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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of the Treasury
Status: Open

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

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

Agency: Department of the Treasury
Status: Open

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

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

Agency: Department of the Treasury
Status: Open

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

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

Agency: Congress
Status: Open

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

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

Agency: Congress
Status: Open

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

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

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

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

Agency: Congress
Status: Open

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

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

Agency: Congress
Status: Open

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

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

Agency: Congress
Status: Open

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

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

Agency: Congress
Status: Open

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

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

Agency: Congress
Status: Open

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

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

Agency: Congress
Status: Open

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

Recommendation: The Secretary of Labor should, in consultation with the Small Business Administration and the Department of the Treasury, immediately provide information to state unemployment agencies that specifically addresses the Small Business Administration's Paycheck Protection Program loans, and the risk of improper payments associated with these loans. (Recommendation 1)

Agency: Department of Labor
Status: Open

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

Recommendation: The Commissioner of Internal Revenue should consider cost-effective options for notifying ineligible recipients on how to return payments. (Recommendation 2)

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

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

Recommendation: The Administrator of the Small Business Administration should develop and implement plans to identify and respond to risks in the Paycheck Protection Program to ensure program integrity, achieve program effectiveness, and address potential fraud, including in loans of $2 million or less. (Recommendation 3)

Agency: Small Business Administration
Status: Open

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

Recommendation: In the absence of efforts to develop a plan, we urge Congress to take legislative action to require the Secretary of Transportation to work with relevant agencies and stakeholders, such as the Departments of Health and Human Services and Homeland Security, and members of the aviation and public health sectors, to develop a national aviationpreparedness plan to ensure safeguards are in place to limit the spread of communicable disease threats from abroad while at the same time minimizing any unnecessary interference with travel and trade. (Matter for Consideration 1)

Agency: Congress
Status: Open

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

Recommendation: To provide agencies access to Social Security Administration's more complete set of death data, we urge Congress to provide the Department of the Treasury with access to the Social Security Administration's full set of death records, and to require that the Department of the Treasury consistently use it. (Matter for Consideration 2)

Agency: Congress
Status: Open

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

Recommendation: To help ensure that federal funding is targeted and timely, we urge Congress to use GAO's Federal Medical Assistance Percentage formula for any future changes to the Federal Medical Assistance Percentage during the current or any future economic downturn. (Matter for Consideration 3)

Agency: Congress
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

Recommendation: The Associate Administrator of the Office of Entrepreneurial Development should reevaluate the SBDC funding application requirements, including reexamining the funding estimate SBDCs are required to use and considering other changes that could reduce administrative burdens on SBDCs. (Recommendation 1)

Agency: Small Business Administration
Status: Open

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

Recommendation: Congress should consider reassessing and determining the level of universal postal service the nation requires. (Matter for Consideration 1)

Agency: Congress
Status: Open

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

Recommendation: Congress should consider determining the extent to which USPS should be financially self-sustaining and what changes to law would be appropriate to enable USPS to meet this goal. (Matter for Consideration 2)

Agency: Congress
Status: Open

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

Recommendation: Congress should consider determining the most appropriate institutional structure for USPS. (Matter for Consideration 3)

Agency: Congress
Status: Open

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

Recommendation: The Secretary of Defense should ensure that the Director of DSCA implements the planned initiative to routinely examine annual case reviews performed by DOD components to help ensure that fees collected into the FMS transportation accounts are accurate. (Recommendation 1)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of Defense should ensure that the Director of DSCA works with DFAS and DOD components to establish a written process to monitor the timeliness of components' delivery reporting to help ensure that fees collected into the FMS transportation accounts are accurate. (Recommendation 2)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of Defense should ensure that the Director of DSCA finalizes and implements internal guidance on how to conduct and document DSCA's monthly review of expenditures from the FMS transportation accounts, including what information should be reviewed and how to identify and follow up on discrepancies. (Recommendation 3)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of Defense should ensure that the Director of DSCA works with DFAS to finalize written guidance to DFAS on how to generate the reports needed for DSCA's monthly review of expenditures from the FMS transportation accounts, including the type of analysis needed. (Recommendation 4)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of Defense should ensure that the Director of DSCA works with DFAS and other DOD components to finalize the planned guidance to DFAS for the review and realignment of expenditures from the FMS transportation accounts to ensure reviews are consistent and include all expenditures. (Recommendation 5)

Agency: Department of Defense
Status: Open

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation: The Secretary of HUD should define and document roles and responsibilities for identifying opportunities to promote more efficient shared service usage through business process analyses, including defining roles for monitoring and implementing actions recommended because of these analyses. (Recommendation 1)

Agency: Department of Housing and Urban Development: Office of the Secretary
Status: Open

Comments: In a letter dated May 19 2020, HUD's Chief Financial Officer stated that HUD concurred with this recommendation and will more specifically define who is responsible for identifying and implementing opportunities for achieving efficiencies with service usage, including roles for the business process analyses the Working Capital Fund division conducts from time to time. HUD expects to complete this action by December 31, 2020. When we can confirm what actions HUD has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of HUD, in conjunction with OCFO, should ensure that the results of the WCF Division's business process analyses are assessed to better understand how these analyses contribute to the WCF's established goal to support the efficient delivery of enterprise goods and services. (Recommendation 2)

Agency: Department of Housing and Urban Development: Office of the Secretary
Status: Open

Comments: In a letter dated May 19 2020, HUD's Chief Financial Officer stated that HUD concurred with this recommendation and will add the results of the Working Capital Fund division's business process analyses as a performance metric to its Working Capital Fund performance scorecard. HUD expects to complete this action by December 31, 2020. When we can confirm what actions HUD has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of HUD should ensure that the WCF Committee conducts periodic reviews of WCF business lines, as authorized in the WCF Committee Charter, to ensure effective management, strong performance, and customer satisfaction. (Recommendation 3)

Agency: Department of Housing and Urban Development: Office of the Secretary
Status: Open

Comments: In a letter dated May 19 2020, HUD's Chief Financial Officer stated that HUD concurred with this recommendation and is in the process of implementing this recommendation. According to the letter, reviews of Working Capital Fund business lines are conducted as a part of regular Working Capital Fund Committee meeting discussions. However, the Committee plans to hold formal review sessions dedicated to reviewing the business lines. HUD expects to complete this action by December 31, 2020. When we can confirm what actions HUD 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 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 Agriculture should direct Departmental Administration to work with the mission areas to develop department-level outcome-oriented performance goals and related measures for the business centers, and use them to assess the effectiveness and impact of the business center reforms. (Recommendation 1)

Agency: Department of Agriculture
Status: Open

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

Recommendation: The Commissioner of Internal Revenue should make publicly available, such as on its website, a list of tax topics considered out of scope for CSRs to answer on the telephone, as well as include references for how and where to find information about these topics. (Recommendation 1)

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

Comments: IRS agreed with this recommendation and said it would make out-of-scope topics more readily available for taxpayers.

Recommendation: The Commissioner of Internal Revenue should reconcile authority and implement procedures for routinely reviewing the English versions of IRS's most commonly used vital tax products and web pages to ensure that information is included in commonly encountered languages about where taxpayers with LEP can obtain the translated content. If such content is not translated, the products and web pages should include information about where taxpayers with LEP can obtain language assistance from IRS. (Recommendation 2)

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

Comments: IRS neither agreed nor disagreed with this recommendation. In commenting on the draft report, IRS said the recommendation affects multiple stakeholders and IRS is evaluating the recommendation and actions for implementation. IRS said it would provide additional details at a later time.

Recommendation: The Commissioner of Internal Revenue should reconcile authority and implement procedures for routinely reviewing its multilingual web pages to effectively prevent, or detect and correct, errors such as incorrect or outdated information. For example, these procedures could call for the divisions to work with the Linguistics, Policy, Tools, & Services (LPTS) section whenever the English version of translated content is updated. (Recommendation 3)

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

Comments: IRS agreed with this recommendation, saying each business unit would be required to work with the Linguistic Policy, Tools and Services Section whenever the English version of translated content is updated. IRS also said interpreting the Form 1040 into different languages would be a major accomplishment that it wishes to achieve in the near future.

Recommendation: The Commissioner of Internal Revenue should conduct the four-factor assessment of its language services to persons with LEP for its most commonly used vital tax products to determine (1) which products should be translated and into what languages, and (2) what interpretation assistance will be provided to arrive at the appropriate mix of translation and interpretation services. IRS should document these assessments, including the determinations it made, and take action as appropriate based on these assessments. (Recommendation 4)

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

Comments: IRS neither agreed nor disagreed with this recommendation. In commenting on the draft report, IRS said the recommendation affects multiple stakeholders and IRS is evaluating the recommendation and actions for implementation. IRS said it would provide additional details at a later time.

