Recommendation: The Director of BOP should update its program evaluation plan to set a new timeline for conducting an evaluation of FPI. (Recommendation 1)

Agency: Department of Justice: Bureau of Prisons
Status: Open

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

Recommendation: In order to help promote a meaningful program assessment, the Director of BOP should develop a goal for FPI related to recidivism reduction and measure progress toward meeting that goal.(Recommendation 2)

Agency: Department of Justice: Bureau of Prisons
Status: Open

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

Recommendation: SBA's Associate Administrator for Government Contracting and Business Development should develop a central repository for PCRs to store the supporting documentation for the data they report on their activities. (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: SBA's Associate Administrator for Government Contracting and Business Development should ensure that SBA submits required reports to Congress on PCRs' assignments and activities. (Recommendation 2)

Agency: Small Business Administration
Status: Open

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

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

Agency: Department of Homeland Security
Status: Open

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

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

Agency: Department of Homeland Security
Status: Open

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

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

Agency: Department of Homeland Security
Status: Open

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

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

Agency: Department of Homeland Security
Status: Open

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

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

Agency: Department of Homeland Security
Status: Open

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

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

Agency: Department of Homeland Security
Status: Open

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

Recommendation: GSA should assess and address the reliability of the information used to calculate reported cost savings for the broker program. (Recommendation 1)

Agency: General Services Administration
Status: Open
Priority recommendation

Comments: In June 2020, GSA said the agency would validate system data through regional and broker outreach and fully utilize validated system data to manage the broker program. The agency also said it will develop a quality control plan and follow-up on outcomes. We will continue to monitor GSA's progress with implementing this recommendation.

Recommendation: GSA should develop outcome-based metrics to evaluate the effectiveness of using brokers to supplement the GSA's leasing workforce. (Recommendation 2)

Agency: General Services Administration
Status: Open

Comments: Although GSA initially did not concur with this recommendation, the agency stated in June 2020 that it agrees with the recommendation and will take steps to implement it. Specifically, GSA plans to revise the broker performance standards and document broker effectiveness through lease cost avoidance, timely lease replacement, and earned commission credits. We will continue to monitor GSA's progress with implementing 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 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 Secretary of Veterans Affairs should ensure that the Associate Executive Director of VA's NAC puts controls in place to better ensure the completeness of vendor FSS sales reporting. (Recommendation 1)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: VA concurred with this recommendation and is taking steps to implement it. In August 2020, VA reported that it has taken steps to better ensure the completeness of vendor FSS sales reporting, including by conducting more active monitoring of the sales data submitted by vendors. These steps are ongoing, but NAC has reported a decrease in the number of FSS contractors not reporting sales.

Recommendation: The Secretary of Veterans Affairs should ensure that the Associate Executive Director of VA's NAC assesses data on the participation of and items and services offered by veteran-owned small businesses in NAC's FSS program, in order to determine whether their program is meeting the needs of VHA contracting officers who use it given the Veterans First requirements they must meet. (Recommendation 2)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: VA concurred with this recommendation and is taking steps to implement it. In August 2020, VA reported that NAC has conducted additional outreach to veteran-owned small businesses regarding FSS participation, and plans to conduct analysis of these businesses' participation in FSS by the end of fiscal year 2020.

Recommendation: The Secretary of Veterans Affairs should ensure that the Associate Executive Director of VA's NAC directs the FSS Director to develop a mechanism to consistently obtain and analyze VHA user feedback on the FSS program. (Recommendation 3)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: VA concurred with this recommendation and has taken several actions to more consistently obtain VHA user feedback on the FSS program, including holding meetings with each VHA regional contracting office and participating in VHA integrated project teams and other recurring meetings. We have requested documentation of these activities, but VA has yet to provide it.

Recommendation: The Secretary of Veterans Affairs should ensure that the Associate Executive Director of VA's NAC provides FSS contracting staff with comprehensive FSS guidance. (Recommendation 4)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: VA concurred with this recommendation and NAC reported in August 2020 that it has taken steps to make existing guidance on the FSS program more accessible to FSS contracting staff. We have requested more documentation from VA to confirm that the guidance is comprehensive.

Recommendation: The Secretary of Veterans Affairs should ensure that the Associate Executive Director of VA's NAC develops an FSS-specific training program to include essential skills and processes to meet ongoing training needs for new and existing contracting staff. (Recommendation 5)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: VA concurred with this recommendation and NAC reported in August 2020 that it has implemented additional introductory training for new FSS contracting staff, as well as quarterly training events for all FSS contracting staff. We have requested additional documentation from VA on the content of the quarterly training.

Recommendation: The Administrator of GSA should work with the Secretary of VA to develop a memorandum of understanding outlining the roles and responsibilities of GSA and NAC for collaborating under GSA's delegation of authority to VA for the healthcare-related Federal Supply Schedules, including the processes through which the two organizations will coordinate and share useful tools and practices. (Recommendation 6)

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

Comments: GSA concurred with this recommendation. In August 2020, GSA stated that it has met with VA and agreed to develop an interagency memorandum of understanding by December 2020.

