by developing an updated mission needs statement. (Recommendation 3)

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

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

Recommendation: The Commandant of the Coast Guard should ensure that the Deputy Commandant for Mission Support and the Deputy Commandant for Operations use the processes outlined in the SELC to identify and analyze alternatives, and objectively select the preferred solution for MISLE to meet approved mission needs. (Recommendation 4)

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

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

Recommendation: The Assistant Secretary for the Office for Civil Rights should revise its CRDC business rule to require that every school district reporting zeros, regardless of district size or numbers of students with disabilities, affirm the zeros are correct during the CRDC data submission process. (Recommendation 1)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and school districts that report very low numbers of incidents and set data-driven thresholds to detect such incidents. (Recommendation 2)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and schools districts that report very high number of incidents and set data-driven thresholds to detect such incidents. (Recommendation 3)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should apply the CRDC business rule targeting illogical data at the school level to all schools, regardless of the number of incidents reported. (Recommendation 4)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should identify the factors that cause underreporting and misreporting of restraint and seclusion and take steps to help school districts overcome these issues. (Recommendation 5)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should further refine and clarify federal restraint and seclusion definitions and take steps to ensure that this information is conveyed to school districts. This could include providing common classroom scenarios that highlight the differences between a restraint and an escort, and a time out and a seclusion. (Recommendation 6)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Director of USCIS should ensure that, in addition to USCIS's basic asylum officer training, all asylum offices provide pre-departure training on the credible and reasonable fear processes before their officers begin screening cases at the family residential centers. (Recommendation 1)

Agency: Department of Homeland Security: United States Citizenship and Immigration Services
Status: Open

Comments: In commenting on a draft of our report, DHS reported that USCIS plans to develop a standardized pre-departure training and provide this training to all detailees prior to deployment to the family residential centers. DHS estimated that these actions would be completed by September 2020. As of August 2020, USCIS told GAO that the number of noncitizens processed under expedited removal has decreased dramatically as a result of Coronavirus Disease 2019. Therefore, details to the Family Residential Centers have largely been paused. USCIS noted that the Asylum Division is reviewing the credible fear and reasonable fear training requirements; working on an enhanced training module; and, developing a standardized pre-departure training by December 31, 2020. USCIS plans to provide the training to all detailees prior to deployment to the Family Residential Centers during calendar year 2021, should the details resume. Providing pre-departure training, in addition to USCIS's basic training for new asylum officers, would help USCIS ensure that officers from all asylum offices are conducting efficient and effective fear screenings of families.

Recommendation: The Director of USCIS should ensure asylum officers systematically record in USCIS's automated case management system if individuals receive credible fear determinations as principal applicants, dependents, or in the interest of family unity, pursuant to regulation or USCIS policy. (Recommendation 3)

Agency: Department of Homeland Security: United States Citizenship and Immigration Services
Status: Open

Comments: In commenting on a draft of our report, DHS reported that USCIS planned to explore ways to modify its case management system so that asylum officers can record whether an individual received a positive credible fear determination as a principal applicant, dependent, or in the interest of family unity. USCIS plans to make any appropriate changes to its case management system and train asylum officers on these changes by December 2020. As of August 2020, USCIS reported that the agency remains on track to complete this work as planned, provided staffing is not affected by USCIS budget issues. Having complete data in its case management system on all outcomes of credible fear screenings at family residential centers would better position USCIS to report on the scope of either the agency's policy for family members who are treated as dependents, pursuant to regulation, or USCIS's use of discretion in the interest of family unity.

Recommendation: The Director of USCIS should collect and analyze additional information on case delays, including specific reasons for delays and how long they last, that asylum officers may face when screening credible and reasonable fear cases. (Recommendation 4)

Agency: Department of Homeland Security: United States Citizenship and Immigration Services
Status: Open

Comments: In commenting on a draft of our report, DHS reported that USCIS will explore ways to collect additional information on credible and reasonable fear case delays in its case management system. USCIS plans to modify the system, as appropriate, to instruct users on the changes, and begin collecting and analyzing the information by December 31, 2020. As of August 2020, USCIS reported that the agency remains on track to accomplish this work by the end of calendar year 2020, provided staffing is not adversely affected by the on-going COVID-19 pandemic and USCIS budget issues. Collecting additional information in its automated case management system on case delays would provide USCIS with more readily available information and analyzing such data could help USCIS identify case delay reasons relevant in the current environment for officers conducting fear screenings and better position USCIS to mitigate the reasons for the delays and improve efficiency in case processing.

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

Agency: Department of Agriculture
Status: Open

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

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

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

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

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

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

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

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

Agency: Department of Agriculture
Status: Open

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

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

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

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

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

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

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

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

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

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

Recommendation: The Secretary of Homeland Security should establish and implement a time frame for completing its drafting of the AED regulations and submitting them to the Office of Management and Budget for further review. (Recommendation 1)

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

Comments: According to DHS, the department was still reviewing its AED regulations in March 2020. Thus, DHS had not completed drafting the regulations or submitted them to the Office of Management and Budget for further review. DHS aims to publish the regulations by July 2020.

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

Agency: Department of the Treasury
Status: Open

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

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

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Secretary of VA should direct the Under Secretary for Health and the Assistant Secretary for Information and Technology/Chief Information Officer to develop and implement a methodology for reliably identifying and reporting the total costs of VistA. The methodology should include steps to identify the definition of VistA and what is to be included in its sustainment activities, as well as ensure that comprehensive costs are corroborated by reliable data. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: The Department of Veterans Affairs (VA) generally agreed with our conclusions and concurred with our recommendation. In a January 2020 update, the department described steps it planned to take to address the recommendation including establishing a team of experts to formulate a comprehensive taxonomy for VistA and all of its components, identifying authoritative and reliable data sources to assign costs to those components, and developing a methodology for ongoing cost tracking and reporting. The department expects these steps to be implemented by September 30, 2020. We will continue to monitor the department's progress to address this recommendation.

