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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

(Recommendation 8).

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation: The 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 Assistant Secretary of DOL's Employment and Training Administration should include detailed information on the methodology used to identify centers for proposed closure in its notices for public comment.

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

Comments: The agency concurred with the purpose and intent of this recommendation, stating that the level of information it included in notices for public comment concerning such matters complied with WIOA requirements and provided a meaningful opportunity for public comment: it did not indicate that it would provide more detailed information in the future. While we acknowledge that DOL is not required to publish its methodology in public notices, we believe that including such information can provide greater transparency in assisting the public and the Congress in understanding the agency's decision-making used to select centers for closure. DOL included detailed information on the methodology used to identify centers for proposed closure in its 2014 and 2016 public notices. As such, we believe ETA should take action to implement this recommendation in the event that the agency proposes Job Corps centers for closure in the future.

Recommendation: The Director of the Bureau of Indian Education should develop a systematic process for identifying JOM contractors and maintaining an accurate and complete list of contractors and other relevant information about contractors, such as the amount of JOM funds they receive and their current points of contact. (Recommendation 1)

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

Comments: Interior concurred with this recommendation. They expect their newly expanded JOM program workforce to develop, publish and implement a comprehensive JOM policy and procedure that includes a systemic process for identifying JOM contractors and maintaining a complete and accurate list of contractors. We will monitor the progress of these efforts.

Recommendation: The Director of the Bureau of Indian Education, in coordination with the Bureau of Indian Affairs as needed, should establish a process to track and monitor the timeliness of JOM disbursements to non-tribal contractors, including identifying a target date for disbursing funds to these contractors. (Recommendation 2)

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

Comments: Interior concurred with this recommendation. The BIE, BIA and other partners will work collaboratively to publish and implement a policy and procedure that accurately tracks and monitors timely disbursement of JOM funds to these contractors. We will monitor the progress of these efforts.

Recommendation: The Director of the Bureau of Indian Education should develop a timeline to assess the usefulness of the information they are collecting from JOM contractors and update JOM information collection forms, including converting them to an electronic format to reduce the burden on contractors to complete them. (Recommendation 3)

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

Comments: Interior concurred with this recommendation. They expect that their newly expanded JOM program workforce will expedite the BIE's review and information collection efforts. We will monitor the progress of these efforts.

Recommendation: The Director of the Bureau of Indian Education should develop and provide training to contractors on administering the JOM program. (Recommendation 4)

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

Comments: Interior concurred with this recommendation. SIE and JOM staff will be tasked with developing a technical assistance framework for contractors and a training plan as part of the wider JOM program policy and task procedures. We will monitor the progress of these efforts.

Recommendation: The Director of the Bureau of Indian Education should clearly define the roles and responsibilities and identify the staff necessary for conducting critical JOM functions, including administering contracts, reviewing the appropriateness of contract types, and overseeing those contractors that are subject to BIE oversight. (Recommendation 5)

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

Comments: Interior concurred with this recommendation. The BIE, BIA and other partners plan to work collaboratively to develop an inter-bureau policy that clearly identifies each agency's roles and responsibilities. They are also developing a data-informed workforce analysis for the JOM program. They will continue to develop and implement a data-informed workforce strategy to identify human capital needs and clearly identifies and assigns critical JOM-related functions among BIE divisions, offices and staff. We will monitor the progress of these efforts.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation: The Secretary of Education should develop an online clearinghouse of sample documents from states and localities who wish to share them, past webinar recordings and their related documents, and links to other relevant resources that all SEAs can access. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education agreed with this recommendation. The agency said that its Office of Elementary and Secondary Education will restructure its entire website to better organize its information, and create a new web page to house all foster care-related information and resources. Additionally, Education said this office will launch a virtual portal through which SEA foster care points of contact may collaborate and share resources. We will consider closing this recommendation when these efforts are complete.

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation: The Secretary of Education should establish timeframes for providing states with additional information on allowable expenditures of funds reserved for pre-employment transition services. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education agreed with this recommendation and stated that it would establish projected timeframes for providing states with additional information on allowable expenditures for the provision of preemployment transition services. Education also stated that it intends to provide states with additional information in at least two forums before the end of calendar year 2018 and to review and analyze previous guidance provided to states on allowable expenditures.