Recommendation: The Secretary of Veterans Affairs should work with the Administrator of GSA to develop a memorandum of understanding outlining the roles and responsibilities of GSA and NAC in collaborating under GSA's delegation of authority to VA for the healthcare-related Federal Supply Schedules, including the processes through which the two organizations will coordinate and share useful tools and practices. (Recommendation 7)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: VA concurred with this recommendation. In August 2020, GSA stated that it has met with VA and agreed to develop an interagency memorandum of understanding by December 2020.

Recommendation: The Administrator of GSA should take steps to document its delegation of authority for the healthcare-related Federal Supply Schedules to VA. (Recommendation 8)

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

Comments: GSA concurred with this recommendation. In August 2020, GSA stated that it is working to develop updated delegation of authority and will provide further details by December 2020.

Recommendation: The Secretary of Veterans Affairs should ensure that the Associate Executive Director of VA's NAC assesses the appropriateness of NAC's current timeliness goals for FSS contract awards and takes steps to comprehensively identify and address barriers to achieving them. (Recommendation 9)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: VA concurred with this recommendation. In August 2020, VA reported that NAC has confirmed that existing timeliness goals are appropriate, and that NAC officials meet on a quarterly basis to discuss barriers to meeting these goals. We have requested more detail from NAC on the barriers they have identified and steps they are taking to address them so that we can assess whether they are comprehensive.

Recommendation: The Secretary of Veterans Affairs should ensure that the Associate Executive Director of VA's National Acquisition Center takes measures to ensure greater efficiency in the offer-intake process, such as providing additional guidance for vendors or by adopting a system that includes checks for completeness of required vendor documentation. (Recommendation 10)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open

Comments: VA concurred with this recommendation. In August 2020, VA reported that NAC has developed a checklist for assessing the completeness of submitted offers, and that new offers are currently processed in an average of two days. NAC is considering adoption of an automated offer intake system. We have requested additional details from NAC on the recent average offer processing time.

Recommendation: The Secretary of Veterans Affairs should take steps to assess duplication between VA's FSS and MSPV programs, to determine if this duplication is necessary or if efficiencies can be gained. (Recommendation 11)

Agency: Department of Veterans Affairs: Office of the Secretary
Status: Open
Priority recommendation

Comments: VA concurred with this recommendation. In August 2020, VA stated that it is analyzing duplication of contracting across the department as part of its Category Management efforts, and expects to complete an internal report on this issue in early 2021.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Acquisition and Sustainment develop and implement a plan to guide and coordinate efforts to implement the Wideband AOA recommendations to support timely, informed decisions on its next wideband satellite communications architecture. (Recommendation 1)

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

Comments: DOD concurred with our recommendation, but as of July 2020 is still working to implement its corrective action plan.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Agency: Environmental Protection Agency
Status: Open

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

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

Agency: Environmental Protection Agency
Status: Open

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

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

Agency: Environmental Protection Agency
Status: Open

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

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

Agency: Environmental Protection Agency
Status: Open

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

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

Agency: Environmental Protection Agency
Status: Open

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

Recommendation: The Office of the Undersecretary of Defense (Comptroller) (OUSD[C]) should include an assessment of risks related to contractor ownership as part of its ongoing efforts to plan and conduct a department-wide fraud risk assessment. As part of this assessment, consistent with leading practices, DOD should involve relevant stakeholders with knowledge of emerging risks and use this information to help inform other types of risk assessments across the department, including for national security concerns. (Recommendation 1)

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

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

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

Agency: Department of the Treasury
Status: Open

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

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

Agency: Department of the Treasury
Status: Open

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

Recommendation: The Secretary of Energy, in coordination with the Administrator of NNSA, should formally communicate to the relevant congressional committees concerns about, and suggested changes to, the enhanced procurement authority in a timely manner. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: NNSA agreed with the recommendation. NNSA officials said they submitted an assessment that includes information on suggested changes to the authority to the congressional committees in March 2020. We requested a copy of the assessment and will update the status of this recommendation after we receive and review it.

Recommendation: The Assistant Secretary of ETA should develop, document, and implement a comprehensive strategy that (1) accounts for Job Corps' projected workload requirements and (2) considers its acquisition workforce needs—including the number of staff, skills, and other supports necessary to plan, award, and monitor Job Corps center contracts—to enable it to effectively plan for and competitively award future Job Corps center contracts. (Recommendation 1)

Agency: Department of Labor: Employment and Training Administration
Status: Open

Comments: DOL stated that it will develop, document, and implement a comprehensive strategy that accounts for Job Corps' projected workload requirements and considers its acquisition workforce needs. DOL noted that it has released a new procurement plan which reflects its decision to re-procure 28 Job Corps centers prior to the final option year of their contract. DOL said that this action would result in each region having no more than five procurements each year, which it considers a manageable procurement workload for its current staffing level. We will consider closing the recommendation when such a comprehensive strategy is implemented.

Recommendation: The FTA administrator should ensure that FTA's cost estimating information for project sponsors is consistent with all 12 steps found in GAO's Cost Estimating and Assessment Guide and needed for developing reliable cost estimates. [Recommendation 1]

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

Comments: As of March 2020, FTA had posted GAO's Cost Estimating and Assessment Guide to its website. However, FTA has yet to update its cost estimating information, which does not align with GAO's best practices in five areas: (1) risk and uncertainty analysis; (2) sensitivity analysis; (3) identifying ground rules and assumptions; (4) obtaining the data; and (5) presenting cost estimates to management. GAO continues to believe that because FTA's cost estimating information does not align with all 12 steps found in GAO's Cost Estimating and Assessment Guide, FTA lacks reasonable assurance that sponsors have developed and communicated high-quality cost estimates. We will continue to monitor FTA's actions.