Recommendation: The Commissioner of Internal Revenue should collect and use employee input on the strengths and weaknesses of its customer service training, including on whether training is effective in improving CSRs' performance, to inform changes to its training program and strategy under the Taxpayer First Act. (Recommendation 5)

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

Comments: IRS agreed with this recommendation and said it would review the employee training evaluation process to determine what steps can be taken to improve training, such as making certain evaluations mandatory for employees and updating the surveys with more focused questions in order to get more substantial feedback.

Recommendation: The Commissioner of Internal Revenue should direct the Wage and Investment division to develop and implement a strategy, in collaboration with its strategic workforce planning initiative, for the efficient use of overtime. (Recommendation 6)

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

Comments: IRS agreed with this recommendation.

Recommendation: The Commissioner of Internal Revenue should further assess the increase in "system downtime" and identify possible solutions to mitigate any problems and reduce system downtime. (Recommendation 7)

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

Comments: IRS agreed with this recommendation. In commenting on the draft report, IRS said it completed a further assessment after our audit and identified potential contributing factors. IRS said it implemented changes to the call center environment and was updating the Customer Service Representative technology platform to further improve system availability.

Recommendation: The Commissioner of Internal Revenue should perform regular monitoring of fluctuations in system downtime charges, such as increases overall or by specific units, to determine what, if any, factors are interrupting CSRs' work. (Recommendation 8)

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

Comments: IRS said it agreed with this recommendation and would monitor the system downtime reported by the Customer Service Representatives (CSR) in Customer Account Services. In commenting on the draft report, IRS said it had implemented changes to the call center environment and was updating the CSR technology platform to further improve system availability.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation: The Administrator of the General Services Administration (GSA), in coordination with the Director of the Office of Management and Budget, should ensure that the average cost per square foot performance measure for GSA-managed space is calculated using actual cost information. (Recommendation 1)

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

Comments: GSA concurred with this recommendation and has developed an action plan to implement it. In January 2020, GSA officials told us that GSA will change the method for calculating the average cost per square foot performance measure by now using the actual rent agencies paid to GSA in the calculation. GSA officials also stated that GSA will post this information annually to performance.gov. We will continue to monitor GSA's implementation of these efforts.

Recommendation: The Secretary of Defense should ensure that the Director of the Defense Finance and Accounting Service provides customers with more complete information on the agency's rate-setting methodologies in rate documentation, briefings, and other forums where rates are discussed, including the costs included in rates, how those costs are calculated, and how changes in DFAS's workload affect customers' overall costs. (Recommendation 1)

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

Comments: The Department of Defense (DOD) concurred with GAO's recommendation and stated that the Defense Finance and Accounting Service (DFAS) provides detailed cost and rate information to customers each year in multiple venues and would reach out to customers to obtain additional details to understand how to fill the information gap regarding rate transparency. In April 2020, DOD provided to GAO DFAS's corrective action plan, which stated that DFAS Client Executives would ask the Army, Navy, and Marine Corps lead Financial Managers for feedback on additional details needed to better plan for the DFAS bill. DFAS would then incorporate this additional detail into the customer bill briefings for the President's Budget Request for fiscal year 2022. DFAS also stated that the Air Force had indicated that DFAS provides appropriate transparency, but had requested that DFAS provide its bill estimate earlier, which DFAS had agreed to do.

Recommendation: The Secretary of Defense should ensure that the Director of the Defense Information Systems Agency provides customers with more complete information on the agency's rate-setting methodologies in rate documentation, briefings, and other forums where rates are discussed, including the costs included in rates, how those costs are calculated, and how changes in DISA's workload affect customers' overall costs. (Recommendation 2)

Agency: Department of Defense: Defense Information Systems Agency
Status: Open

Comments: The Department of Defense (DOD) concurred with GAO's recommendation and stated that the Defense Information Systems Agency (DISA) will make every effort to improve dialogue with customers to ensure the correct people have a full understanding of DISA's methodologies used to develop their rates. In April 2020, DOD provided to GAO DISA's corrective action plan, which stated that DISA would continue to make every effort to improve dialogue with customers to ensure an increased understanding of methodologies used to develop the rates. In this plan, DISA reported that, in February and March 2020, its Chief Financial Officer (CFO) coordinated with the communications and financial management senior leadership for the military services to discuss Defense Working Capital Fund (DWCF) rate methodology and transparency. In May 2020, DOD provided an updated status on this recommendation, stating that a result of the DISA CFO outreach was that DISA would use the regular and recurring DISA Drumbeat engagements with the military departments to present and maintain an open and transparent dialogue on DISA DWCF rates. GAO requested documentation for the recent Navy and Air Force Drumbeat meetings and the pending Army meeting, as well as recent rate briefings that document that DISA is providing this more complete rate-setting information to its customers. GAO will update the status of this recommendation once this documentation is received.

Recommendation: The Secretary of Defense should ensure that the Director of the Defense Logistics Agency provides customers with more complete information on the agency's rate-setting methodologies in rate documentation, briefings, and other forums where rates are discussed, including the costs included in its rates, how it calculates those costs, and how and when proposed changes to its rate-setting methodologies will affect customers' overall costs. (Recommendation 3)

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

Comments: The Department of Defense (DOD) concurred with GAO's recommendation and stated that the Defense Logistics Agency (DLA) would include more detailed information in its annual rate briefing to the Office of the Under Secretary of Defense (Comptroller) and the services regarding what is in its costs, how it calculates costs, and how and when changes would impact customers' overall costs. In addition, DLA stated that it conducts semiannual Cost Summits and periodic DLA/Service Days with customers. DLA said it would include discussions, as appropriate, of topics such as potential pricing methodology changes and estimated cost impacts to customers, well in advance of implementation. In March 2020, DLA notified GAO that it had discussed cost rates with the military services during the January 2020 DLA Cost Summit and the Service Days with each of the military services that it held in June and November 2019. GAO requested documentation for these five meetings that includes the more complete information on DLA's rate-setting methodologies that GAO identified in the recommendation. GAO will update the status of this recommendation once this documentation is received.

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

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

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

Recommendation: The Commissioner of the Social Security Administration should ensure that (a) the agency's policies and guidance are specific enough so field office staff know how to apply complex suitability criteria for assessing payee suitability, such as by providing a minimum set of specific questions; and (b) additional regional guidance that is made available to staff is centrally reviewed for compliance and completeness. (Recommendation 1)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation but did not specify plans to address it.

Recommendation: The Commissioner of the Social Security Administration should create safeguards in the Electronic Representative Payee System (eRPS) to ensure that field office staff fully document all required information, such as the rationale for their decision, before approving an application. (Recommendation 2)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and identified actions to address it. Specifically, SSA reported that, as part of implementing the Strengthening Protections for Social Security Beneficiaries Act of 2018, planned changes to eRPS will improve documentation of selection decisions. SSA also reported it will also consider additional enhancements to eRPS in the future. We will consider closing this recommendation when this effort is complete.

Recommendation: The Commissioner of the Social Security Administration should complete a plan, including timeframes, for comprehensively evaluating if and how to leverage external sources of information on organizations' suitability, such as by conducting background checks or credit checks on organizations or key staff that handle beneficiaries' funds or requiring organizations to conduct their own background checks on key staff. (Recommendation 3)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and identified actions to address it. SSA officials stated that it is first focusing on implementing provisions of the Strengthening Protections for Social Security Beneficiaries Act of 2018 related to background checks for certain individual payees. After completing this work, the agency plans to evaluate conducting criminal background checks and credit checks on organizational payees and their staff. While we agree that implementing background screening pursuant to the law should take precedence, SSA should seek opportunities to implement screening for organizational payees at the earliest opportunity.

Recommendation: The Commissioner of the Social Security Administration should develop and implement mechanisms to systematically obtain and review feedback from organizational payees and communicate findings to SSA management. (Recommendation 4)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation but did not identify plans to address it.

Recommendation: The Commissioner of the Social Security Administration should (a) establish a plan and time frame for periodically reviewing the predictive model's design; (b) consider additional data sources that would allow for additional screening or modeling of potentially high-risk organizational payees; and (c) ensure that subsequent design decisions are documented in sufficient detail so the development process can be more fully understood and replicated, either by SSA or a knowledgeable third party, with minimal further explanation. (Recommendation 5)

Agency: Social Security Administration
Status: Open
Priority recommendation

Comments: SSA agreed with this recommendation in 2019 and identified actions to address it. The agency stated that it would pursue other data sources to develop additional screening tools and models to identify potentially high-risk organizational payees, but that it is unable to incorporate additional data into the existing model. They reported they cannot use new data to modify the existing model, which was built from cases and transactions that occurred many years ago. We recognize that the current model, which focuses on misuse findings and is based on historical data, presents challenges for both updating and including new data sources. Therefore, as SSA considers additional screening tools and models to identify high-risk, low-volume organizational payees, SSA should develop a plan for revising the existing model that allows for more timely updates and results in documentation of related design decisions. In April 2020, SSA officials reported that the agency is finalizing a plan to revise the existing model and would pursue other data sources to develop additional screening tools and models to identify potentially high-risk organizational payees.