Recommendation: The Assistant Secretary for the Office for Civil Rights should immediately remind and clarify for all school districts that they are to only report zero incidents of restraint and seclusion when there are none and that they are to leave cells blank to indicate when data are not collected or incomplete. The Assistant Secretary should also ensure that instructions for when to record zeros and when to leave cells blank are prominently displayed and readily available to districts as they complete the CRDC. (Recommendation 1)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: The Department of Education agreed with this recommendation, but in its initial comments said that it was too late to send such a reminder for the 2017-18 data collection because 94 percent of districts had already submitted their data. Education agreed to feature the instructions more prominently on the website and consider other changes, such as targeted communications and changes in the placement of the instructions for the 2019-20 collection. However, in August 2019 Education emailed districts that had reported zero incidents for the 2017-18 school year and told them to review their data and submit corrections if necessary. It also sent separate emails to all districts that clarified and reminded districts when to report zero and when to leave cells blank. For the next CRDC survey, covering the 2019-20 school year, Education said that it was proposing changes to the survey, including featuring instructions and technical assistance more prominently on the online form. We will continue to monitor Education's efforts to implement this recommendation.

Recommendation: The Assistant Secretary for the Office for Civil Rights should monitor compliance with its action plan requirement, and ensure plans are submitted and address all missing data. (Recommendation 3)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: The Department of Education agreed with this recommendation. Education stated that it had taken steps to more closely scrutinize action plans for the 2017-18 data collection, including directly communicating with districts about their action plans and scheduling calls with any district that requests similar or repetitious action plans over the course of two or more collections. In December 2019, Education stated that for future collections, it would contact each district with an approved action plan before the start of each new collection and reconfirm that the district will take the needed steps to collect and report the data. Moreover, Education is studying ways to augment the online submission system to send automated reminders regarding data elements covered by action plans. We will continue to monitor Education's efforts to implement this recommendation.

Recommendation: The Assistant Secretary for the Office for Civil Rights should prominently disclose for past collections the potential problems with using restraint and seclusion data given the known misreporting issues, such as those detailed in this report involving 9 of the nation's large public school districts. (Recommendation 4)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: The Department of Education initially disagreed with this recommendation, but subsequently said that for the 2015-16 data collection, it would amend the data notes to ensure the public is aware of potential changes by prominently displaying the data notes and clearly delineating the data flaws on its website. We will continue to monitor Education's efforts to implement this recommendation.

Recommendation: The Administrator of GSA should take steps to reconcile G-REX and the Federal Real Property Profile to the extent practical. (Recommendation 1)

Agency: General Services Administration
Status: Open

Comments: GSA is taking steps to implement this recommendation. GSA staff summarized the agency's approach to addressing the recommendation in a January 2020 meeting. GAO agreed to check progress with GSA in the summer of 2020.

Recommendation: The Administrator of GSA should develop a process for assessing at regular intervals, such as annually, agencies' policies and procedures for managing their delegated leasing activities. (Recommendation 2)

Agency: General Services Administration
Status: Open

Comments: GSA is taking steps to implement this recommendation. GSA staff summarized the agency's approach to addressing the recommendation in a January 2020 meeting. GAO agreed to check progress with GSA in the summer of 2020.

Recommendation: The Administrator of GSA should develop a process that would allow GSA to track agencies' progress in meeting GSA management goals, such as cost effective lease rates, and avoiding holdovers. (Recommendation 3)

Agency: General Services Administration
Status: Open

Comments: GSA is taking steps to implement this recommendation. GSA staff summarized the agency's approach to addressing the recommendation in a January 2020 meeting. GAO agreed to check progress with GSA in the summer of 2020.

Recommendation: The Administrator of GSA should develop a systematic, risk-based process for monitoring a selection of submitted post award documents. (Recommendation 4)

Agency: General Services Administration
Status: Open

Comments: GSA is taking steps to implement this recommendation. GSA staff summarized the agency's approach to addressing the recommendation in a January 2020 meeting. GAO agreed to check progress with GSA in the summer of 2020.

Recommendation: The Director of OMB should clarify and document OMB's procedure for changing official data definition standards for DATA Act reporting, for example, by explicitly describing how change procedures developed for other government-wide initiatives apply to DATA Act definition standards in a public source of guidance or information. (Recommendation 1)

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

Comments: OMB has taken steps to restructure the federal data ecosystem, including issuing government-wide guidance covering all federal data and creating a Business Standards Council. However, given the complexity of recent changes, OMB needs to explicitly and publicly describe how those changes-developed in the context of other government-wide initiatives-apply to DATA Act data element definitions.

Recommendation: The Director of OMB should ensure that the June 2018 policy changes regarding DATA Act data definition standards are clearly identified and explained in the official repository or another authoritative public source of DATA Act standards and guidance, such as by including a revision history along with the current version of the definitions. (Recommendation 2)

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

Comments: In January 2020, OMB staff cited its Federal Spending Transparency Data Standards website and specifically notations on that site regarding the dates of revisions made to those standards as being responsive to this recommendation. However, the specific notations cited by OMB only show changes made back in 2015 and do not reflect nor explain some of the more recent revisions that led to GAO making this recommendation.

Recommendation: The Secretary of Homeland Security should develop and implement a process to systematically review the reliability of the data used in its Border Security Metrics Report and comprehensively identify any limitations with the data and methodologies that underlie its metrics. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with the recommendation and in a May 2020 update stated that it plans to address this recommendation in its FY2019 Border Security Metrics Report scheduled to be issued in the summer of 2020. We will continue to monitor DHS's ongoing efforts to do so.

Recommendation: The Secretary of Homeland Security should ensure the communication of the limitations of the metrics identified through the systematic review in the department's annual Border Security Metrics Report. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: In its comment letter, DHS concurred with the recommendation and requested that we consider it closed as implemented because the department already detailed some of the limitations in its fiscal year 2017 report, and plans to continue to identify known limitations and the progress made to mitigate previously identified limitations in future reports. As discussed in the report, we agree that DHS identified and disclosed limitations for some metrics in its fiscal year 2017 Border Security Metrics Report; however, we identified at least one additional limitation for 21 of the 35 metrics on which DHS reported that DHS did not disclose or about which it could have been more transparent. To address the intent of this recommendation, once DHS has implemented a process to systematically review the reliability of the data used in its report and comprehensively identified related limitations, it should disclose those limitations in its annual Border Security Metrics Report. In a May 2020 update, DHS stated that it plans to address this recommendation in its FY2019 Border Security Metrics Report scheduled to be issued in the summer of 2020. We will continue to monitor DHS's ongoing efforts to do so.