Recommendation: The FTA Administrator should provide a central, easily accessible source with all of FTA's cost estimating information to help project sponsors improve the reliability of their cost estimates. [Recommendation 2]

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

Comments: As of March 2020, FTA had developed a webpage with some cost estimating information for project sponsors. However, the website did not include key information for project sponsors which FTA had previously provided to GAO for its analysis of cost estimating information. We continue to believe that providing a centralized location to share existing FTA documentation with sponsors, and ensuring that the documentation incorporates best practices from GAO's Cost Estimating and Assessment Guide, such as sensitivity analyses, could improve the reliability of sponsors' cost estimates and could reduce the risk of cost overruns for Capital Investment Grant (CIG) New Starts applicants and grantees. We will continue to monitor FTA's actions to address this recommendation.

Recommendation: The Director, MDA, should utilize additional schedule margin afforded by the EPAA Phase 3 delay to conduct additional testing necessary to thoroughly assess the capabilities and limitations of Phase 3 against IRBMs and a raid scenario prior to delivery. (Recommendation 1)

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

Comments: The Department of Defense partially concurred with this recommendation, stating that all EPAA Phase 3 BMDS functions requiring a flight test environment were already successfully demonstrated and that MDA has addressed the intent of our recommendation by adding ground tests to further assess EPAA Phase 3 Capabilities. However, in order for the agency to meet the full intent of our recommendation, additional flight testing to demonstrate capability against EPAA Phase 3 threats, including intermediate-range threats and raid scenarios, is necessary.

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: To the extent that Congress wants to further encourage federal agencies to use tribal energy sources, it should consider amending the Energy Policy Act of 2005 to provide more specific direction to federal agencies for implementing the tribal energy preference, to include consideration of additional incentives or requirements to use these energy sources. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: We will provide updated information when we confirm what steps Congress has taken related to this matter.

Recommendation: The Principal Deputy Assistant Attorney General for OJP should consistently document CEBR program-wide goals to clarify intended program results. (Recommendation 1)

Agency: Department of Justice: Office of Justice Programs
Status: Open

Comments: In September 2019, OJP reported that it is building a logic model for the CEBR program that will provide the basis for addressing this recommendation. According to OJP, this logic model will more clearly align CEBR program goals and objectives with permitted program activities and associated performance measures. OJP had originally planned to finalize this logic model by March 2020 and share it--including any resulting changes in how program goals are articulated--with the CEBR stakeholder community in advance of the fiscal year 2021 grant cycle, beginning October 1, 2020. In June 2020, OJP reported that the CEBR program was transferred from OJP's National Institute of Justice to OJP's Bureau of Justice Assistance. As a result, OJP reported that plans to finalize and communicate the CEBR logic model have been postponed. GAO will follow-up with OJP in the winter of 2020-2021 to obtain documentation on the logic model and how they are communicating it. This will enable GAO to determine if the model--and OJP's efforts to communicate it to stakeholders--meets the intent of the recommendation by consistently documenting CEBR program-wide goals and clarifying intended results.

Recommendation: The Principal Deputy Assistant Attorney General for OJP should ensure that performance measures for each CEBR program-wide goal fully reflect appropriate attributes of successful performance measures. (Recommendation 2)

Agency: Department of Justice: Office of Justice Programs
Status: Open

Comments: In September 2019, OJP reported that it is reviewing each CEBR program performance measure as part of its process for creating a CEBR program logic model. According to OJP, the purpose of this review is to ensure the measures are meaningful and have the right attributes. In June 2020, OJP reported that, as appropriate, updated performance measures will be included in the fiscal year 2021 CEBR grant program solicitation--which they anticipate releasing in early 2021. GAO will follow-up with OJP in the spring of 2021 to obtain documentation of changes to performance measures, and to determine whether updated performance measures meet the intent of the recommendation.

Recommendation: The Principal Deputy Assistant Attorney General for OJP should document which employee positions have been delegated certification (final signature) authority for confidential financial disclosure reports and specify required levels of review and approval. (Recommendation 3)

Agency: Department of Justice: Office of Justice Programs
Status: Open

Comments: In June 2020, OJP provided a memo sent by the Principal Deputy Assistant Attorney General for OJP to OJP components, dated March 2020. This memo states that supervisors are to review and sign reports, and notes that secondary supervisors may review and sign reports as Final Reviewing Officials, but it is not mandatory. This is a positive step, but does not fully meet the intent of the recommendation because it is not clear if immediate supervisors have been delegated final signature authority. Specifically, there are two places for signature on the reports (1) "Signature and Title of Supervisor/Other Intermediate Reviewer," and (2) "Signature and Title of Agency's Final Reviewing Official" (certification). According to Office of Government Ethics' regulation and guidance, review and signature of a supervisor or other intermediate reviewer is optional, but review and signature of a Final Reviewing Official-who has been delegated authority to certify reports-is required. OJP's memo states that secondary supervisors may sign as Final Reviewing Officials (i.e. have been delegated this authority), but OJP's memo is not clear if immediate supervisors have also been delegated authority to certify reports as Final Reviewing Officials. To address this discrepancy and enable GAO to close this recommendation as "implemented," OJP needs to clarify who has been delegated authority to certify reports as Final Reviewing Officials.