Recommendation: The Commissioner of the Social Security Administration should require field offices to contact payees about missing or problematic annual accounting forms within a specific time frame. (Recommendation 6)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation but did not identify plans to address it.

Recommendation: The Commissioner of the Social Security Administration should revise the annual accounting form to enhance its effectiveness. Such revisions could include (but not be limited to) more fully ascertaining the use of collective accounts, adopting stakeholders' recommendations on using the form to collect more meaningful data, and reflecting best practices from behavioral science insights in the design of the form. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation but did not identify plans to address it.

Recommendation: The Commissioner of the Social Security Administration should enhance the eRPS system to ensure that field offices are (a) alerted when collective accounts are due to be reviewed; and (b) able to take action on expired collective account information and thereby avoid payees' continued use of these accounts without oversight. (Recommendation 8)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation and identified actions to address it. SSA officials reported that they would work with staff to ensure staff know where to find alerts for expiring accounts and enhance how eRPS displays information on collective accounts that have already expired. We agree with SSA's proposed actions. However, we adjusted our recommendation to clarify that SSA should enhance eRPS in a manner that ensures staff take action on expired accounts and that payees do not continue to use expired accounts without oversight.

Recommendation: The Commissioner of the Social Security Administration should, as it carries through with its plan to develop a risk assessment for the organizational payee program, ensure that that the plan reflects periodic consideration of findings from onsite reviews and audits. (Recommendation 9)

Agency: Social Security Administration
Status: Open
Priority recommendation

Comments: SSA agreed with this recommendation. In April 2020, SSA officials reported starting its Representative Payee Fraud Risk Assessment. We will consider closing this recommendation when SSA ensures that its risk assessment plan reflects periodic consideration of findings from onsite reviews and audits.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA clarify internal guidance for daily account reviews by specifying criteria for the level (such as percentage or dollar amount) of change in transportation account balances that would require DSCA to contact DFAS for further examination. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and identified plans to address it, such as to establish a percentage threshold for monitoring daily account balance changes. We will monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA establish a methodology to calculate a target range, with desired upper and lower bounds, for FMS transportation account balances that could be used to better inform DSCA's account reviews. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and identified plans to address it, such as to create internal guidance for calculating upper and lower bounds and to monitor the accounts against them. We will monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA modify the internal guidance for the annual review process to include the specific steps DSCA officials should take in preparing the annual report, including ensuring that they incorporate rigorous analysis into the annual reports. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and identified plans to address it, such as to update internal guidance with specific criteria for measuring the health of the accounts and to perform rigorous analysis of historical account data as part of its annual review process. We will monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA develop internal guidance related to the redistribution of funds between the FMS trust fund fee accounts. Such internal guidance could include criteria for when to consider redistributing funds between accounts and for when to return those funds, how to analyze the amount of any redistributions needed, and how to clearly report any redistributions to DSCA management. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and identified plans to address it, such as to update internal guidance with specific criteria and analysis steps to follow when making determinations about redistributing funds between the FMS trust fund fee accounts. We will monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA assess whether funds redistributed from the administrative account to the transportation account should be moved back to the FMS administrative account and document this decision. If the Director of DSCA determines that the funds should be moved back to the FMS administrative account, the Director should ensure the movement of funds in accordance with this decision. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and explained certain steps DSCA has already taken in response. In particular, DSCA has completed an assessment of the health of the main FMS transportation account sufficient to determine that it plans to move the redistributed funds back to the FMS administrative account and DSCA has taken initial steps to move those funds. We will continue to monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA develop internal guidance for the steps that DSCA, in combination with DFAS, should undertake when a Building Partner Capacity-specific transportation account closes to help ensure that any remaining unused funds are transferred to the miscellaneous receipts of the U.S. Treasury in accordance with DOD officials' stated intention to do so. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and identified plans to address it, such as to develop guidance for DFAS to follow when Building Partner Capacity-specific transportation accounts close to ensure any remaining funds are transferred to the miscellaneous receipts of the U.S. Treasury. We will monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA create specific internal guidance for how and from where data should be obtained to be used for its transportation fee rate reviews and the timeframes the data should cover to ensure DSCA has a systematic sample upon which to base its rate setting decisions. This updated internal guidance should be based on consultations with the military departments, DFAS, and U.S. Transportation Command (TRANSCOM) on which sources of transportation cost and fee data are the most reliable and comparable for use in its FMS transportation fee rate reviews. (Recommendation 7)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and stated that DSCA has discussed with other relevant DOD agencies in a Transportation Working Group how to best address it. In particular, DSCA noted this Working Group has decided that all data for the rate reviews should come from common data systems and be submitted in a uniform manner. Upon determination of the systems to use and processes to follow, DSCA plans to update internal guidance accordingly. We will monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA develop specific internal guidance to follow when performing transportation fee rate reviews. Such internal guidance could specify when these reviews should occur; a process to obtain management commitment to complete a review before DSCA requests that the military departments compile data for it; and a process for performing the reviews that includes developing clear, documented goals and an appropriate level of analysis to best ensure that DSCA's analysis meets those goals. (Recommendation 8)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and identified plans to address it, such as to update internal guidance for FMS transportation fee rate reviews to ensure they are completed every 5 years. We will monitor DSCA's implementation of this aspect of the recommendation, as well as the other aspects related to DSCA providing greater specificity about the processes for obtaining management commitment and for performing the rate reviews.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA conduct a review of the current structure of the FMS transportation fee rate, in consultation with other relevant DOD agencies, to determine if other rate structures could better balance considerations related to administrative burden, equity, efficiency, and revenue adequacy. (Recommendation 9)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and identified plans to address it, such as to perform rigorous analysis and to consult with other relevant DOD agencies in the Transportation Working Group about whether the current structure of the FMS transportation fee rate is still valid or should be updated, and to update internal guidance as appropriate. We will monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA clarify internal guidance for the military departments on how to calculate the estimated actual transportation prices to charge FMS purchasers for certain items, such as by specifying a calculation methodology. This updated internal guidance should be based on consultations with the military departments, TRANSCOM, and any other relevant DOD components on which sources of data and which calculation methodologies would be most accurate. (Recommendation 10)

Agency: Department of Defense
Status: Open

Comments: In DSCA's letter responding to this report, DSCA concurred with this recommendation and identified plans to address it, such as to consult with other relevant DOD agencies in the Transportation Working Group to review this calculation methodology, determine a revised methodology that better aligns with TRANSCOM's transportation routes and contracting costs, and to update internal guidance as appropriate. We will monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense (Acquisition and Sustainment) develop and adopt a depot maintenance carryover metric that provides reliable, complete, consistent, and appropriate information. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: In written comments on a draft of this report, DOD concurred with the recommendation. Specifically, DOD stated that the Undersecretary of Defense (Acquisition and Sustainment) and the Undersecretary of Defense (Comptroller) will coordinate with the Military Departments to promulgate regulations implementing GAO's recommendation, and collaborate to develop a new budgetary exhibit to coincide with the Fiscal Year 2022 budget estimate submission. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of OMB should ensure that information is collected regarding how centralized reporting of procurement requirements might reduce recipient reporting burden—including input from stakeholders such as contractors through an iterative and ongoing process—to inform OMB's planned expansion of the Central Reporting Portal.

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

Comments: In an October 2019 written response to the recommendation contained in GAO-19-299, OMB acknowledged the importance of collecting stakeholder input and described some steps that it has taken to do so in the past. The letter also stated OMB's intention to engage key stakeholders moving forward but was not specific regarding steps it planned to take related to the potential expansion of the Central Reporting Portal. GAO will continue to monitor this issue including what specific actions, if any, OMB takes in response to this recommendation.

Recommendation: OMB's Shared Services Policy Officer should work with GSA to finalize a plan for monitoring the implementation of NewPay. The plan should include:
• implementation goals, a timeline, and milestones for agencies to transition from one provider to another;
• transparent reporting mechanisms on key milestones; and
• a process for capturing and communicating lessons learned.
(Recommendation 1)

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

Comments: OMB staff did not agree or disagree with GAO's March 2019 recommendation. As of January 2020, OMB had not addressed this recommendation. According to OMB staff, they are still deliberating goals and milestones for NewPay. In addition, OMB is working on a knowledge library to capture lessons learned for shared services initiatives. However, OMB staff did not provide a timeline for when they will complete these efforts. Without a detailed monitoring plan that includes goals, transparent reporting mechanisms on key milestones, and a process for capturing and communicating lessons learned, it will be more difficult for OMB and GSA to provide oversight of the transition and its effects on providers and customers, including whether there are interruptions to delivery of services. Additionally, this information could help OMB and GSA avoid gaps in service or costly delays as agencies transition to the new model for obtaining payroll and work management services.