Recommendation: The Under Secretary for the Office of Strategy, Policy, and Plans should include the results of sensitivity analyses to key assumptions in its statistical models of unlawful entry estimates in its annual Border Security Metrics Report. (Recommendation 3)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with the recommendation and in a May 2020 update stated that it plans to address this recommendation in its FY2019 Border Security Metrics Report scheduled to be issued in the summer of 2020. We will continue to monitor DHS's ongoing efforts to do so.

Recommendation: The Under Secretary for the Office of Strategy, Policy, and Plans should include measures of statistical uncertainty for all metrics based on estimates derived from statistical models in its annual Border Security Metrics Report. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with the recommendation and in a May 2020 update stated that it plans to address this recommendation in its FY2019 Border Security Metrics Report scheduled to be issued in the summer of 2020. We will continue to monitor DHS's ongoing efforts to do so.

Recommendation: The Secretary of the Treasury should fully comply with OMB's requirements by providing metadata in a single location that are easy to find on the USAspending.gov website. (Recommendation 3)

Agency: Department of the Treasury
Status: Open

Comments: Treasury agreed with the recommendation. As of September 2020, metadata are not available on USAspending.gov.

Recommendation: The Secretary of the Army should require monitoring of its processes used for recording all required real property information--to include evaluating on an ongoing basis whether or to what extent these activities are being carried out--and remediating any identified deficiencies. (Recommendation 1)

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

Comments: The Army concurred with this recommendation. As of February 2020, DOD officials told us that the Army has required monitoring of its processes used for recording all real property information. Specifically, the Army developed a 5-year plan to address the recommendations to improve data quality and accountability in conjunction with the ongoing DOD financial statement audit. The plan reportedly requires measuring results through directed physical inspections and record updates, using a single, standardized Accountable Property System of Record (APSR) for all assets. DOD officials also told us that the Army developed an automated validation and second-person verification to comply with the requirements and business rules of the DOD Real Property Information Model (RPIM), and that it continue to use OSD's validation and verification tool when providing annual data inputs to OSD's Real Property Assets Database, with any feedback to be addressed at senior Army levels. However, DOD officials did not provide any documentation that these requirements have been established. Once we receive that documentation, we will review it to assess the extent to which it meets the intent of our recommendation.

Recommendation: The Secretary of the Navy should require monitoring of Navy and Marine Corps processes used for recording all required real property information--to include evaluating on an ongoing basis whether or to what extent these activities are being carried out--and remediating any identified deficiencies. (Recommendation 2)

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

Comments: The Navy concurred with this recommendation. As of February 2020, DOD officials stated that the Navy required monitoring of its processes used for recording real property information. Specifically, the Navy established a requirement for a 100% inventory check to ensure existence and completeness of its real property information. As part of DOD larger effort to improve its financial management through the Financial Improvement and Audit Readiness (FIAR) guidance, DOD officials also told us that the Navy plans to implement the existence and completeness results provided by an independent Public Accounting Firm. Further, it will continue to use OSD's validation and verification tool when providing annual data inputs to OSD's Real Property Assets Database, with any feedback to be addressed at senior Navy levels. However, DOD officials did not provide any documentation that these requirements had been put in place. Once we receive that documentation, we will review it to assess the extent to which it meets the intent of our recommendation.

Recommendation: The Secretary of the Air Force should require monitoring of its processes used for recording all required real property information--to include evaluating on an ongoing basis whether or to what extent these activities are being carried out--and remediating any identified deficiencies. (Recommendation 3)

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

Comments: The Air Force concurred with this recommendation. As of February 2020, DOD officials told us that the Air Force has required monitoring of its processes for recording all required real property information. For example, the Air Force plans to establish a Data Quality Program (DQP) within the Air Force Civil Engineer Center Information Technology Functional Management Office to incorporate requirements for improving accuracy of its asset information in its Accountable Property System of Record (APSR). The Air Force also plans to revise its instruction AFI 32-9005 to define responsibility for the accuracy of data at the lowest level. Further, it plans to require use of OSD's validation and verification tool to identify and correct inaccuracies when providing annual data inputs to OSD's Real Property Assets Database, with any feedback to be addressed at senior Air Force levels. However, DOD officials did not provide any documentation that these requirements had yet been put in place. We await documentation of these requirements and will review them, once received, to assess the extent to which they meet the intent of our recommendation.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense for Acquisition and Sustainment, in collaboration with the military services, defines and documents which data elements within the RPAD submissions are most significant for decision-making. (Recommendation 4)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation to define and document which data elements within its Real Property Assets Database (RPAD) submissions are most significant for decision-making. As of February 2020, DOD officials told us they will conduct a review of all data elements in its Real Property Assets Database, including compiling list of all data elements actively being used by data consumers. DOD also plans to divide required data elements into blocks to begin strenuous monitoring for accuracy. DOD's estimated completion date for these actions is September 2023. We will continue to monitor the completion of DOD's planned actions.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense for Acquisition and Sustainment, in collaboration with the military services, coordinates on corrective action plans to remediate discrepancies in significant data elements in its real property data system that are identified by OSD's verification and validation tool. (Recommendation 5)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation to coordinate on corrective action plans to remediate discrepancies in significant data elements in its real property data system that are identified by OSD's verification and validation tool. As of February 2020, DOD officials told us they plan to establish a senior leader Functional Governance Board to monitor accuracy compliance. DOD also plans to establish quarterly progress reports to be posted on the Data Analytics Integration Support (DAIS) application for constant monitoring by all users. DOD's estimated completion date for these actions is September 2022. We will continue to monitor the completion of DOD's planned actions.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense for Acquisition and Sustainment, in collaboration with the military services, develops a strategy that identifies and addresses risks to data quality and information accessibility. At a minimum, this strategy should establish time frames and performance metrics for addressing risks related to (1) unfilled real property positions, (2) a lack of a department-wide approach to improving its data, and (3) implementation of OSD's expanded data platform. (Recommendation 6)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD partially concurred with this recommendation and stated that it plans to collaborate with the military services on separate service strategies that reflect each military service's operating environment. As of February 2020, DOD officials told us they plan to stabilize their Data Analytics Integration Support (DAIS) platform to improve data inventory by ensuring successful network connectivity for all military service users. DOD will update policy guidance to formalize the use of the DAIS platform for inventory submission by the military services. DOD also will develop and formalize in policy benchmarks and metrics to monitor data accuracy. DOD's estimated completion date for these actions is September 2023. We will continue to monitor the completion of DOD's planned actions.