Recommendation: The Principal Deputy Assistant Attorney General for OJP should (1) clarify its guidance to grantees to specify what their requirements are under 28 C.F.R. pt. 69 with regard to obtaining lobbying certification documents, and obtaining and forwarding to OJP lobbying disclosure forms, from tiers beneath them; and (2) design a control to follow-up with grantees to help ensure they are meeting these requirements. (Recommendation 4)

Agency: Department of Justice: Office of Justice Programs
Status: Open

Comments: In September 2020, OJP reported that it plans to (1) issue guidance to all OJP funding recipients to remind them of lobbying disclosure requirements and provide instructions for how to submit the disclosures, and (2) implement an updated in-depth monitoring checklist whereby OJP can ensure applicable lobbying disclosure forms are collected and submitted to OJP. OJP stated that it plans to take these steps by October 1, 2020. GAO will follow-up in late 2020 to obtain and review all relevant documentation and ensure that these steps meet the intent of the recommendation.

Recommendation: The Commandant of the Coast Guard should direct program managers to establish shore infrastructure performance goals, measures, and baselines to track the effectiveness of maintenance and repair investments and provide feedback on progress made. (Recommendation 2)

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

Comments: The Coast Guard concurred with this recommendation and said it would take steps to implement it. As of April 2020, the Coast Guard continues to develop and refine its shore infrastructure measures with associated goals and estimates that it will complete these efforts in December 2020. When we confirm actions the Coast Guard has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commandant of the Coast Guard should work with Congress to develop and implement a process to routinely align Coast Guard's shore infrastructure portfolio with mission needs, including by disposing of all unneeded assets. (Recommendation 3)

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

Comments: The Coast Guard concurred with this recommendation and said it would take steps to implement it. As of April 2020, the Coast Guard continues work to establish a formalized process to assess current and projected operational and mission support needs to identify and recommend disposal of unneeded land, buildings, and structures. The Coast Guard anticipates completing these efforts by December 2020. When we confirm actions the Coast Guard has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commandant of the Coast Guard should establish guidance for planning boards to document inputs, deliberations, and project prioritization decisions for infrastructure maintenance projects. (Recommendation 4)

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

Comments: The Coast Guard concurred with this recommendation and said it would take steps to implement it. As of April 2020, the Coast Guard is reviewing its existing guidance for planning boards and expects to complete these efforts in December 2020. When we confirm actions the Coast Guard has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commandant of the Coast Guard should employ models for its asset lines for predicting the outcome of investments, analyzing trade-offs, and optimizing decisions among competing investments. (Recommendation 5)

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

Comments: In 2019, GAO reported that the Coast Guard generally has not employed models for predicting the outcome of maintenance investments and optimizing among competing investments, as called for in leading practices. GAO found that, in one instance, the Coast Guard used a model to optimize maintenance for its aviation pavement and, according to Coast Guard officials, found that it could save nearly $14 million by accelerating investment in this area (e.g., paving runways) sooner rather than deferring such maintenance. Coast Guard officials told GAO that such modeling could be applied within and across all of its shore infrastructure asset types, but the Coast Guard did not implement the results of this model and does not require their use. Employing models to predict the future condition and performance of facilities could potentially identify and achieve cost savings, according to leading practices. The Coast Guard concurred with GAO's recommendation that it employ models for its asset lines for predicting the outcome of investments, analyzing trade-offs, and optimizing decisions among competing investments. As of January 2020, the Coast Guard has not employed models to evaluate its asset lines. Instead, the Coast Guard reported that it is evaluating alternative models for its asset lines, and estimated that the Coast Guard will complete this analysis by December 31, 2020.

Recommendation: The Commandant of the Coast Guard should include supporting details about competing project alternatives and report trade-offs in Congressional budget requests and related reports. (Recommendation 6)

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

Comments: In February 2019, GAO reported that Coast Guard budget requests did not provide Congress with accurate information about its funding needs. Specifically, we found that the Coast Guard did not meet this leading practice as its budget requests (1) have not clearly identified funding allotted for routine shore infrastructure maintenance needs, and (2) have not generally addressed deferred maintenance and repair deficiencies, resulting in increases to its backlogs. Specifically, GAO found that budget requests related to shore infrastructure for fiscal years 2012 through 2019 did not provide Congress with required and complete information, as previously noted, necessary to inform decision-makers of the risks posed by untimely investments in maintenance and repair backlogs. GAO also reported that the Coast Guard annual Unfunded Priorities List does not clearly articulate prioritization decisions, including information about trade-offs among competing project alternatives, as well as the impacts on missions conducted from shore facilities in disrepair that had not been prioritized in previous years, or is it aligned with its requirements-based budget targets for shore infrastructure. DHS concurred with GAO's recommendation that the Coast Guard include supporting details about competing project alternatives and report trade-offs in Congressional budget requests and related reports. In its August 2019 180-day letter response, DHS stated that the Coast Guard Office of Budget and Programs will include additional information in the future Unfunded Priorities Lists. However, when the Coast Guard released its 2020 Unfunded Priorities List to Congress it did not contain additional details on competing priorities. GAO will continue to monitor Coast Guard budget requests and related reports, including the Unfunded Priorities Lists, for additional supporting details about competing project alternatives and trade-offs