Recommendation: OMB's Shared Services Policy Officer should work with GSA to document key roles and responsibilities, including which agency will be the NewPay Service Management Offices (SMO), who will be assigned to the NewPay Task Order Review Board, how the SMO, the Review Board, and other key stakeholders will work together, and which agency will be responsible for interpreting payroll rules and regulations. (Recommendation 2)

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

Comments: OMB staff did not agree or disagree with GAO's March 2019 recommendation. As of January 2020, OMB had taken some steps to address this recommendation. OMB designated GSA as the Quality Service Management Office (QSMO) for NewPay. As QSMO, GSA will be responsible for managing the payroll marketplace. However, OMB has not documented how GSA and other key stakeholders will work together. For example, OMB has not documented which agency will review and approve task orders. Until OMB and GSA clearly identify, communicate, and document key roles and responsibilities, they run the risk of not achieving their objectives. They also risk repeating past problems associated with the delivery of shared services, such as the inconsistent implementation and interpretation of standards and migrations that encounter costly delays should agencies not follow available guidance.

Recommendation: OMB's Shared Services Policy Officer should work with GSA to update provider information on services offered, pricing, and performance and share that information with prospective customers. (Recommendation 3)

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

Comments: OMB staff did not agree or disagree with GAO's March 2019 recommendation. As of January 2020, OMB had not addressed this recommendation. Without up-to-date information on providers -- such as the services OMB and GSA plan to offer, their level of performance, and their costs -- it will be time- consuming and difficult for potential customers to compare providers. This lack of information could slow the rate of shared services adoption.

Recommendation: OMB's Shared Services Policy Officer should work with GSA to implement a process for collecting and tracking cost-savings data that would allow them to assess progress toward the shared services cost-savings goal of an estimated $2 billion over 10 years. (Recommendation 4)

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

Comments: OMB staff did not agree or disagree with GAO's March 2019 recommendation. As of January 2020, OMB had not addressed this recommendation. According to OMB officials, OMB will collect cost-savings data via the integrated data collection process, which requires agencies to publicly post their cost savings and avoidance data. However, OMB has not demonstrated how it plans to use data from the IT Integrated Data Collection Instrument to track cost savings specifically related to shared services overall and for individual projects. Until OMB and GSA finalize a plan for collecting the needed data and evidence to effectively measure cost-savings goals, it will be difficult to demonstrate progress -- a recurring challenge associated with previous shared services efforts.

Recommendation: The Secretary of the Navy should clarify whether and how to use the laboratory initiated research authority within the Capital Investment Program. (Recommendation 2)

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

Comments: In December 2018, DOD agreed with our recommendation. In March 2019, DOD reported that the Navy was working on establishing a process for its laboratories to use the funds made available to them through the laboratory initiated research authority and planned to have this new policy in place by September 1, 2019 but was subsequently changed to a new date of October 1, 2019. However, the Navy was unable to finalize its policy prior to the start of the 2020 fiscal year. In February 2020, a senior USD(R&E) official stated that internal discussions between Navy acquisition officials and Navy financial management officials were ongoing. This official further noted that the Navy planned to finalize its policy by December 1, 2020, in time to influence the Navy's fiscal year 2022 budget request.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Acquisition and Sustainment assesses whether DLA Document Services' single manager role for printing and reproduction provides the best value to the government--as determined by quality, price, and delivery time and in light of DLA Document Services' transformation plan--and whether any additional efficiencies are possible, and use the results of that assessment to inform the revision of DOD Instruction 5330.03. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with GAO's October 2018 recommendation. By July 2019, DOD had completed a study of printing and reproduction services to determine the best value to the department. As of December 2019, according to a DOD official, the Office of the Under Secretary of Defense for Acquisition and Sustainment plans to develop steps toward achieving the best value to the government based on the study results, and update DOD Instruction 5330.03, which describes the mission, responsibilities, functions, and relationships of DLA Document Services by July 2020. Completion of these actions would allow DOD to determine if further efficiencies in its document services are possible.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Acquisition and Sustainment assesses whether DOD's current approach to obtaining print devices represents the best value to the government or whether other approaches, such as further consolidations under DLA Document Services as a proposed single manager for print device procurement, would be more cost effective. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with GAO's October 2018 recommendation. In July 2019, DOD had completed a study of printing and reproduction services to determine the best value to the department. As of December 2019, according to a DOD official, the Office of the Under Secretary of Defense for Acquisition and Sustainment plans to develop steps toward achieving the best value to the government based on the study results, and update DOD Instruction 5330.03, which describes the mission, responsibilities, functions, and relationships of DLA Document Services by July 2020. Completion of these actions would allow DOD to determine if further efficiencies in its document services are possible.

Recommendation: The Secretary of Defense should ensure that the DOD Chief Information Officer (CIO) implements controls, such as reporting procedures, to routinely monitor actions to reduce the number of print devices, consistent with department-wide goals for reducing the number of print devices that are included in the CIO's 2012 memorandum. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with GAO's October 2018 recommendation. As of December 2019, DOD had ongoing actions intended to address the recommendation. For example, according to a DOD official, the DOD Chief Information Officer (CIO) will collaborate with the Under Secretary of Defense for Acquisition and Sustainment to define the necessary responsibilities, policy, and procedures in the planned revision of DOD Instruction 5330.03, which describes the mission, responsibilities, functions, and relationships of DLA Document Services. DOD plans to update the instruction by July 2020. Implementing controls, such as clarifying responsibilities, policy, and procedures would better enable DOD to achieve department-wide goals for reducing print devices it established in the CIO's 2012 memorandum.

Recommendation: The Secretary of Defense should ensure that the DOD CIO assigns responsibility for implementing the CIO's 2012 memorandum on optimizing the use of employee information technology devices. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with GAO's October 2018 recommendation. As of December 2019, DOD had ongoing actions intended to address the recommendation. For example, according to a DOD official, the DOD Chief Information Officer (CIO) will collaborate with the Under Secretary of Defense for Acquisition and Sustainment to define the necessary responsibilities, policy, and procedures in the planned revision of DOD Instruction 5330.03, which describes the mission, responsibilities, functions, and relationships of DLA Document Services. DOD plans to update the instruction by July 2020. Implementing controls, such as clarifying responsibilities, policy, and procedures would better enable DOD to achieve department-wide goals for reducing print devices it established in the CIO's 2012 memorandum.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense (Comptroller), in consultation with the military services and DLA, evaluates options to report more accurate funding information and takes steps to improve the accuracy of its budgetary and financial information reporting on document services internally and to Congress, including making distinctions between printing and non-printing-related costs and information on device procurement and electronic content management. This information could be provided as part of DOD's annual Operation and Maintenance budget justification materials. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) partially concurred with this recommendation. As of July 2019, DOD had ongoing actions intended to address the recommendation. For example, according to DOD documentation, the offices of the Under Secretary of Defense for Acquisition and Sustainment and Under Secretary of Defense (Comptroller) planned to examine the Service-related definitions of printing and reproduction for potential process improvements. DOD anticipated completing this action by July 2020. Examining opportunities to improve the definitions of printing and reproduction services would better position DOD to report more accurate funding information for document services, as GAO recommended in October 2018

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness (USD(P&R)), in consultation with the Secretaries of the military departments, comprehensively evaluate the funding targets for Category A and B MWR programs and document any changes made to the targets and the methodology used. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. As of September 2020, OSD officials stated that the Department is conducting a comprehensive review of the entire DOD MWR program that will encompass a review of the MWR funding targets. OSD officials stated that OSD, in conjunction with the Military Departments have been engaged over the last two years to complete this review. OSD officials said that once this review is complete, DOD Instruction 1015.10 and DOD Instruction 1015.15 will be updated with the new policy. OSD officials estimate completing this by 9/30/2022.

Recommendation: The Secretary of Defense should ensure that the USD(P&R), in consultation with the Secretaries of the military departments, develop measurable goals for its MWR programs' performance measures to determine the programs' cost-effectiveness. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. OSD officials stated that the Department is conducting a comprehensive review of the entire DOD MWR program that will encompass a review of the MWR funding targets. OSD officials said that OSD, in conjunction with the Military Departments have been engaged over the last two years to complete this review. OSD officials said that once this review is complete, DOD Instruction 1015.10 and DOD Instruction 1015.15 will be updated with the new policy. OSD officials said that after agreement on the new funding targets is reached, work will begin to develop measurable performance goals. OSD officials estimate that this work will be completed by 9/30/2022.

Recommendation: The Administrator of CMS should complete a comprehensive, national risk assessment and take steps, as needed, to assure that resources to oversee expenditures reported by states are adequate and allocated based on areas of highest risk. (Recommendation 1)

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

Comments: CMS has taken steps to conduct a comprehensive national risk assessment. As of October 2019, CMS had developed a standard tool to assess risk and staff capacity. The agency indicated that once the assessment is complete, CMS will identify opportunities to increase resources, review the current allocation of financial staff, and determine the appropriate allocation of staff by state. We will continue to monitor CMS's action to complete this assessment.