Recommendation: The Administrator of CMS should provide states with more information on how to fulfill the requirement for independent encounter data audits, including information on the required audit scope and methodology, and what should be described in the resulting report. (Recommendation 1)

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

Comments: HHS agreed with our recommendation, noting that CMS would provide states with additional information on how to fulfill the requirement for independent encounter data audits. HHS also noted in January 2019 that CMS was developing voluntary guidance that will include information on best practices for validating encounter data. To implement this recommendation, the Administrator of CMS should inform states of the required audit scope and methodology as well as the resulting report. As of January 2020, HHS officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: The Administrator of CMS should provide states information on the required content of the annual assessment of encounter data reporting. (Recommendation 2)

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

Comments: HHS agreed with our recommendation, noting that CMS would provide states further information on the required content of the annual assessment. In January 2019, HHS noted that CMS continues to develop guidance to states on how to fulfill the annual assessment requirement. As of January 2020, HHS officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: The Administrator of CMS should provide states with information on the circumstances under which CMS would defer or disallow matching funds in response to noncompliant encounter data submissions. (Recommendation 3)

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

Comments: HHS neither agreed nor disagreed with our recommendation and noted steps it has already taken to remind states of their obligation to submit timely, quality encounter data, and prioritize data quality. In January 2019, HHS identified a possible step CMS could take in the event it finds deficiencies in states' encounter data reporting that cannot be resolved through informal monitoring and discussions with state Medicaid agencies. In particular, HHS noted that CMS would issue guidance on the parameters by which the agency would impose financial penalties on states for noncompliant encounter data submissions, if necessary. In February 2020, CMS officials told us that they continue to monitor state encounter data submissions and would issue guidance to states if they identify deficiencies in the data that cannot be resolved through informal monitoring and disccussions with state Medicaid agencies. To implement this recommendation, the Administrator of CMS should provide states with this information. We will update the status of this recommendation when we receive additional information.

Recommendation: Congress should consider designating an agency to regularly collect and maintain specified cost-related data from credit allocating agencies and periodically assess and report on LIHTC project development costs. (Matter for Congressional Consideration 1)

Agency: Congress
Status: Open

Comments: As of August 2020, Congress had not designated an agency to regularly collect and maintain data on LIHTC project development costs.

Recommendation: IRS's Associate Chief Counsel, in consultation with Treasury's Assistant Secretary for Tax Policy, should require general contractor cost certifications for LIHTC projects to verify consistency with the developer cost certification. (Recommendation 1)

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

Comments: IRS disagreed with the recommendation and had not taken action to implement it as of August 2020. We maintain that requiring general contractor cost certifications would help address a known fraud risk.

Recommendation: To help allocating agencies analyze development cost trends and drivers and make comparisons to other agencies, IRS's Commissioner of the Small Business/Self-Employed Division should encourage allocating agencies and other LIHTC stakeholders to collaborate on the development of more standardized cost data, considering information in this report about variation in data elements, definitions, and formats. (Recommendation 2)

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

Comments: IRS disagreed with the recommendation and had not taken action to implement it as of August 2020. We maintain that greater standardization of LIHTC cost data would facilitate analysis of cost drivers and cost-management practices.

Recommendation: IRS's Associate Chief Counsel, in consultation with Treasury's Assistant Secretary for Tax Policy, should communicate to credit allocating agencies how to collect information on and review LIHTC syndication expenses, including upper-tier partnership expenses. (Recommendation 3)

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

Comments: IRS disagreed with the recommendation and had not taken action to implement it as of August 2020. We maintain that communicating expectations about the collection and review of syndication expenses would enhance program transparency and allocating agency financial assessments.

Recommendation: The Director of BLM should systematically and comprehensively track the actual costs BLM incurs when reclaiming orphaned wells and the information, including the number of orphaned wells and inactive wells over time, necessary to determine the agency's potential liabilities. (Recommendation 1)

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

Comments: BLM concurred with this recommendation and, in July 2019, the agency developed a new funding code to track the costs incurred when reclaiming orphaned wells and issued written guidance to state and field offices in order to implement the bureau-wide use of the code. Also in July 2019, BLM officials stated that the agency will expand existing reporting capabilities to provide the ability to track orphaned and inactive well records over time. As of September 2020, we are working to confirm what actions BLM has taken to track the number of orphaned and inactive wells over time, and we will provide updated information when we obtain it.

Recommendation: The Director of BLM should develop a resource management plan addressing resources needed for conducting well and bond adequacy reviews and reclaiming orphaned wells. (Recommendation 6)

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

Comments: BLM officials stated that the agency conducts annual work planning processes which facilitates the decisions regarding the allocation of agency resources. In July 2019, BLM included additional language in its annual work plan that underscores the importance and relevance of well and bond adequacy reviews. The agency also developed a new fund code to track the actual reclamation costs incurred from reclaiming orphaned wells. The annual work plan also lists identifying and cataloging orphaned wells as a performance goal and the plan states that BLM is working with state regulatory agencies to plug wells within funding levels and state agreements. However, as of September 2020, absent identification of funds needed to reclaim orphaned wells and where those funds will come from, BLM does not have a plan to reclaim wells that are currently orphaned.

Recommendation: The Director of the Office of Investment and Innovation within SBA should work with participating agencies to implement the Commercialization Benchmark or, if that is not feasible, revise the benchmark so that it can be implemented (Recommendation 2).

Agency: Small Business Administration
Status: Open

Comments: SBA agreed with the recommendation. As of January 2020, SBA officials said they plan to continue working with participating agencies to determine a feasible way to implement the Commercialization Benchmark. According to SBA officials, SBA is leading an interagency Commercialization Working Group with participating agency officials and has implemented a commercialization reporting tool on the SBIR.gov site. Agency officials participating in the interagency working group have identified challenges with a single model for the benchmark and are working to resolve the issues.