Recommendation: The Secretary of Education should take additional steps to provide states assistance on updating and finalizing their interagency agreements with state educational agencies to include pre-employment transition services. These steps could include, for example, accelerating their efforts to discuss the benefits of finalizing interagency agreements, and reminding states of existing technical assistance resources pertaining to updating and finalizing interagency agreements. (Recommendation 2)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation, in large part, because there is no statutory provision authorizing the agency to identify such states. Nevertheless, Education stated that it is taking some steps as part of its ongoing monitoring of the VR program to provide assistance to states that have not updated their interagency agreements. This is consistent with the intention of our recommendation but we believe more could be done. The agency also noted that it would continue to offer and provide technical assistance if it becomes known through the onsite monitoring of the VR program or through other means that states have not updated their interagency agreements between VR agencies and state educational agencies. In addition, its Rehabilitation Services Administration (RSA) and Office of Special Education Programs will provide information related to sources of technical assistance, as appropriate, to VR agencies and state educational agencies. While these steps may be helpful, given the number of states that have not updated and finalized their agreements and the length of time Education officials say they will take to complete this round of monitoring where Education asks state VR agencies about these agreements, additional action by Education may be needed to help states more efficiently and effectively coordinate services to students with disabilities.

Recommendation: The Secretary of Education should develop a written plan with specific timeframes and activities for identifying and disseminating best practices that address, as appropriate, implementation challenges for pre-employment transition services, such as those identified in this report. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation believing it is premature to develop a timeline for the dissemination of best practices. The agency stated that the identification of "best" practices, meaning those that are clearly supported by a body of evidence derived from valid and reliable research findings, is still emerging as states implement the requirements. Education stated that as RSA identifies best practices through its monitoring and technical assistance activities, it will, in collaboration with its Office of Special Education Programs, consider when and how best to disseminate this information to state VR and educational agencies. With regard to including specific timeframes and activities in a written plan, by detailing the specific steps Education is taking and plans to take along with the amount of time it expects them to take, Education would be better positioned to complete those steps in a timely manner and meet the statutory requirement that Education highlight best state practices and support state agencies.

Recommendation: Congress should consider requiring that states notify parents/guardians of changes in students' federal special education rights when a student with a disability is moved from public to private school by their parent.

Agency: Congress
Status: Open

Comments: As of August 2019, Congress has not considered this matter.

Recommendation: The Assistant Secretary for Special Education and Rehabilitative Services should review information provided by states related to changes in federal special education rights when a parent places a student with a disability in a private school and work with states to correct inaccurate information.

Agency: Department of Education: Office of Special Education and Rehabilitative Services
Status: Open
Priority recommendation

Comments: Education generally agreed with this recommendation. However, the agency believes it is necessary to review the full documents containing information provided by states, so that it can determine the context in which the information was presented. We will coordinate with Education as appropriate to facilitate such a review. As of March 2020, the agency worked with relevant states to improve the information provided, and reviewed states' revised information to parents about federal rights of children with disabilities who are placed by parents in private schools. Education stated that this effort did not identify any inaccurate or inconsistent information. However, some states appear not to have modified language that Education previously identified as inaccurate. Education did not explain why it has determined that this information is now accurate. To fully address this recommendation, Education should either provide this explanation or have these states correct any inaccurate information.

Recommendation: To improve oversight of school finances and provide better information to schools and the public about its monitoring efforts, the Chief Operating Officer of the Office of Federal Student Aid should update the composite score formula to better measure schools' financial conditions and capture financial risks.

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: In September 2019, Education published updated regulations related to the financial responsibility composite score that include steps to address some of the limitations identified in our report. For instance, these regulations incorporate changes to better align the composite score calculations with recently updated accounting standards related to leases. In additional, these regulatory changes are designed to curb the ability of schools to manipulate their composite scores by clarifying what is considered "long-term debt" and requiring schools to disclose in their financial statements the terms of the debt and certify that the funds were used for capitalized assets rather than to fund operations. However, these regulatory updates do not fully address the current limitations of the composite score formula. For example, they do not reflect several other changes in accounting standards identified in our report or incorporate new financial metrics that would provide a broader indication of schools' financial health, such as liquidity, historical trend analysis, or future projections. Education has stated that it intends to explore further updates to the composite score methodology in future regulatory actions, and we will continue to monitor these efforts.