Recommendation: The Director of the Office of Management and Budget should instruct the Office of Federal Procurement Policy: (1) To facilitate additional training to improve the understanding of the contracting workforce regarding the Buy American Act requirements; and (2) To facilitate clarifying revisions to FPDS-NG, where needed, and provide training and guidance for recording Buy American Act information in FPDS-NG to improve the accuracy of the Buy American data. (Recommendation 1)

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

Comments: The Office of Federal Procurement Policy (OFPP) within OMB concurred with our recommendation, noting that it plans to coordinate with federal agencies on the extent to which they have developed training and guidance. Based on this information, OFPP will work with agencies to determine the most appropriate course of action to address gaps, if any. As of August 2020, OFPP stated that it had not taken any additional actions to implement the recommendation because it is currently focused on implementing Executive Order 13881 "Maximizing Use of American-Made Goods, Products and Materials".

Recommendation: The Secretary of Veterans Affairs should clarify existing guidance, or provide training or other instruction, to help contracting officials: (1) Address the applicability of the Buy American Act requirements and provide instruction on how to implement the requirements, including in any training developed to implement the Veterans First policy; (2) Identify the factors that should be considered in order to determine the applicability of the Trade Agreements Act and waiver of the Buy American Act; and (3) Identify sources of information available for determining products' origins and the steps they should take to verify information that is inconsistent. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: The Department of Veterans Affairs (VA) concurred and has since taken action to address some of our three-part recommendation. For example, VA revised its "Procurement Policy Memorandum 2017-12", on April 9, 2019, to better clarify its existing Buy American Act guidance and highlight key factors contracting staff should consider when determining the applicability of Buy American Act exceptions and waivers. Additionally, in October 2019, VA provided GAO briefing slides for a new training to be offered at the agency's acquisition academy that includes specific instruction pertaining to the use of Buy American Act exceptions and waivers. However, VA has yet to address our recommendation that the agency clarify guidance or provide training to help contracting officers identify sources of information regarding product origin and the steps to be taken to verify inconsistent product origin information. We plan to keep this recommendation open until VA implements guidance or training of this nature and we are able to assess the extent to which it fully addresses our recommendation.

Recommendation: The Secretary of Health and Human Services should provide guidance, training, or other instruction to help contracting officials: (1) Identify the factors that should be considered in order to determine the applicability of the Trade Agreements Act and waiver of the Buy American Act; (2) Document determinations of the use of Buy American exceptions for domestic non-availability and ensure the required approvals are obtained; and (3) Identify sources of information available for determining products' origins and the steps they should take to verify information that is inconsistent. (Recommendation 4)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS concurred with this recommendation and has taken steps to implement it. HHS issued a memorandum in February 2019 requiring all contracting officers as part of their continuous learning program to complete the Buy American Statute course, FAC063, offered by the Federal Acquisition Institute. As of February 2020, about 90 percent of contracting officials had taken the required training. However, due to its COVID-19 Pandemic response activities, HHS stated that all of its contracting officials had not completed the training as intended. HHS also developed checklists and guidance related to the Buy American Act and Trade Agreements Act. We plan to keep this recommendation open until HHS completes its training initiative.

Recommendation: FEMA's Administrator should update the strategy identified in its 2007 Advance Contracting of Goods and Services Report to Congress to clearly define the objectives of advance contracts, how they contribute to FEMA's disaster response operations, and whether and how they should be prioritized in relation to new post-disaster contract awards. (Recommendation 1)

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

Comments: FEMA agreed with this recommendation. In February 2020, FEMA updated its Disaster Contracting Desk Guide to more clearly identify what advance contracts are and how they should be used in relation to post-disaster contracts. Additionally, in July 2020, FEMA officials stated that they had initiated efforts to draft an advance contract strategy as part of FEMA's policy development process. According to FEMA officials, the directive will outline an agency-wide process for identifying and establishing advance contracts, and encourage the maximum use of advance contracts. The officials anticipate completing the directive by January 2021.

Recommendation: The Administrator of General Services should take steps to improve agency-wide monitoring of exchange/sale activities within GSA by specifying the Office of Administrative Services' responsibilities and by defining the scope of its authority. (Recommendation 2)

Agency: General Services Administration
Status: Open

Comments: As of February 2020, GSA developed and distributed a Standard Operating Procedure that established the Office of Administrative Services as having jurisdiction and program oversight for all internal agency exchange/sale transactions. GSA's Office of Administrative Services had also taken steps to coordinate with other GSA offices to coordinate annual exchange/sale data reporting for the agency. We will continue to monitor GSA's actions in addressing the recommendation.

Recommendation: The VA's Deputy Assistant Secretary of Acquisition and Logistics, in collaboration with the Veterans Health Administration's Office of Procurement and Logistics, should revise VA's policy to include details on the exchange/sale authority, particularly those related to monitoring by Regional Offices and use of the authority for medical centers, and establish time frames with milestones for communicating such information. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: As of February 2020, VA's Office of Acquisition and Logistics, in conjunction with Veterans Health Administration's Procurement and Logistics Office, was working on updating the status of two policy notices to amend existing policy to include details on the exchange/sale authority and to collect data on exchange/sale usage within the agency as a basis for reviewing progress and compliance with VA utilization officers. We will continue to monitor the status of VA's actions to address our recommendation.