Recommendation: The Assistant Administrator for Recovery should develop a detailed workforce plan that documents steps for hiring, training, and retaining key appeals staff. The plan should also address staff transitions resulting from deployments to disasters. (Recommendation 3)

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

Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, to prepare for the potential production of a detailed regional workforce plan, PAAB (Public Assistance Appeals Branch) has been collecting information from the Regions regarding the percentage of time (on a monthly basis) that each Regional appeals analyst has worked on appeals. In August 2018, PAAB shared with the Regions its preliminary analysis of this information and asked the Regions to provide feedback regarding the methods used to analyze this information. PAAB said that they intend to assess first-level appeals' regional inventory and timeliness issues, as well as the work needed to prepare and finalize a detailed regional workforce plan. According to FEMA, PAAB is also analyzing second-level appeal inventory and timeliness, and will continue to monitor second-level appeal timeliness. In April 2020, we met with FEMA to discuss additional information and documentation they sent us involving their analysis of appeal inventories and whether this analysis is part of a larger effort to develop a detailed workforce plan as called for in the recommendation. As a result of this meeting, we received further documentation from FEMA in July 2020, and are in the process of evaluating this to determine whether FEMA has fully addressed this recommendation.

Recommendation: The Assistant Administrator for Recovery should work with Regional Administrators in all 10 regional offices, to establish and use goals and measures for processing first-level PA appeals to monitor performance and report on progress. (Recommendation 4)

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

Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, in July 2018, the Public Assistance Division and PAAB transmitted a survey to the Regions containing questions about how each Region establishes goals for processing first-level appeals and how each Region measures and monitors performance with respect to those goals. Thereafter, the Regions provided survey responses to PAAB. According to FEMA, PAAB has begun analyzing the survey responses for the purpose of enabling FEMA's Associate Administrator for the Office of Response and Recovery and FEMA's Chief of Staff to work with all FEMA Regional Administrators to establish and use goals and measures for processing first-level PA appeals to monitor performance and report on progress. In April 2020, we met with FEMA to discuss additional information and documentation they sent us involving these efforts and their development of performance metrics that reflect best practices for the timely processing, tracking, and reporting of first appeals. As a result of this meeting, we received further documentation from FEMA in July 2020, and are in the process of evaluating this to determine whether FEMA has fully addressed this recommendation.

Recommendation: The Administrator of CMS, in partnership with the states, should take additional steps to expedite the use of T-MSIS data for program oversight. Such steps should include, but are not limited to, efforts to (1) obtain complete information from all states on unreported T-MSISdata elements and their plans to report applicable data elements; (2) identify and share information across states on known T-MSIS datalimitations to improve data comparability; and (3) implement mechanisms, such as the Learning Collaborative, by whichstates can collaborate on an ongoing basis to improve thecompleteness, comparability, and utility of T-MSIS data.(Recommendation 1)

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

Comments: HHS concurred with this recommendation. As of February 2020, CMS has taken steps to improve T-MSIS data quality, but further efforts are needed to expedite the data's use in oversight. With regard to obtaining complete information from all states, CMS released additional guidance in March 2019, on state compliance with T-MSIS requirements. This guidance includes the need to resolve data issues associated with 12 top priority items and missing data elements, both of which are key for using T-MSIS data. Further, CMS identified an additional 11 top priority items, noting it also expected states to resolve data issues with these items. CMS reports that it has helped resolve data issues related to these 23 top priority items by sending states summary data on compliance with associated reporting requirements. CMS has notified states of their compliance status and asked non-compliant states to submit corrective action plans. However, CMS reports that the level of states' T-MSIS data completeness varies and agency state liaisons and technical assistants continue to work individually with states to identify, prioritize, and resolve key missing data elements. With regard to identifying and sharing information, CMS has made some T-MSIS data available for use through five T-MSIS analytical files, which include data on Medicaid and CHIP enrollment, demographics, service utilization, and payments. Further, CMS has created resources to support researchers in their use of these analytical files, including information on the completeness and accuracy of certain data elements. With regard to implementing mechanisms for collaboration across states, additional CMS action is needed. In particular, CMS's efforts to create a mechanism for states to disseminate information about T-MSIS data and its comparability across states remain limited and the agency has not launched its proposed Learning Collaborative to facilitate ongoing feedback and collaboration. While progress has been made, additional actions, such as establishing mechanisms for ongoing feedback and collaboration across states, are needed to consider this recommendation implemented.

Recommendation: The Administrator of CMS should articulate a specific plan and associated time frames for using T-MSIS data for oversight. (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 February 2020, CMS has taken steps to articulate guidance to states, but has not outlined a specific plan and associated time frames for using T-MSIS data for oversight. Until CMS takes these actions, the recommendation remains open.

Recommendation: FERC should regularly assess the overall performance of capacity markets by developing goals for assessing capacity market performance, measuring the performance of capacity markets against these goals, and using performance information to make changes as needed to capacity markets. To do so, FERC should leverage data and information already being collected by FERC, the RTOs, and the independent market monitors. (Recommendation 2)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: As of May 2020, FERC is in the process of taking steps to address this recommendation.

Recommendation: FERC should develop and document an approach to regularly identify, assess, and respond to risks that capacity markets face. (Recommendation 3)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: As of May 2020, FERC is in the process of taking steps to address this recommendation.

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

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

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

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

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

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

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

Recommendation: The Secretary of Commerce should direct the NOAA Administrator to develop a strategy for expanding NOAA's use of the private sector in its hydrographic survey program, as required by law.

Agency: Department of Commerce
Status: Open

Comments: In September 2018, NOAA reported that it had awarded a contract to assess hydrographic surveying needs and had drafted a Memorandum of Agreement to improve coordination with the U.S. Geological Survey on data acquisition and management. NOAA also reported that it planned to identify surveying tasks that could be accomplished using the private sector, and would take steps to improve the funding transfer process so that it could take advantage of Federal Emergency Management Agency and National Transportation Safety Board funds available for certain types of private sector survey activities. NOAA officials stated these tasks would be completed and a final strategy on working with the private sector issued by December 30, 2020.

Recommendation: To help ensure the accuracy of MSPB's reporting on whistleblower appeals received and closed, the Chairman of MSPB should update MSPB's data entry user guide to include additional guidance and procedures to help improve the identification of appropriate whistleblower appeal closing codes to use.

Agency: Merit Systems Protection Board
Status: Open

Comments: MSPB is finalizing finalized expanded guidance and procedures on coding whistleblower data. MSPB is committed to ensuring that procedures are in place for identifying and using appropriate whistleblower codes; however, MSPB is limited by its various legacy applications with regard to the improvements related to data entry that can be implemented at this time. MSPB currently is in the process of designing new core business applications that will incorporate appropriate data quality, integrity, and accountability measures to further improve its data management practices. Until the new case management system is in production in FY 2020 or early FY 2021, MSPB remains committed to utilizing the resources necessary to ensure the accuracy of its reported data. To achieve this objective, experienced attorneys reviewed, validated, and, where necessary, corrected agency whistleblowing data prior to public release in FY 2016, FY 2017, and FY 2018. MSPB is committed to this extra layer of review for FY 2019, and will continue to evaluate how to achieve this objective given other workload and available resources. According to MSPB it expects additional progress on its efforts by July 2020.