Recommendation: The Administrator of CMS should clarify in internal guidance when a variance analysis on expenditures with higher match rates is required. (Recommendation 2)

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

Comments: In October 2019, CMS indicated that the agency held meetings to clarify internal guidance on the variance analysis and is the process of drafting updated guidance for the CMS-64 review. We will continue to monitor CMS's actions to update the guidance.

Recommendation: The Administrator of CMS should revise the sampling methodology for reviewing expenditures for the Medicaid expansion population to better target reviews to areas of high risk. (Recommendation 3)

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

Comments: In October 2019, CMS indicated that given their current resources, they believe the sampling methodology is sufficient and have no plans to revise it. The agency noted that the current methodology requires a minimum sample size but gives reviewers the flexibility to expand the size of the sample if warranted by risk and as resources permit. We continue to believe that the current methodology does not sufficiently target areas of high risk.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA takes steps to work with Defense Finance and Accounting Service (DFAS)--DSCA's financial service provider--and other DOD components, as appropriate, to improve the reliability of the data the DSCA obtains on all DOD components' use of FMS administrative funds, including actual execution data, at an appropriate level of detail, such as by object class. (Recommendation 1)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: In February and May 2019, DSCA informed us that it had taken some steps to implement this recommendation, including establishing an automatic interface with certain DOD components' accounting systems to provide DSCA with daily information and data on those components' actual spending of FMS administrative funds. DSCA noted that it is working toward establishing automatic interfaces for the other components that receive these funds. In October 2019, DSCA informed us that implementation is ongoing. As of August 2020, we continue to monitor DOD's ongoing actions to implement this recommendation .

Recommendation: The Secretary of Defense should ensure that the Director of DSCA works with DFAS to conduct regular reconciliations of the data that DSCA collects on DOD components' use of administrative funds, to help ensure that the data are reliable. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: In May 2019, DSCA noted that it is undertaking an initiative to incorporate reconciliation capabilities into its oversight of components' use of FMS administrative funds. In October 2019, DSCA informed us that efforts to implement this recommendation are ongoing. As of August 2020, we continue to monitor DOD's actions to implement this recommendation .

Recommendation: The Director of DSCA should follow its requirement to conduct at least two annual reviews of military department business processes for administrative funds. (Recommendation 3)

Agency: Department of Defense: Defense Security Cooperation Agency
Status: Open

Comments: In October 2019, DSCA informed us that it had conducted two business process reviews for military departments in 2019. As of August 2020, we continue to monitor DSCA's ongoing actions to implement this recommendation.

Recommendation: The Director of DSCA should conduct periodic (e.g., annual or biennial) reviews of other DOD components' (e.g., other than military departments) business processes for administrative funds, based on a risk-based approach. Such an approach could include consideration of whether an entity has received a prior review or representative sampling over time, as well as consideration of factors such as the results of prior audits or other identified risks. (Recommendation 4)

Agency: Department of Defense: Defense Security Cooperation Agency
Status: Open

Comments: In October 2019, DSCA informed us that it planned to conduct one review for another DOD component (e.g., other than a military department) in fall 2019. In January 2019, it collaborated with other DOD components that receive FMS administrative funds to develop risk-based criteria for selecting components for periodic business process reviews . DSCA also provided updated policies and procedures for these reviews, which state that DSCA will conduct at least one review for another DOD component annually. As of August 2020, we continue to monitor DSCA's ongoing actions to implement this recommendation.

Recommendation: The Director of DSCA should create and maintain a complete list of military department organizations or offices that receive administrative funds and are subject to DSCA's business process reviews. (Recommendation 5)

Agency: Department of Defense: Defense Security Cooperation Agency
Status: Open

Comments: In May 2019, DSCA provided supporting documentation to show that, as part of its annual budget review cycle, it had required DOD components to provide a list of sub-components/organizations that receive FMS administrative funds. In October 2019, DSCA provided a list of sub-components/organizations that DSCA obtained as part of the 2019 annual budget cycle. As of August 2020, we continue to monitor DSCA's actions to implement this recommendation.

Recommendation: The Director of DSCA should update DSCA's policy for selecting military department organizations for reviews of their business processes for administrative funds, to better ensure that it reflects a risk-based approach. (Recommendation 6)

Agency: Department of Defense: Defense Security Cooperation Agency
Status: Open

Comments: In May 2019, DSCA provided updated standard operating procedures for selecting military department organizations for reviews of their business processes for administrative funds. As of August 2020, we are reviewing the documentation provided and following up with DSCA to determine the extent to which the new procedures reflect a risk-based approach.

Recommendation: The Director of DSCA should clarify guidance to ensure that the DSCA officials conducting reviews of business processes for administrative funds periodically track action items until they are completed. (Recommendation 7)

Agency: Department of Defense: Defense Security Cooperation Agency
Status: Open

Comments: In February 2019, DSCA noted that it had updated its policies and procedures to reflect that it will track action items from business process reviews every 30 days, until the action items area completed. DSCA needs to providing supporting documentation for its efforts to track action items. As of August 2020, we continue to monitor DSCA's ongoing actions to implement this recommendation .

Recommendation: The Director of DSCA should develop a process for conducting periodic (e.g., quarterly or annual), targeted reviews of DOD components' use of administrative funds, including transactions testing, to verify that actual costs incurred are allowable and approved. (Recommendation 8)

Agency: Department of Defense: Defense Security Cooperation Agency
Status: Open

Comments: In February 2019, DSCA noted that it was in the process of conducting "mock" audits of DOD components' use of FMS administrative funds, and that it was undergoing efforts to ensure that a process is in place for the financial review of components' actual spending of these funds. DSCA noted that these efforts were ongoing in October 2019. As of August 2020, we continue to monitor DSCA's ongoing efforts to implement this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA takes steps to work with DFAS and other DOD components, as appropriate, to improve the reliability of the data that DSCA obtains on all DOD components' use of CAS funds, including actual execution data, at an appropriate level of detail, such as by object class. (Recommendation 9)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: In February and May 2019, DSCA informed us that it had taken some steps to implement this recommendation, including establishing an automatic interface with certain DOD components' accounting systems to provide DSCA with daily information and data on those components' actual spending of FMS CAS funds. DSCA noted that it is working toward establishing automatic interfaces for the other components that receive these funds. In October 2019, DSCA informed us that implementation is ongoing. As of August 2020, we continue to monitor DOD's ongoing actions to implement this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of DSCA works with DFAS to conduct regular reconciliations of the data that DSCA collects on DOD components' use of CAS funds, to help ensure that the data are reliable. (Recommendation 10)

Agency: Department of Defense
Status: Open

Comments: In May 2019, DSCA noted that it is undertaking an initiative to incorporate reconciliation capabilities into its oversight of components' use of FMS CAS funds. In October 2019, DSCA informed us that efforts to implement this recommendation are ongoing. As of August 2020, we continue to monitor DOD's actions to implement this recommendation

Recommendation: The Director of DSCA should develop a process for conducting periodic (e.g., quarterly or annual), targeted reviews of DOD components' use of CAS funds, including transactions testing, to verify that actual costs incurred are allowable and approved. (Recommendation 11)

Agency: Department of Defense: Defense Security Cooperation Agency
Status: Open

Comments: In February 2019, DSCA noted that it was in the process of conducting "mock" audits of DOD components' use of FMS CAS funds, and that it was undergoing efforts to ensure that a process is in place for the financial review of components' actual spending of these funds. As of October 2019, DSCA noted that these efforts were ongoing. As of August 2020, we continue to monitor DSCA's ongoing efforts to implement this recommendation.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense (Comptroller), in coordination with the U.S. Army, Air Force, Navy, and Marine Corps, conduct a review of the foreign currency rates used at disbursement to determine whether cost-saving opportunities exist by more consistently selecting cost-effective rates at disbursement. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. As of August 2019, DOD had planned actions to update Volume 6A, Chapter 7 of the Financial Management Regulation (FMR) with guidance on rates for disbursement to ensure all components are utilizing the most cost-effective rates while balancing mission requirements and time required to process transactions. DOD estimates that the FMR revision will be completed by October 31, 2020. Until the revision to the FMR is completed, DOD risks paying more to disburse funds for overseas expenditures than would otherwise be required.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense (Comptroller) analyze realized and projected losses to determine the necessary size of the FCFD account balance and use the results of this analysis as the basis for transfers of unobligated balances to the account. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) partially concurred with this recommendation. However, as of August 2019, DOD had not planned any actions intended to implement this recommendation. According to DOD, projecting foreign currency gains or losses to determine the necessary size of the Foreign Currency Fluctuations, Defense (FCFD) account balance would only be possible if foreign currency rates do not fluctuate. DOD states that if projected gains or losses are used to determine the necessary size of the FCFD account when foreign currency rates are volatile, it would expose the department to additional risk. In our report, we acknowledged the inherent challenge in projecting foreign currency gains or losses. However, we also noted that DOD already projects foreign currency gains or losses as the basis for transfers out of the FCFD account but does not use the same analysis to inform its transfers into the account. Further, DOD has the flexibility to make multiple transfers of funds to the FCFD account in a fiscal year in response to any unforeseen foreign currency fluctuations. Without an analysis of projected losses to determine the necessary size of the account balance, DOD may be maintaining the account at a higher balance than is necessary and losing opportunities to more efficiently use funds.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense (Comptroller) revise the Financial Management Regulation to include guidance on ensuring that data are complete and accurate, including assignment of responsibility for correcting erroneous data in its Foreign Currency Fluctuations Defense (O&M) reports. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. As of August 2019, DOD had planned actions to revise Volume 6A, Chapter 7 of the Financial Management Regulation (FMR) to ensure reporting is complete and accurate and assign responsibilities to DOD components for data correction. DOD estimates that the revision to the FMR will be completed by October 31, 2020. Without updated guidance to ensure that the data that tracks foreign currency gains and losses are complete, DOD and Congress will continue to lack quality information with which to make decisions and exercise stewardship over resources for managing foreign currency fluctuations.