Recommendation: The Secretary of Defense should ensure that the Director, Defense Pricing and Contracting , addresses how contracting officials using the LPTA process should apply the Section 813 criterion regarding procurement for goods that are predominantly expendable in nature, nontechnical, or have a short life expectancy or shelf life as revisions to the Defense Federal Acquisition Regulation Supplement (DFARS) are considered. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation and issued supplemental guidance in September 2019. The guidance does not clarify what goods qualify as being predominantly expendable in nature, nontechnical, or have a short life expectancy or shelf life. It states contracting officers should check with the requiring activity to make this determination. However, since there is no clear definition of these terms, requiring activities will not have any better insight how to apply this criterion than contracting officers. We maintain that DOD needs to clarify how these terms should apply to goods..

Recommendation: The Secretary of Defense should ensure that the Director, Defense Pricing and Contracting addresses how contracting officials using the LPTA process should apply the Section 813 criterion regarding full life-cycle costs, including for operations and support as revisions to the DFARS are considered. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation and issued supplemental guidance in September 2019. This guidance states it is up to the requiring activity to document that the lowest price reflects the full life cycle costs. However, through our work it was unclear to those we interviewed how to determine a full life cycle costs for services. The guidance cites DoD Instruction 4140.01, DoD Supply Chain Material Management Policy for further guidance on how to determine life cycle costs for services. This policy does not clarify how life cycle costs should be applied to services. We maintain that DOD needs to clarify how this requirement should be implemented by contracting officers as the guidance issued does not do this.

Recommendation: The SBA Administrator or her designee should complete the design and implementation of a comprehensive evaluation of the Small Business Procurement Scorecard aligned with key attributes of effective program evaluations to assess the effectiveness of the revised scorecard in measuring agency performance and promoting small business procurement opportunities. (Recommendation 1)

Agency: Small Business Administration
Status: Open

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

Recommendation: The SBA Administrator or her designee should institute a process to review Small Business Procurement Scorecards for accuracy prior to publication and a mechanism for publicly identifying when issued scorecards have been revised. (Recommendation 2)

Agency: Small Business Administration
Status: Open

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

Recommendation: The Secretary of Veterans Affairs should ensure that VA's Director of the Office of Acquisition and Logistics, in consultation with VA's Office of Small and Disadvantaged Business Utilization, takes measures to ensure that VA contracting staff adhere to the requirements for documenting the required Vendor Information Pages searches in contract files. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and is taking steps to implement it. In August 2020, VA reported that it was beginning a process to update its contracting system to automate the inclusion of documentation of Vendor Information Pages searches in contract files. VA is also now tracking compliance rates. VA plans to provide GAO an update in fall 2020.

Recommendation: The Secretary of Veterans Affairs should ensure that the Director of the Office of Acquisition and Logistics conducts a fraud risk assessment for the Veterans First program. (Recommendation 5)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and is taking steps to implement it. In August 2020, VA provided GAO with a draft fraud risk assessment, and also reported that it is developing measures to mitigate identified risks. VA has not yet provided a date by which it plans to finalize its risk assessment and risk mitigation measures.

Recommendation: The Secretary of Veterans Affairs should ensure that the Director of the Office of Acquisition and Logistics directs the Risk Management and Compliance Service to share, through guidance, training, or other methods, subcontracting limitation risks and monitoring practices with contracting officers and their management. (Recommendation 6)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and is taking steps to implement it. In August 2020, VA provided draft lists of subcontracting limitations risks, as well as draft monitoring guidance and tools. After these items are finalized, VA plans to post them on a portal accessible to all VA contracting staff, but has yet to provide a date by which it expects to take this step.

Recommendation: The Secretary of the Navy should: assess why reverse auctions that are conducted using existing contract vehicles have only one bidder at higher rates than reverse auctions conducted on the open market; determine what factors indicate that conducting reverse auctions is appropriate when using existing contract vehicles; and provide this information to contracting officials so that they can consider it when developing their acquisition strategies.(Recommendation 4)

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

Comments: DOD agreed with this recommendation and stated that the department expected to complete actions to address it by the end of calendar year 2018. In August 2019, Navy officials told us that they had reviewed data on reverse auctions to determine a root cause of single bidders, and describing the factors that indicate that conducting a reverse auction are appropriate. However, they had not yet provided this information to contracting officials as of July 2020.

Recommendation: The Secretary of the Navy should: document and provide information to contracting officials that describes available reverse auction providers and platforms, and any associated fee structures; and provide guidance, as appropriate, to contracting officials to ensure that they compare the options that are available to them when considering whether to use reverse auctions. (Recommendation 6)

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

Comments: DOD agreed with this recommendation and stated that the department expected to complete actions to address it by the end of calendar year 2018. In August 2019, Navy officials stated that memorandum of understanding with reverse auction providers, including fee information, are distributed to contracting officials. However, as of August 2020, they had not provided us with evidence that they had distributed a memorandum related to the primary reverse auction provider currently used by the Navy.