Recommendation: To help ensure the accuracy of MSPB's reporting on whistleblower appeals received and closed, the Chairman of MSPB should add a quality check in MSPB's data analysis and reporting process to better identify discrepancies or other anomalies in data queries and the resulting datasets.

Agency: Merit Systems Protection Board
Status: Open

Comments: MSPB stated that it completed drafting the data integrity study mentioned in our previous response, looking at the current processes and integrity of case-related data as a whole throughout the agency. As explained above and highlighted in MSPB's FY 2018 Annual Report, MSPB's initiative to design and configure new core business applications currently is underway, and the findings in the study are integral to incorporating the appropriate data integrity processes, including quality checks and controls, into these new applications. According to MSPB it expects additional progress on its efforts by July 2020.

Recommendation: To support its strategic and open data goals, the Director of OPM should improve the availability of the EHRI payroll data--for example, by preparing the data for analytics, making them available through online tools such as FedScope, and including them among the EHRI data sources on the OPM website and Data.gov.

Agency: Office of Personnel Management
Status: Open
Priority recommendation

Comments: OPM agreed with the recommendation. In December 2018, OPM told us it will establish a plan to make payroll data available through analytical tools such as FedScope no later than the fourth quarter of fiscal year 2019. To fully implement the recommendation, OPM will need to improve the availability of payroll data-either from the existing EHRI system or the new employee digital record-by ensuring the data are prepared and made available for analytics research.

Recommendation: To improve internal controls for data quality, the Director of OPM should consistently monitor system-generated error and edit check reports and ensure that timely action is taken to address identified issues.

Agency: Office of Personnel Management
Status: Open
Priority recommendation

Comments: OPM agreed with the recommendation. In December 2018, OPM reported that it plans to begin follow-up efforts with agencies and shared service providers on payroll data errors and anomalies and to notify data providers of problems. To fully implement the recommendation, OPM will need to follow up with shared services centers and agencies regarding issues identified with the payroll data they submit to EHRI. These steps will help ensure the quality of historical and current payroll data. They will also ensure that system detected errors are resolved and do not compound over time.

Recommendation: To integrate the payroll data into the larger suite of EHRI databases, the Director of OPM should develop a schedule for executing these plans.

Agency: Office of Personnel Management
Status: Open

Comments: OPM concurred with our recommendation, but has not yet developed a plan for integrating payroll into the larger suite of EHRI databases.

Recommendation: To integrate the payroll data into the larger suite of EHRI databases, the Director of OPM should evaluate existing internal control activities and develop new control activities for EHRI payroll data, such as implementing transactional edit checks that leverage the information in the other EHRI datasets.

Agency: Office of Personnel Management
Status: Open

Comments: While OPM concurred with our recommendation, the agency has not evaluated or implemented, for Payroll data, the control activities and edit checks that are currently used to support the reliability of the other EHRI datasets.

Recommendation: To improve the quality of the data published on ForeignAssistance.gov and help ensure consistency in published information, the Secretary of State should, in consultation with the Director of OMB and the USAID Administrator, develop additional guidance that takes into consideration current challenges to updating ForeignAssistance.gov with verified data.

Agency: Department of State
Status: Open
Priority recommendation

Comments: As of May 2020, State had taken some steps to coordinate with OMB and USAID to improve the quality of data reported for ForeignAssistance.gov. Notably, in May 2020, State and USAID submitted a joint report to Congress outlining a plan to consolidate the two federal websites reporting foreign assistance spending--ForeignAssistance.gov (managed by State) and explorer.usaid.gov (managed by USAID). As part of the plan, State and USAID will establish a joint data governance structure to reduce discrepancies in data, bolster the capacity of agencies to submit data, and ensure the accuracy and quality of data. Once the governance structure is finalized, they will send a copy to GAO. GAO will then review this information to assess if it sufficiently addresses GAO's recommendation.

Recommendation: To assist in determining whether to require USPS and PRC to report on delivery performance for rural and non-rural areas, Congress should direct USPS to provide cost estimates related to providing this information.

Agency: Congress
Status: Open

Comments: As of March 2020, Congress has not taken any action to direct USPS to provide cost estimates related to reporting on delivery performance for rural and non-rural areas

Recommendation: To help ensure that the respective DHS and DOD data systems contain sufficiently complete and accurate information to facilitate effective oversight of the personnel security clearance revocation and appeal process, the Secretary of Defense should direct the Under Secretary of Defense for Intelligence to take steps to ensure that data are recorded and updated in the Joint Personnel Adjudication System (JPAS) and the department's new systems, so that the relevant fields are filled.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. As of November 2019, DOD requested to close this recommendation per a closure memo signed by Ms. Nancy Spaulding. We are awaiting further documentation supporting the closure of this recommendation.

Recommendation: To help ensure independence and the efficient use of resources, the Secretary of Defense should direct the DOD General Counsel to first, resolve the disagreement about the legal authority to consolidate the PSABs (Personnel Security Appeals Board) and, in collaboration with the PSABs and the Under Secretary of Defense for Intelligence, address any other obstacles to consolidating DOD's PSABs.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation. DOD agreed with us to review legal or other impediments to consolidation, and stated that the DOD Office of General Counsel will address any unresolved disagreements about legal authority for consolidation of PSABs. DOD further commented that the DOD Office of General Counsel will work closely with the Office of the Under Secretary of Defense for Intelligence to address other issues concerning consolidation of PSABs. However, DOD commented that some DOD components disagreed with PSAB consolidation. Specifically, DOD stated that of the eleven components that provided responses to the draft report, eight concurred or had no issues or comments, while the remaining three components noted that the PSABs should remain at the component level and not be consolidated. As of July 2018, DOD stated that the DOD Office of General Counsel is conducting an ongoing review, with all legal opinions contingent upon a USD(I) funded PERSEREC study to determine the feasibility of PSAB consolidation. USD(I) is coordination with OGC in order to provide the results of the study upon completion. DOD estimates this study will be completed in the third or fourth quarter of Fiscal Year 2019. As of November 2019, DOD stated that the PERSEREC study is still ongoing. GAO will continue to monitor the completion of the study.