Recommendation: The Secretary of Defense should ensure that the Secretary of the Army develop a plan with timelines for implementing changes to its General Fund Enterprise Business System to accurately record its disbursements, consistent with DOD Financial Management Regulation guidance. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. As of August 2019, DOD had planned actions intended to address the recommendation. Specifically, the Secretary of the Army intended to develop a Systems Change Request for how disbursements are recorded in the General Fund Enterprise Business System to be consistent with DOD's Financial Management Regulation. DOD estimates that the system changes will be complete by the second quarter of FY 2020. Until DOD completes its planned actions to address this recommendation, the Army and DOD will continue to lack accurate information for tracking and helping to manage foreign currency gains and losses.

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

Agency: Department of Homeland Security
Status: Open

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

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

Agency: Department of Homeland Security
Status: Open

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

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open

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

Recommendation: To address control weaknesses and related program-integrity risks we identified in Lifeline, the Chairman of FCC should require Commissioners to review and approve, as appropriate, spending above the budget in a timely manner.

Agency: Federal Communications Commission
Status: Open

Comments: On November 16, 2017, FCC adopted a Notice of Proposed Rulemaking that proposed to adopt a self-enforcing budget mechanism for the Lifeline program. However, as of January 2020, FCC has not yet adopted a decision on this proposal.

Recommendation: To address control weaknesses and related program-integrity risks we identified in Lifeline, the Chairman of FCC should establish time frames to evaluate compliance plans and develop instructions with criteria for FCC reviewers how to evaluate these plans to meet Lifeline's program goals.

Agency: Federal Communications Commission
Status: Open

Comments: According to the FCC as of January 28, 2020, the agency does not currently have a schedule to implement this recommendation.

Recommendation: To address control weaknesses and related program-integrity risks we identified in Lifeline, the Chairman of FCC should develop an enforcement strategy that details what violations lead to penalties and apply this as consistently as possible to all Lifeline providers to ensure consistent enforcement of program violations; the strategy should include a rationale and method for resource prioritization to help maximize the effectiveness of enforcement activities.

Agency: Federal Communications Commission
Status: Open

Comments: FCC's enforcement must remain flexible in order to be responsive to the ever changing variants that Universal Service Fund violations may take. According to the FCC, as with all Commission matters, the Chairman may indicate agency priorities in terms of subject matter, but the Chairman does not dictate which cases the Enforcement Bureau pursues. The Office of the Chairman, in consultation with the Enforcement Bureau, has articulated priorities with respect to enforcement activities in the Lifeline area including, but not limited to: 1. Detection and elimination of willful attempts to defraud the Lifeline Program by claiming support subsidies for ineligible or fictitious subscribers. 2. Detection and elimination of unlawful claims for enhanced support for Tribal areas. 3. Detection and elimination of carrier collections of multiple support subsidies for duplicative subscribers, regardless of the source of duplications. 4. Detection and elimination of carrier failures to de-enroll inactive or ineligible subscribers. The Enforcement Bureau has focused its enforcement efforts in line with these priorities and has taken a number of actions since the publication of GAO-17-538.

Recommendation: To address our findings regarding the USF, the Chairman of FCC should take action to respond to USAC requests for guidance and address pending requests concerning USF contribution requirements to ensure the contribution factor is based on complete information and that USF pass-through charges are equitable.

Agency: Federal Communications Commission
Status: Open

Comments: According to the FCC, the FCC is scheduled to complete implementing this recommendation in December 2021.

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

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

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

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

Agency: Department of Agriculture
Status: Open
Priority recommendation

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

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

Agency: Department of Agriculture
Status: Open
Priority recommendation

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

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

Agency: Department of Agriculture
Status: Open

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

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

Agency: Department of Agriculture
Status: Open
Priority recommendation

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

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

Agency: Department of Agriculture
Status: Open
Priority recommendation

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

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

Agency: Department of Agriculture
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

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

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

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

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

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

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

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

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

Recommendation: In order to improve the accuracy of the information included in the O&M budget justification material submitted to Congress and provide complete information to review the military services' fuel consumption spending requests, the Secretary of Defense should direct the Under Secretary of Defense (Comptroller), in consultation with the military services and DLA, to report complete fuel consumption information to Congress, to include actual and estimated fuel volume and actual O&M base obligations for fuel consumption spending separate from O&M Overseas Contingency Operations obligations. This information could be provided as part of DOD's annual O&M budget justification materials, or through other reporting mechanisms.

Agency: Department of Defense
Status: Open

Comments: DOD non-concurred with this recommendation. As of July 2020, DOD had not taken any action to implement the recommendation. DOD stated that it agreed that including additional fuel consumption detail could be useful information, but that it would be difficult and labor intensive to implement a system to separate base from OCO data for several reasons, including its use of legacy financial management systems that cannot easily distinguish between base and OCO execution data.

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation: To ensure that Congress will have more complete information on DOD's full funding needs for its O&M base budget and to conduct oversight of DOD's use of OCO funds to support base programs and activities, the Secretary of Defense should direct the Office of the Under Secretary of Defense Comptroller to revise its guidance on preparing budget justification materials and execution reports for Congress to require the addition of O&M obligations used for base programs and activities at the level of information presented for each account.

Agency: Department of Defense
Status: Open

Comments: DOD non-concurred with our recommendation. DOD stated in its initial response to our recommendation that there is no legal or administrative subdivision of the O&M appropriation for base and OCO; however, we continue to believe that the recommendation is valid and will follow up annually on the status of the recommendation. As of May 2019, DOD reaffirmed its initial response and has not taken any action to implement our recommendation.

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: In order to more fully implement key practices and meet requirements and to better institutionalize standards and practices, the Secretary of HUD should establish a process and schedule for regularly reviewing, revising, and updating HUD's human capital strategic plan, strategic workforce plan, and succession plan.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In response to our recommendation, HUD developed an internal management calendar and associated standard operating procedures. The purpose of the management calendar is to document recurring processes of program offices across the agency, assist in planning and managing the agency's deliverables to ensure that critical deadlines are met, and provide information on ongoing reporting requirements occurring across the agency. We will determine whether HUD has fully implemented our recommendation when the agency provides documentation showing how the management calendar is used for updating human capital, workforce, and succession plans.

Recommendation: In order to more fully implement key practices and meet requirements and to better institutionalize standards and practices, the Secretary of HUD should establish a process and schedule for reviewing and updating policies and procedures to help ensure that policies and procedures for key management functions remain current and complete.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In response to our recommendation, HUD developed an internal management calendar and associated standard operating procedures. The purpose of the management calendar is to document recurring processes of program offices across the agency, assist in planning and managing the agency's deliverables to ensure that critical deadlines are met, and provide information on ongoing reporting requirements occurring across the agency. We will determine whether HUD has fully implemented our recommendation when the agency provides documentation showing how the management calendar is used for updating policies and procedures for key management functions.

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

Agency: Congress
Status: Open

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

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

Agency: Congress
Status: Open

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

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

Agency: Department of the Interior
Status: Open

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

Recommendation: To help ensure that the department can better achieve business process reengineering and enterprise architecture outcomes and benefits, the Secretary of Defense should utilize the results of our portfolio manager survey to determine additional actions that can improve the department's management of its business process reengineering and enterprise architecture activities.

Agency: Department of Defense
Status: Open

Comments: DOD has made progress implementing the recommendation. Specifically, in January 2017, the department issued a business enterprise architecture improvement plan. The plan was intended to address business enterprise architecture usability and deficiencies in information supporting the investment management process. As part of its planning efforts, the department identified opportunities to address the results of our survey. For example, according to the plan, our survey results were used to identify opportunities for improving management and integration of existing enterprise business processes and investments; assessing duplication early in the analysis phase and finding process and capability reuse across the department; and providing a federated business enterprise architecture information environment and capabilities to discover and exchange information from other sources. The plan included delivering three major capabilities. In October 2019, the office of the Chief Management Officer (CMO) demonstrated its new capabilities to GAO. Further, in October 2019, staff within the office of the CMO were working to move the capabilities to a government-approved host environment, although the office had not yet finalized its plan to do so. As of November 2019, the department had not yet deployed the capabilities.