Recommendation: The Secretary of Defense should direct the F-35 program office to resolve all critical deficiencies before making a full-rate production decision. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation and stated that critical deficiencies would be resolved before full-rate production, due in December 2019. In May 2020, we reported that DOD delayed its full-rate production decision from December 2019 to between September 2020 and March 2021.

Recommendation: The Secretary of Defense should direct the F-35 program office to identify what steps are needed to ensure the F-35 meets reliability and maintainability requirements before each variant reaches maturity and update the Reliability and Maintainability Improvement Program with these steps. (Recommendation 2)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with our recommendation. According to a DOD official, as of July 2020, the F-35 program office is in the process of revising its plan for improving the F-35's reliability and maintainability.

Recommendation: The Secretary of Agriculture should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 3)

Agency: Department of Agriculture
Status: Open

Comments: The agency concurred with our recommendation, and in June 2018, USDA CIO delegated the review and approval of acquisition plans and strategies to the Capital Planning and Information Technology Governance Division (CPITGD) through the Associate CIO of the Information Resource Management Center. However, as of June 2020, the agency had not provided evidence to demonstrate that these reviews and approvals are taking place as required by OMB's guidance. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of Commerce should ensure that the office of the CAO is involved in the process to identify IT acquisitions. (Recommendation 4)

Agency: Department of Commerce
Status: Open

Comments: In a March 2018 response to our report, the agency agreed with our recommendation and stated that the CIO and the Senior Procurement Executive will issue a memo to their acquisition and CIO member offices clarifying the offices joint responsibilities to ensure that all IT acquisitions are submitted to the CIO for review and approval. The memo is also to provide guidance on the process by which the CIO will review proposed contract actions. However, as of February 2020, the agency had not responded to requests for updates. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of Commerce should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 5)

Agency: Department of Commerce
Status: Open

Comments: In a March 2018 response to our report, the agency agreed with our recommendation and stated that it intended to clarify its policies and procedures to comply with OMB rules, including the IT acquisition checklist, which must be completed for every proposed contract action. In addition, the CIO and Senior Procurement Executive will work together to review existing acquisition plan review and approval processes. However, as of February 2020, the agency had not responded to requests for updates. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of HHS should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 10)

Agency: Department of Health and Human Services
Status: Open

Comments: The agency agreed with our recommendation and in an April 2018 update stated that HHS has a policy for the HHS IT acquisition review process for acquisition strategies. However, as of February 21, 2020, the agency had not provided evidence that the CIO (or designee) was reviewing and approving IT acquisition plans, as required. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of State should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 22)

Agency: Department of State
Status: Open

Comments: The agency agreed with our recommendation, and in a December 2019 update provided information on the agency's CPIC process and a template for IT acquisition strategies. However, it is not clear whether the CIO is reviewing and approving IT acquisitions plans through the CPIC process and the template does not provide a place for the CIO review and approval. In addition, we have requested evidence of CIO approval of selected IT acquisitions. We will continue to monitor the implementation of this recommendation

Recommendation: The Secretary of the Treasury should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 23)

Agency: Department of the Treasury
Status: Open

Comments: The agency did not state whether it agreed or disagreed with the recommendation. In March 2019, Treasury issued a memo that requires the CIO to review and approve IT acquisition plans for acquisitions with a total value of $68 million or more, or for actions with a period of performance longer than 5 years. The review and approval of all other IT acquisition plans are delegated to the component CIOs or Chief Technology Officers. However, the agency had not yet provided evidence that the CIO (or designee) was reviewing and approving selected IT acquisition plans, as required. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of Transportation should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 26)

Agency: Department of Transportation
Status: Open

Comments: The agency concurred with the recommendation. In October 2019, Transportation issued guidance requiring that the CIO or designee to review and approve all IT acquisition plans. We have requested that the agency provide us evidence of CIO-approved IT acquisition plans. The agency stated that it planned to respond by May 15, 2020. We will continue to monitor the implementation of this recommendation.

Recommendation: The Secretary of VA should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 28)

Agency: Department of Veterans Affairs
Status: Open

Comments: The agency concurred with the recommendation. In November 2019, VA issued guidance that requires the CIO, in conjunction with the Chief Acquisition Officer, to review and approve all IT acquisition strategies and plans. Specifically, the CIO is to review and approve IT acquisitions valued at $15 million or more. The CIO has delegated the review and approval of IT acquisitions less than $15 million to other designees, based on the value of the contract. However, the agency had not provided evidence that the CIO (or designee) was reviewing and approving selected IT acquisition plans, as required. We will continue to monitor the implementation of this recommendation.

Recommendation: The Administrator of NASA should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 32)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: The agency concurred with the recommendation, and in September 2017, NASA's CIO delegated the review and approval authority of IT acquisitions to the Center CIOs. We have requested evidence of CIO-approved IT acquisitions. We will continue to monitor the implementation of this recommendation.

Recommendation: The Director of the Office of Personnel Management should ensure that IT acquisition plans or strategies are reviewed and approved according to OMB's guidance. (Recommendation 34)

Agency: Office of Personnel Management
Status: Open

Comments: The agency concurred with the recommendation and in an April 2020 updated stated that OPM has contracted with a third-party vendor to evaluate the OPM IT human capital, architecture, and governance processes from planning to acquisition to implementation. The agency further stated that it is working to fully implement an IT governance process where the OPM CIO fully reviews and approves IT acquisition plans and processes. We will continue to monitor the implementation of this recommendation.