Recommendation: To improve oversight of school finances and provide better information to schools and the public about its monitoring efforts, the Chief Operating Officer of the Office of Federal Student Aid should improve guidance to schools about how the financial composite score is calculated, for example, by updating current guidance to include explanations about common areas of confusion and misinterpretation for schools.

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: Education agreed with this recommendation and that additional general guidance to schools would be helpful. The department also stated that it will update the guidance in its Federal Student Aid Handbook and may provide answers and related guidance to some frequently asked questions on its website. As of October 2019, Education had not completed these actions.

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

Agency: Department of Education
Status: Open

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

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

Agency: Department of Education
Status: Open

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

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

Agency: Department of Education
Status: Open

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

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

Agency: Department of Education
Status: Open

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

Recommendation: To enhance DOD's efforts to better integrate and improve intelligence support to major defense acquisition programs, and to better enable personnel to provide intelligence inputs to their portfolios of acquisition programs, the Secretary of Defense should direct--as appropriate--the Under Secretary of Defense for Acquisition, Technology, and Logistics; the Under Secretary of Defense for Intelligence; and/or the Secretaries of the military departments, in coordination with one another, to establish certifications that include having these personnel complete required training.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with the recommendation. DOD provided corrective action plans that show they expect to complete efforts that will address this recommendation in 2019. We will continue to monitor the status of DOD's actions and whether these actions address the intent of our recommendations.

Recommendation: To enhance DOD's efforts to better integrate and improve intelligence support to major defense acquisition programs, and to facilitate implementation of improved processes and procedures developed by the Acquisition Intelligence Requirements Task Force and by the Air Force for the integration of intelligence into major defense acquisition programs, the Secretary of Defense should direct--as appropriate--the Under Secretary of Defense for Acquisition, Technology, and Logistics; the Under Secretary of Defense for Intelligence; and/or the Secretaries of the military departments, in coordination with one another, to revise relevant guidance and procedures--including DOD Instruction 5000.02 and DOD Directive 5250.01-- require that intelligence mission data at the acquisition program, service, and department levels be prioritized.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with the recommendation. DOD provided corrective action plans that show they expect to complete efforts that will address this recommendation in 2019. We will continue to monitor the status of DOD's actions and whether these actions address the intent of our recommendations.

Recommendation: To enhance DOD's efforts to better integrate and improve intelligence support to major defense acquisition programs, and to better ensure that DOD obtains useful feedback from stakeholders and the intended users of the Validated Online Lifecycle Threat tool, the Secretary of Defense should direct--as appropriate--the Under Secretary of Defense for Acquisition, Technology, and Logistics; the Under Secretary of Defense for Intelligence; and/or the Secretaries of the military departments, in coordination with one another, to instruct the Director of the Defense Intelligence Agency to develop a communication plan for the tool that includes plans for communicating with and obtaining feedback from stakeholders and intended users such as acquisition program offices and personnel providing intelligence support to acquisition programs.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with the recommendation. DOD provided corrective action plans that show they expect to complete efforts that will address this recommendation by the end of 2018. We will continue to monitor the status of DOD's actions and whether these actions address the intent of our recommendations.

Recommendation: To enhance DOD's efforts to better integrate and improve intelligence support to major defense acquisition programs, and to ensure that it fulfills the needs of acquisition programs and the intelligence community and works as intended, the Secretary of Defense should direct--as appropriate--the Under Secretary of Defense for Acquisition, Technology, and Logistics; the Under Secretary of Defense for Intelligence; and/or the Secretaries of the military departments, in coordination with one another, to assess the need for the Acquisition Intelligence Support Assessment tool and, if validated by this assessment, define this tool's requirements for development and identify the entity responsible for providing oversight and funding for its continued development, implementation, and operation.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with the recommendation. DOD provided corrective action plans that show they expect to complete efforts that will address this recommendation sometime in the future. We will continue to monitor the status of DOD's actions and whether these actions address the intent of our recommendations.