Recommendation: The Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB, to establish and implement policies and procedures for accounting for and reporting all significant General Fund activity and balances, obtaining assurance on the reliability of the amounts, and reconciling the activity and balances between the General Fund and federal entities.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), this recommendation remained open. Over the past few years, Treasury has made progress by (1) improving the accounting for and reporting of General Fund transactions and balances, (2) working to resolve significant differences between the General Fund and federal entity trading partners, and (3) including differences involving General Fund activity and balances in the quarterly scorecard process. However, significant differences between the General Fund and federal entity trading partners existed as of the end of fiscal year 2019. Also, Treasury continues to work on obtaining audit assurance on the activity and balances. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of the Treasury should direct the Fiscal Assistant Secretary, working in coordination with the Controller of OMB, to establish a formalized process to require the performance of additional audit procedures specifically focused on intragovernmental activity and balances between federal entities to provide increased audit assurance over the reliability of such information.

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of the completion of our fiscal year 2019 audit of the consolidated financial statements of the U.S. government (CFS), this recommendation remained open. Treasury did not perform corrective actions in FY 2019 to address this recommendation. We will follow-up on progress made by Treasury and OMB as part of our fiscal year 2020 CFS audit.

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

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

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

Recommendation: In order to improve NMB's planning and make the most effective use of its limited resources, the Chairman of the National Mediation Board should develop and fully implement key components of an information security program in accordance with the Federal Information Security Management Act of 2002.

Agency: National Mediation Board
Status: Open

Comments: In February 2020, we determined that NMB had taken some steps to further implement key information security practices, but had not fully implemented this recommendation. We reported in GAO-20-236 that NMB continued to only partially follow the eight key information security practices in accordance with the Federal Information Security Management Act (FISMA). NMB must take other steps, such as providing risk assessment documentation of its enterprise network for fiscal year 2019. NMB officials stated that the agency plans to address several of these practices by the end of fiscal year 2020. They further noted that they hired a Chief Information Officer and planned to hire additional staff and employ contractors to aid in these efforts.

Recommendation: In order to improve NMB's planning and make the most effective use of its limited resources, the Chairman of the National Mediation Board should establish a privacy program that includes conducting privacy impact assessments and issuing system of record notices for systems that contain personally identifiable information.

Agency: National Mediation Board
Status: Open

Comments: In February 2020, we reported in GAO-20-236 that NMB had taken some steps to implement information privacy practices, such as designating a privacy officer. However, NMB must take additional steps, such as specifying whether a system of records notice would be developed, as required by the Office of Management and Budget.

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff to strengthen procedures in place to guide Reserve Banks' efforts to manage emergency program access for higher-risk borrowers by providing more specific guidance on how Reserve Bank staff should exercise discretion and document decisions to restrict or deny program access for depository institutions and primary dealers that would otherwise be eligible for emergency assistance.

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: We most recently sought information from the Board of Governors of the Federal Reserve System in July 2018 regarding the status of the recommendation but did not receive any new information. Therefore, the recommendation remains open.

Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff to document a plan for estimating and tracking losses that could occur under more adverse economic conditions within and across all emergency lending activities and for using this information to inform policy decisions, such as decisions to limit risk exposures through program design or restrictions applied to eligible borrowing institutions.

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: We most recently sought information from the Board of Governors of the Federal Reserve System in July 2018 regarding the status of the recommendation but did not receive any new information. Therefore, the recommendation remains open.

Recommendation: While creating control systems at the same time that the emergency programs were being designed and implemented posed unique challenges, the recent crisis provided invaluable experience that the Federal Reserve System can apply in the future should the use of these authorities again become warranted. Going forward, to further strengthen policies for selecting vendors, ensuring the transparency and consistency of decision making involving the implementation of any future emergency programs, and managing risks related to these programs, the Chairman of the Federal Reserve Board should direct Federal Reserve Board and Reserve Bank staff to document the Federal Reserve Board's guidance to Reserve Banks on types of emergency program decisions and risk events that require approval by or consultation with the Board of Governors, the Federal Open Market Committee, or other designated groups or officials at the Federal Reserve Board.

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: We most recently sought information from the Board of Governors of the Federal Reserve System in July 2018 regarding the status of the recommendation but did not receive any new information. Therefore, the recommendation remains open.

Recommendation: To better ensure that requirements for tenant eligibility are met across the FLH portfolio, the Secretary of Agriculture should direct the Administrator of RHS to require its loan servicers to use the Systematic Alien Verification and Entitlements (SAVE) program administered by the Department of Homeland Security to verify tenant's residency status during supervisory reviews.

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, according to officials, USDA has proposed revisions to its regulations that will incorporate the usage of Systematic Alien Verification and Entitlements (SAVE) program. The proposed rule is under interagency review with the Office of Management and Budget. Publication of the final rule is planned to occur in fiscal year 2022 according to USDA officials. We will continue to monitor USDA's progress in implementing our recommendation.

Recommendation: The Secretary of Agriculture should direct the Administrator of RHS to better utilize available data on demand for the FLH program--such as systematically reviewing local market analyses, further analyzing occupancy data on a statewide, regional, or national level, and retaining and analyzing application information--to help target available funding to areas of greatest need.

Agency: Department of Agriculture
Status: Open

Comments: As of May 2020, according to officials, USDA has conducted an analysis of occupancy data and information retained in program applications, to determine how funding can be allocated to better meet market demand, and support community revitalization and affordable housing needs. Officials planned to use the results of this analysis to revise USDA's Farm Labor Housing Notice for Solicitation of Applications. The notice is currently undergoing an internal clearance process, which USDA anticipates completing by fiscal year 2022. We will continue to track the agency's progress on this recommendation.

Recommendation: To ensure that IRS can adequately enforce certain tax provisions, Congress may wish to consider providing IRS with MEA to use tax return information from previous years to ensure that taxpayers do not improperly claim credits or deductions in excess of lifetime limits where applicable.

Agency: Congress
Status: Open

Comments: As of March 2020, Congress has expanded IRS's math error authority in certain circumstances, but not as broadly as GAO suggested in February 2010. Section 208 of division Q of the Consolidated Appropriations Act, 2016 (Public Law 114-113 enacted in December 2015) gave IRS the authority to use math error authority if (1) a taxpayer claimed the Earned Income Tax Credit, Child Tax Credit, or the American Opportunity Tax Credit (AOTC) during the period in which a taxpayer is not permitted to claim such credit as a consequence of either having made a prior fraudulent or reckless claim; or (2) a taxpayer omitted information required to be reported because the taxpayer made prior improper claims of the Child Tax Credit or the AOTC. While expanding math error authority is consistent with what GAO suggested in February 2010, GAO maintains that a broader authorization of math error authority with appropriate controls would enable IRS to correct obvious noncompliance, would be less intrusive and burdensome to taxpayers than audits, and would potentially help taxpayers who underclaim tax benefits to which they are entitled. If Congress decides to extend broader math error authority to IRS, controls may be needed to ensure that this authority is used properly such as requiring IRS to report on its use of math error authority. The Administration also requested that Congress expand IRS's math error authority as part of the Service's Congressional Budget Justification and Annual Performance Report and Plan for fiscal year 2021. Specifically, the Administration requested authority to correct a taxpayer's return in the following circumstances: 1) the information provided by the taxpayer does not match the information contained in government databases or Form W-2, or from other third party databases as the Secretary determines by regulation; 2) the taxpayer has exceeded the lifetime limit for claiming a deduction or credit; or 3) the taxpayer failed to include with his or her return certain documentation that is required to be included on or attached to the return. As of March 2020, the Congress had not provided IRS with such authority.

Recommendation: To address weaknesses in DCOE's strategic plan, the Secretary of Defense, through the Director of TMA, should direct the DCOE director to revisit and revise as necessary the organization's goals for completing statutorily required responsibilities.

Agency: Department of Defense
Status: Open

Comments: As of July 2017, DOD officials have not implemented this recommendation. GAO considers it to be open. We will update the status of this recommendation when we receive additional information.

Recommendation: To address weaknesses in DCOE's strategic plan, the Secretary of Defense, through the Director of TMA, should direct the DCOE director to require the directorates to align their day-to-day activities to support DCOE's mission and goals.

Agency: Department of Defense
Status: Open

Comments: As of July 2017, DOD officials have not implemented this recommendation. GAO considers it to be open. We will update the status of this recommendation when we receive additional information.

Recommendation: To address weaknesses in DCOE's strategic plan, the Secretary of Defense, through the Director of TMA, should direct the DCOE director to improve the performance measures in the plan to enable DCOE to determine if achievement of each measure fully supports attainment of its associated goal.