Recommendation: To enhance management attention to closing out contracts, the Secretary of Health and Human Services should develop a means for department-wide oversight into components' progress in meeting their goals on closing contracts and the status of contracts eligible for closeout. (Recommendation 2)

Agency: Department of Health and Human Services
Status: Open

Comments: The Department of Health and Human Services agreed with the recommendation and has developed a template and instructions for quarterly reporting from its divisions. The Department identified some performance measures that it will monitor on a quarterly basis, such as contracts closed on time and total backlog. Due to competing priorities and focus on the COVID-19 response, the Department plans to provide additional steps toward progress at the next reporting cycle.

Recommendation: To enhance management attention to closing out contracts, the Attorney General should direct the Senior Procurement Executive to ensure the development of a means to track data on the number and type of contracts eligible for closeout and where the contracts are in the closeout process, as well as a means to assess--at the agency or component level--progress by establishing goals and performance measures for closing contracts. (Recommendation 4)

Agency: Department of Justice
Status: Open

Comments: The Department of Justice agreed with the recommendation and in early fiscal year 2020 enhanced its financial management system to allow the Bureaus to assess whether a contract needs to be closed out. The Department anticipates that the associated guidance, which includes performance measures, will be issued in late summer 2020.

Recommendation: To enhance management attention to closing out contracts, the Secretary of State should develop a means at the agency level to track data on the entirety of the number and type of contracts eligible for closeout, where the contracts are in the closeout process, and establish goals and performance measures for closing contracts. (Recommendation 5)

Agency: Department of State
Status: Open

Comments: The Department of State agreed with the recommendation and is upgrading its system to improve data quality and enable the tracking and sharing of contract closeout information. The enhancements to the contracting system would allow the Department to establish a baseline and develop metrics to measure progress on closing contracts. The Department anticipates that the upgrades and data utilization will continue into fiscal year 2021.

Recommendation: The U.S. Trade Representative should, with appropriate experts in Commerce, OMB, and GSA, improve the U.S. methodology for providing federal government procurement statistics to the WTO to ensure both accurate and more timely reporting, consistent with GPA requirements--for example, by providing preliminary estimates and updated values of covered federal procurement or by using an alternative methodology that bases measures of covered government procurement on actual annual obligations, if USTR determines that such an approach is consistent with WTO obligations.

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

Comments: In February 2017 we reported that the United States had revised its approach to statistical reporting to the World Trade Organization (WTO) about covered federal government procurement from an "award values" methodology to an actual "cumulative obligations" approach in October 2015. The "cumulative obligations" methodology resulted in a more accurate measure of covered federal procurement, but it introduced a 6-year delay in reporting. We found this reporting delay inconsistent with the 2014 WTO Agreement on Government Procurement (GPA) requirement of reporting within 2 years of the end of the reporting period. We recommended that the U.S. Trade Representative (USTR) should, with appropriate experts in Commerce, Office of Management and Budget, and General Services Administration, improve the U.S. methodology for providing covered federal government procurement statistics to the WTO to ensure both accurate and more timely reporting, consistent with GPA requirements--for example, by providing preliminary estimates and updated values of covered federal procurement or by using an alternative methodology that bases measures of covered government procurement on actual annual obligations, if USTR determines that such an approach is consistent with WTO obligations. Following the issuance of our report, in December 2017 USTR reported that they had worked with other agencies to improve their methods. While they decided to continue to report statistics using the "cumulative obligations" methodology they decided to also report "partially reported" (preliminary) statistics to improve the timeliness of U.S. reporting. This preliminary data was to be based on the same data used in the "cumulative obligations" methodology but can be submitted within two years of the end of the reporting period and therefore comply with GPA statistical reporting obligations. USTR submitted preliminary statistics for FY 2015 on November 15, 2017; for FY 2016 on October 31, 2018; and for FY 2017 on October 29, 2019. USTR will later update these statistics to reflect the "final" total value in 2021. GAO will continue to monitor this recommendation until that time.

Recommendation: To ensure that DOE's control activities continue to be relevant and effective for managing supply chain risk, the Secretary should direct the Under Secretary for Nuclear Security, as the Administrator of the NNSA, to work with the Office of Intelligence and Counterintelligence and other DOE organizations, as appropriate, to assess the circumstances that might warrant using the enhanced procurement authority, and (1) if this assessment identifies circumstances that might warrant using the authority, the Secretary should direct the Under Secretary for Nuclear Security to work with other DOE organizations, as appropriate, to establish processes for using it and examine whether adequate resources are in place to support those processes, and (2) communicate the results of this assessment to the relevant congressional committees for their use in determining whether to extend the authority past its current termination date.

Agency: Department of Energy
Status: Open

Comments: In an October 7, 2016, letter the Under Secretary for Nuclear Security and Administrator of the National Nuclear Security Administration (NNSA) said he agreed with GAO's recommendation to assess situations that might warrant the use of the enhanced procurement authority and, should specific circumstances be identified for use of the authority, NNSA would develop a process for its use. The assessment would include an examination of resources to support use of the authority. NNSA would work with other Department of Energy organizations as appropriate in conducting the assessment. NNSA officials said they submitted the assessment to the congressional committees in March 2020. We requested a copy of the assessment and will update the status of this recommendation after we receive and review it.