Recommendation: To help districts address key challenges in meeting MOE and mitigate unintended consequences that may affect services for students with disabilities, while preserving the safeguard for funding for students with disabilities, Congress should consider options for a more flexible MOE requirement. This could include adopting a less stringent MOE requirement to align with the MOE requirements in other education programs or adding to or modifying exceptions. For example, current exceptions could be changed to allow one-time increases in spending without changing a district's MOE baseline in order to encourage pilot innovations or to allow certain spending decreases (e.g., state caps on teacher benefits), as long as a district can demonstrate the decrease does not negatively affect services.

Agency: Congress
Status: Open

Comments: As of February 2020, Congress has not taken legislative action on this issue.

Recommendation: The Secretary of Education should develop a risk-based, cost-effective strategy to verify that states are implementing a process for assessing whether any teacher preparation programs are low-performing.

Agency: Department of Education
Status: Open

Comments: In 2016, Education published an issue brief about identifying low-performing schools, which referenced GAO's report and the potential risks of limited state action to identify and address low performance. In December 2019, Education provided GAO with a revised data collection instrument for collecting information about states' criteria for identifying low-performing teacher preparation programs. Officials stated that the instrument has been approved by OMB and Education plans to start using it in October 2020. Officials said that the instrument is designed to provide more structured information about state criteria and allow Education to better monitor states' responses from year to year. We are encouraged by these efforts and will revisit the status of this recommendation when the new template is implemented in 2020.

Recommendation: To improve agencies' guidance development, review, evaluation, and dissemination processes for non-significant guidance, we recommend that the Secretaries of USDA, HHS, DOL, and Education should improve the usability of selected component websites to ensure that the public can easily find, access, and comment on online guidance. These improvements could be informed by the web and customer satisfaction metrics that components have collected on their websites. Some examples of changes that could facilitate public access to online guidance include (1) improving website usability by clarifying which links contain guidance; (2) highlighting new or important guidance; and (3) ensuring that posted guidance is current.

Agency: Department of Health and Human Services
Status: Open

Comments: In comments printed in the April 2015 final report, HHS concurred with the recommendation and stated that it would review current links to guidance documents and explore ways to enhance their visibility and usability. As of June 2020, GAO is working with HHS officials to obtain additional updates and documentation regarding the department's implementation of this recommendation.

Recommendation: To strengthen Education's oversight of accreditors through the recognition review process, the Secretary of Education should draw upon accreditor data to determine whether accreditors are consistently applying and enforcing their standards to ensure that the education offered by schools is of sufficient quality. For example, Education could systematically use available information related to the frequency of accreditor sanctions or could do additional analyses, such as comparing accreditor sanction data with Education's information on student outcomes, to inform its recognition reviews.

Agency: Department of Education
Status: Open

Comments: Education agreed with this recommendation, noting that it is committed to identifying ways to use data about and from accreditors in its oversight. As of December 2017, Education has taken steps to track the number of accreditor sanctions issued by each accrediting agency. Education previously noted that this information will then be used to focus their limited resources on those accrediting agencies with extremely low or high sanction rates, to strengthen its oversight of accreditors. In April 2018, Education reported that it tracks accreditor sanctions and is aware of the number of sanctions when conducting agency reviews. They found no correlation between the number of sanctions an accrediting agency levies against its accredited institutions and compliance or noncompliance with the Criteria for Recognition, so they noted that this is not a useful tool. However, we continue to believe that implementing the recommendation could help inform Education's reviews of accreditors and ultimately reduce potential risk to students and federal funds. For example, analyses of accreditor sanction data could help reveal patterns in individual accreditor behavior and overall trends in sanctions. In addition, as we noted in the report, Education could compare accreditor sanction data with outcome data for accreditors' member institutions. These analyses could help Education determine how to better use data in decision-making, which is a goal listed in their 2014 strategic plan (cited in the report), as well as help to identify potential risks the accreditors might face. To close this recommendation, Education should show that it uses sanction data to inform its discussions of accreditor recognition and oversight.