Agency: Department of Defense
Status: Open

Comments: As of July 2017, DOD officials have not implemented this recommendation. GAO considers it to be open. We will update the status of this recommendation when we receive additional information.

Recommendation: To ensure that DCOE obligations are properly classified and recorded in accordance with OMB guidance, the Secretary of Defense, through the Office of the Assistant Secretary of Defense (Health Affairs) (ASD(HA)), should direct TMA to develop written procedures with detailed steps to be performed for ensuring proper classification and recording of obligations in TMA's financial management systems.

Agency: Department of Defense
Status: Open

Comments: As of July 2017, DOD officials have not implemented this recommendation. GAO considers it to be open. We will update the status of this recommendation when we receive additional information.

Recommendation: To ensure that DCOE obligations are properly classified and recorded in accordance with OMB guidance, the Secretary of Defense, through the ASD(HA), should direct TMA to assign responsibility for updating and maintaining procedural guidance and systems codes to assure consistency with annual OMB guidance.

Agency: Department of Defense
Status: Open

Comments: As of July 2017, DOD officials have not implemented this recommendation. GAO considers it to be open. We will update the status of this recommendation when we receive additional information.

Recommendation: To gain efficiencies and improve taxpayer service, the Commissioner of Internal Revenue should direct the appropriate officials, based on the quality of service provided by comparable organizations and on what matters most to the customer, to determine a customer service telephone standard, and the resources required to achieve this standard based on input from Congress and other stakeholders.

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

Comments: As of August 2019, IRS finalized a customer service strategy identifying an optimal telephone level of service. According to the strategy, IRS has a process to compare major metrics with other agencies and private industry, and conducted two studies to look at industry practices. In response to our recommendation, IRS compared its telephone data with similar telephone environments, and determined that a telephone level of service between 70 and 80 percent provides an optimal balance for servicing customer service telephones and paper correspondence requests. However, IRS faced two significant challenges in managing the 2019 filing season: (1) implementing major tax law changes from the Tax Cuts and Jobs Act (TCJA), and (2) a lapse in appropriations that left IRS unfunded during five weeks leading up to the opening of the 2019 filing season. As a result of issues stemming from these challenges, IRS revised its 2019 filing season telephone service goals from 80 percent to 65 percent during the filing season, and from 75 percent to 63 percent for all of fiscal year 2019. By not maintaining the identified optimal level of service standard, IRS is missing opportunities to illustrate gaps between actual and desired levels of service that may have resulted from issues linked to TCJA implementation and the lapse in appropriations. IRS did outline steps it is taking to achieve the optimal range of 70-80 percent telephone level of service outlined in its customer service strategy. Specifically, IRS said that it is working to upgrade equipment for all IRS business units that provide telephone services to taxpayers. It also cited examples of these upgrades, such as implementing a customer callback system that allows callers to keep their place in queue without remaining on the phone. While IRS said it has allocated funding to begin the development and installation of the customer callback feature, it did not provide an estimate of the resources required to upgrade the equipment and otherwise achieve the optimum range of telephone level of service. By not providing sufficient information to Congress on resources needed to achieve an optimal level of service, IRS is missing opportunities to justify the resources it believes are needed to improve taxpayer service.

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

Agency: Congress
Status: Open

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

Recommendation: To address USPS's financial viability in the short term, Congress may wish to consider providing financial relief to USPS, including modifying its retiree health benefit cost structure in a fiscally responsible manner. Congress may also wish to consider any and all options available to reduce USPS costs, including revising the statutory framework for collective bargaining to ensure that binding arbitration takes its financial condition into account. At the same time, to facilitate making progress in difficult areas, Congress may wish to consider establishing (1) a panel of independent experts, similar to a BRAC-like commission, to coordinate with USPS and stakeholders to develop a package of proposed legislative and operational changes needed to reduce costs and address challenges to USPS's business model and (2) procedures for the review and approval of these proposals by the President and Congress. These proposals could focus on adapting delivery and retail services to declining mail volumes; making postal operations, networks, and workforce more cost-efficient; and generating new revenue.

Agency: Congress
Status: Open

Comments: As of March 2020, Congress has taken no action on this matter.

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

Agency: Congress
Status: Open

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

Recommendation: To provide transparency and accountability over the payments FEMA makes to WYOs for expenses and profits, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to determine in advance the amounts built into the payment rates for estimated expenses and profit.

Agency: Department of Homeland Security
Status: Open

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. FEMA's current payment rates do not explicitly consider WYO insurers' actual expenses and profit. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they were reviewing comments received in response to the July 2019 notice.

Recommendation: To provide transparency and accountability over the payments FEMA makes to WYOs for expenses and profits, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to annually analyze the amounts of actual expenses and profit in relation to the estimated amounts used in setting payment rates.

Agency: Department of Homeland Security
Status: Open
Priority recommendation

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. However, GAO has reported that an annual analysis of the WYO insurers' actual expenses and profit could be regularly performed in relation to FEMA's existing payment methodology. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they would complete an annual analysis of WYO data by the end of fiscal year 2020 and that they were reviewing comments received in response to the July 2019 notice.

Recommendation: To provide transparency and accountability over the payments FEMA makes to WYOs for expenses and profits, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to consider the results of the analysis of payments, actual expenses, and profit in evaluating the methods for paying WYOs.

Agency: Department of Homeland Security
Status: Open

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they were reviewing comments received in response to the July 2019 notice.

Recommendation: To increase the usefulness of the data reported by WYOs to the National Association of Insurance Commissioners (NAIC) and to institutionalize FEMA's use of such data, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to take actions to obtain reasonable assurance that NAIC flood insurance expense data can be considered in setting payment rates that are appropriate, including identifying affiliated company profits in reported flood insurance expenses.

Agency: Department of Homeland Security
Status: Open

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. FEMA can also take actions, in addition to any actions related to the rule, to develop method(s) for obtaining reasonable assurance that NAIC data is accurate and usable for setting payment rates before implementation of a new compensation methodology. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they were reviewing comments received in response to the July 2019 notice.

Recommendation: To increase the usefulness of the data reported by WYOs to the National Association NAIC and to institutionalize FEMA's use of such data, the Secretary of Homeland Security should direct the Under Secretary of Homeland Security, FEMA, to develop comprehensive data analysis strategies to annually test the quality of flood insurance data that WYOs report to NAIC.

Agency: Department of Homeland Security
Status: Open

Comments: According to FEMA officials, FEMA is responding to this recommendation as part of its development of a final rule on WYO compensation practices, required by the Biggert-Waters Act. FEMA can also take actions, in addition to any actions related to the rule, to develop and implement data analysis strategies to annually test the quality of flood insurance data WYO insurers report to NAIC before implementation of a new compensation methodology. FEMA issued an Advance Notice of Proposed Ruling on July 8, 2019 seeking comments by September 6, 2019 regarding possible approaches to incorporating actual flood insurance expense data into the WYO payment methodology. As of February 2020, FEMA officials said that they were reviewing comments received in response to the July 2019 notice.

Recommendation: The Secretary of the Department of Homeland Security should direct FEMA to take steps to ensure that its rate-setting methods and the data it uses to set rates result in full-risk premiums rates that accurately reflect the risk of losses from flooding. These steps should include, for example, verifying the accuracy of flood probabilities, damage estimates, and flood maps; ensuring that the effects of long-term planned and ongoing development, as well as climate change, are reflected in the flood probabilities used; and reevaluating the practice of aggregating risks across zones.

Agency: Department of Homeland Security
Status: Open
Priority recommendation

Comments: In April 2018, FEMA officials told us they had begun to redesign NFIP's risk rating system to help ensure policy rates better reflect the risk of flooding. The redesign, known as Risk Rating 2.0, includes efforts to use catastrophe models, stochastic approaches, and updated map information to better reflect the variation in flood risk. These reforms are also intended to improve how FEMA's rating process accounts for general and specific factors that affect flood probabilities and damage. While FEMA initially announced that new rates for all single-family homes would go into effect nationwide on October 1, 2020, it announced in November 2019 that it would defer implementation to October 1, 2021. FEMA said this would allow it to conduct a comprehensive analysis of the proposed rating structure so as to protect policyholders and minimize any unintentional negative effects of the transition, and that the new implementation date would cover all NFIP policies.

Recommendation: The Secretary of the Department of Homeland Security should direct FEMA to ensure that information is collected on the location, number, and losses associated with existing and newly created grandfathered properties in NFIP and to analyze the financial impact of these properties on the flood insurance program.

Agency: Department of Homeland Security
Status: Open

Comments: As of February 2020, FEMA officials said they had finished identifying properties with grandfathered premium rates and that they planned to analyze their economic implications as part of their efforts to update their premium rate setting approach, known as Risk Rating 2.0. FEMA plans to implement this redesign on October 1, 2021.

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

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

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

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

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

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