Recommendation: To help ensure that all employees within DOD receive the same rights during the revocation process, the Secretary of Defense should direct the Secretary of the Navy to revise Secretary of the Navy Manual M-5510.30 to specify that any information collected by the Navy PSAB from the employee's command will be shared with the employee, who will also be given the opportunity to respond to any such information provided.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. As of November 2019, DOD stated that Navy Instruction 5510.30C and concomitant manual M-5510.30 have been revised and are being coordinated throughout the Department of the Navy at every level--to include the Action Officer level. DOD stated the estimated completion date is the third quarter of FY 2019. We have no updates on whether this instruction and the manual are complete. This recommendation will remain open pending further updates from DOD.

Recommendation: To help ensure independence and the efficient use of resources, and, if the General Counsel determines that there are no legal impediments and that other obstacles to consolidation can be addressed, the Secretary of Defense should direct the Defense Legal Services Agency to take steps to implement the Secretary of Defense's direction to consolidate DOD's PSABs.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation. DOD stated that some DOD components disagreed with PSAB consolidation. Specifically, DOD stated that of the eleven components that provided responses to the draft report, eight concurred or had no issues or comments, while the remaining three components noted that the PSABs should remain at the component level and not be consolidated. One of these three components also commented that the perceived efficiencies from consolidation described in our report should be validated and that all models for consolidation should be evaluated before a decision is made that would consolidate the PSABs. DOD's comments reflect internal disagreement, which corroborates our finding that there is disagreement within DOD on the legal authority, risks, and benefits of consolidating the department's multiple appeals boards. As we also note in our report, the Secretary of Defense has already directed this consolidation. As of November 2019, DOD stated that the Office of General Counsel's determination on the legal impediments to consolidation is contingent upon the results of the PERSEREC study, which will assess the feasibility of PSAB consolidation. The study results will inform the OGC decision. DOD estimates this study will be completed in the third or fourth quarter of Fiscal Year 2019. However, the study has not been released yet. This recommendation will remain open until DOD takes steps to consolidate the PSABs.

Recommendation: To help ensure that all employees within DOD receive the same rights during the revocation process, the Secretary of Defense should direct the Secretary of the Army to revise Army Regulation 380-67 to specify that any information collected by the Army PSAB from the employee's command or by the Army PSAB itself will be shared with the employee, who will also be given the opportunity to respond to any such information provided.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. As of July 2018, DOD stated that the Army updated its PSAB guidance in 2016 to include the GAO-recommended verbiage regarding new information. Similar language will also be incorporated in Army Regulation 380-67, which is currently under revision. DOD estimates the revision will be completed in the fourth quarter of Fiscal Year 2019. As of November 2019, no further updates were provided by DOD. GAO will monitor the status of this regulation and assess whether the revised regulation meets the intent of this recommendation.

Recommendation: To help ensure that all employees are treated fairly and receive the protections established in the executive order, the Secretary of Homeland Security should direct the Commandant, U.S. Coast Guard, to revise the Coast Guard instruction for military personnel to specify that military personnel may be represented by counsel or other representatives at their own expense.

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with our recommendation. As of August 2018, the Commandant of the Coast Guard issued a policy message stating that individuals may have counsel or other representatives present at the service member's own expense. According to a Coast Guard official, this message serves as interim guidance until the personnel security manual can be finalized. Coast Guard officials stated that the manual will be undergoing revision, and is expected to be updated at the end of March 2019 . We are awaiting documentation from the Coast Guard that this manual is complete. This recommendation will remain open until the Coast Guard finalizes the update to its manual in accordance with our recommendation.

Recommendation: To facilitate department-wide review and assessment of the quality of the personnel security clearance revocation process, the DNI should, in consultation with the Secretaries of Defense and Homeland Security, develop performance measures to better enable them to identify and resolve problems, and direct the collection of related revocation and appeals information.

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

Comments: ODNI concurred with our recommendation. As of November 2019, ODNI stated that review proceedings considerations have been a focus of the ongoing Trusted Workforce 2.0 discussions with a view toward whether policy changes were necessary. ODNI further stated that one key to further examination of this issue is to gather metrics which can inform any subsequent adjustment to the current Executive Branch revocation and review proceedings area. They stated that metrics collection has begun with a January 2019 data call which includes the capture of metrics on denials, revocations, and national security adjudications resulting in an adverse adjudication of eligibility for access to classified information or eligibility to hold a sensitive position. Metrics collected is expected to be completed in 2020. When we confirm what data fields are included in the metrics collection and whether this meets the intent of our recommendation, we will provide further updates.

Recommendation: To facilitate coordination between personnel security and human capital offices regarding how a security clearance revocation should affect an employee's employment status, and to help ensure that individuals are treated in a fair and consistent manner, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness, in consultation with the Under Secretary of Defense for Intelligence, to review and revise policy regarding coordination between the personnel security and human capital offices to clarify what information can and should be communicated between human capital and personnel security officials at specified decision points in the revocation process, and when that information should be communicated.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. As of November 2019, DOD stated that USD(I) has formed a working group to develop a new DOD manual that would respond to this recommendation. DOD further stated that this working group has completed the first half of the manual and will finish the initial review by the fourth quarter of FY 2019. Estimated completion date for the manual is the first quarter of FY 2020. This recommendation remains open pending the department's issuance of this manual.

Recommendation: To help ensure that the DNI report to Congress contains accurate data about the number of current DOD military and federal civilian employees eligible to access classified information, the Secretary of Defense should direct the Under Secretary of Defense for Intelligence and the Under Secretary of Defense for Personnel and Readiness to review and analyze the discrepancies in the total number of employees and the number of employees eligible to access classified information, and take immediate steps to address the problems.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. As of August 2018, DOD stated that this recommendation is tied to recommendation 2 regarding updating information in JPAS and DISS. Officials from the Office of the Under Secretary of Defense for Intelligence (USD(I) is facilitating Data Quality Initiatives to identify where gaps may exist and ensure all pertinent data is recorded and updated in JPAS and its successor system, DISS. Officials stated that there is an annual or quarterly service specific personnel center synchronization effort to match the data in JPAS and the personnel centers. Since publication of our report through December 2017, DMDC has conducted 413 DQIs to evaluate and correct data anomalies in JPAS. Further, on a monthly basis, the Office of the Under Secretary of Defense for Intelligence (OUSD(I)), the Defense Manpower Data Center (DMDC), the Office of Personnel Management (OPM), DOD components, and industry participate in a meeting which addresses actions to improve the accuracy of information in JPAS. GAO will monitor fielding of the new system and in the process of validating DOD officials' statements that discrepancies have been substantially resolved. As of November 2019, DOD requested to close this recommendation per a closure memo signed by Ms. Nancy Spaulding. We are awaiting further documentation supporting the closure of this recommendation.

Recommendation: To help ensure that similarly situated individuals are treated consistently, and to facilitate oversight and help ensure the quality of the security clearance revocation process, the DNI should review whether the existing security clearance revocation process is the most efficient and effective approach. In this review, the DNI should consider whether there should be a single personnel security clearance revocation process used across all executive-branch agencies and workforces, with consideration of areas such as the timing of the personal appearance in the revocation process, and the ability to cross-examine witnesses. Further, to the extent that a single process or changes to the existing parallel processes are warranted, the DNI should consider whether there is a need to establish any policies and procedures to facilitate a more consistent process, and recommend as needed any revisions to existing executive orders or other executive-branch guidance.

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

Comments: ODNI concurred with our recommendation. As of November 2019, ODNI stated that there is not currently an ongoing effort to review the security clearance revocation process across all executive branch agencies and workforces. Instead, the Trusted Workforce 2.0 efforts is conducting an end-to-end review of the current security clearance process for the executive branch and ODNI is currently gathering metrics on adverse security actions which can inform any subsequent determination on whether the revocation process requires policy adjustment by the DNI. When we confirm what actions DNI has taken in response to this recommendation, we will provide updated information.

Recommendation: To ensure that MA encounter data are of sufficient quality for their intended purposes, the Administrator of CMS should establish specific plans and time frames for using the data for all intended purposes in addition to risk adjusting payments to MAOs.

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

Comments: HHS generally agreed with this recommendation. Although CMS reports using MA encounter data for purposes other than risk adjustment, as of February 2020, it has not fully developed specific plans and time frames with dates for all uses. CMS reports that it has begun testing the use of MA encounter data for public health purposes, such as identifying beneficiaries with a history of opioid-related overdose and with other conditions, such as cancer and sickle cell. Further, CMS uses MA encounter data to help identify beneficiaries at risk in areas affected by public health emergencies. CMS reports that its Office of the Actuary (OACT) has used MA encounter data to analyze MA beneficiary utilization of certain Part B drugs. Further, OACT reports that it intends to assess other areas where it could use MA encounter data, such as analyses comparing Medicare fee-for-service and MA. As of February 2020, the agency has not developed specific plans and time frames for this and other intended purposes. For example, although CMS intends to use MA encounter data for program integrity purposes, it has not yet developed specific plans and time frames to do so. We will continue to monitor CMS's progress in developing specific plans and time frames with dates for all intended purposes of MA encounter data.

Recommendation: To ensure that MA encounter data are of sufficient quality for their intended purposes, the Administrator of CMS should complete all the steps necessary to validate the data, including performing statistical analyses, reviewing medical records, and providing MAOs with summary reports on CMS's findings, before using the data to risk adjust payments or for other intended purposes.

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

Comments: HHS generally agreed with this recommendation, however, HHS did not commit to completing data validation before using MA encounter data for risk adjustment. As of February 2020, CMS has continued to make progress in examining the completeness and accuracy of MA encounter data, but more work remains to fully validate these data. CMS has developed and is implementing an MA Encounter Data Integrity and Monitoring plan, which includes data analysis, guidance, and monitoring. As part of this plan, CMS has established preliminary performance metrics for MA encounter data completeness and accuracy. CMS is also conducting analyses related to accuracy and completeness, but has not established performance benchmarks for these analyses. While the agency plans to communicate findings from the analyses to Medicare Advantage organizations, it has not yet done so. Finally, CMS has not verified MA Encounter data by reviewing medical records. While these steps are encouraging, without fully validating the completeness and accuracy of MA encounter data, CMS would be unable to confidently use these data for risk adjustment or other program management or policy purposes.

Recommendation: In order to maintain progress in maximizing the efficiency of existing data sources, and to improve the broader efficiency of the federal statistical system and improve communication among agencies and others, the Director of OMB, in consultation with the Chief Statistician, should work with the ICSP, when OMB next updates guidance on agency survey and statistical information collection and dissemination methods, to include additional details on actions agencies can take to meet requirements to identify duplication, to consult with persons outside of the agency, and address other requirements as appropriate.

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

Comments: In March 2020, OMB staff reported that Federal Committee on Statistical Methodology has been developing two new products, featured in the Federal Data Strategy 2020 Action Plan, that they believe will be responsive to this recommendation when completed. They are (1) an update to Statistical Working Paper 22 on statistical disclosure limitation methodology, and (2) guidance on measuring and reporting data quality.

Recommendation: In order to maintain progress in maximizing the efficiency of existing data sources, and to improve the broader efficiency of the federal statistical system and improve communication among agencies and others, the Director of OMB, in consultation with the Chief Statistician, should work with the ICSP to create new methods or enhance existing methods to improve the dissemination of information and resources produced by interagency statistical committees. For example, such enhancements could include increasing the timeliness and availability of information on websites to better capture the full range of products and identify committee priorities.

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

Comments: In March 2020, OMB staff reported that Federal Committee on Statistical Methodology has been developing two new products, featured in the Federal Data Strategy 2020 Action Plan, that they believe will be responsive to this recommendation when completed. They are (1) an update to Statistical Working Paper 22 on statistical disclosure limitation methodology, and (2) guidance on measuring and reporting data quality.

Recommendation: In order to maintain progress in maximizing the efficiency of existing data sources, and to increase the reliability of the information presented on the Reginfo.gov website and in OMB's internal system, the Director of OMB, in consultation with the Chief Statistician, should work with the ICSP to implement quality-control procedures designed to identify and remedy any differences between cost and burden information provided on the website and in the related supporting statement documentation that underlies this information.

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

Comments: OMB staff reported that because it publishes cost and burden information in Federal Register notices, PRA statements, and on RegInfo.gov, the public is able to identify discrepancies and bring them to OMB's attention. We believe that the responsibility to identify these discrepancies should belong to OMB and not the public.