Recommendation: The Undersecretary for Health should consistently collect sexual orientation data in VHA's health record system, which could include adding a field for providers to input veterans' sexual orientation. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Undersecretary for Health should analyze veterans' sexual orientation data in order to assess health care outcomes for lesbian, gay, and bisexual veterans. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Undersecretary for Health should consistently collect veterans' self-identified gender identity data within and across record systems. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Undersecretary for Health should analyze veterans' self-identified gender identity data in order to assess health care outcomes for transgender veterans. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: 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: The Administrator of FEMA should plan and conduct regular fraud risk assessments of PA emergency work grants to determine a fraud risk profile that aligns with leading practices as provided in the Fraud Risk Framework. Specifically, this process should include (1) identifying inherent fraud risks to PA grant funds, (2) assessing the likelihood and impact of inherent fraud risks, (3) determining fraud risk tolerance, (4) examining the suitability of existing fraud controls, and (5) documenting the fraud risk profile. (Recommendation 1)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
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 FEMA should designate one entity as the lead entity with responsibility for providing oversight of agency-wide efforts to manage fraud risks to PA emergency work grants, including managing the fraud risk assessment process, consistent with leading practices. (Recommendation 2)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
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 FEMA should update key training and guidance documents for the PA grant program to include information on where and how to report suspected fraud, and direct PA recipients to include such information in key training and guidance documents they provide to subrecipients. (Recommendation 3)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
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 FEMA should update key resources, such as training and guidance documents, FEMA makes available to PA applicants to ensure these resources consistently communicate information on the highest fraud risks to PA emergency work grant funds and applicants' responsibilities for managing those risks. The highest fraud risks may include risks related to procurement and debris removal, and other risks FEMA identifies through fraud risk assessments. (Recommendation 4)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
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 FEMA should implement program-specific antifraud training for PA staff who work directly with PA applicants; this training should include information on the highest fraud risks to PA emergency work grants. The highest fraud risks may include risks related to procurement and debris removal, and other risks FEMA identifies through fraud risk assessments. (Recommendation 5)

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

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

Recommendation: The Under Secretary for Health should ensure the RCS Chief Officer evaluates Vet Center productivity expectations for counselors, including (1) obtaining systematic feedback from counselors on any potentially negative effects on client care, and (2) determining whether directors and counselors need additional training or guidance on how the expectations are calculated. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should ensure the RCS Chief Officer develops a plan and time frames for periodically reassessing its productivity expectations for counselors, and implementing any needed changes as appropriate. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should ensure the RCS Chief Officer develops and implements a Vet Center staffing model that incorporates key practices in the design of staffing models. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should ensure the RCS Chief Officer establishes a plan and time frames for assessing and updating its staffing model regularly, and for implementing any needed changes as warranted. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary of Defense (Comptroller) should, in collaboration with the Under Secretary of Defense (Acquisition and Sustainment), develop and implement a DOD-wide strategy to remediate real property asset control issues. (Recommendation 1).

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and stated that it was committed to placing increased leadership emphasis on real property asset controls to ensure mission readiness, audit readiness, testing for existence and completeness, and maintaining internal controls.

Recommendation: The Under Secretary of Defense (Comptroller) should, in collaboration with the Under Secretary of Defense (Acquisition and Sustainment), develop department-wide instructions for performing the E&C verifications. (Recommendation 2).

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and stated that it was committed to placing increased leadership emphasis on real property asset policies and instructions to ensure consistent and repeatable existence and completeness verifications.

Recommendation: The Secretary of VA should improve the completeness and accuracy of use of force data in Report Executive by addressing (1) incomplete categorization of the type of force used, (2) inaccurate data on the highest level of force used, and (3) the potential for duplicate data entries. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Secretary of VA should implement plans to include analytical features in Report Executive that will position the agency to analyze use of force data at VA medical centers nationwide, including by officer; type of force used; and facility, among other variables. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Secretary of VA should ensure that medical centers submit records of all locally initiated use of force investigations and any resulting disciplinary action to VA headquarters office(s) with responsibility for police oversight. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Secretary of VA should implement plans for obtaining a quality database to collect all locally initiated use of force investigations at medical centers. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: Once positioned to do so, the Secretary of VA should analyze all use of force investigations and any resulting disciplinary action by facility; officer; and outcome, among other variables. (Recommendation 5)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Division Director for Risk Management Supervision (RMS) should require case managers to document how high-risk areas in the scoping plan were considered by the examination team if they were not addressed in the examination report. (Recommendation 1)

Agency: Federal Deposit Insurance Corporation
Status: Open

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

Recommendation: The Division Director for RMS should implement policies to require that higher-level managers review case managers' documentation that describes whether banks have fully addressed MRBAs. (Recommendation 2)

Agency: Federal Deposit Insurance Corporation
Status: Open

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

Recommendation: The Division Director for RMS should revise examination documentation retention policies to increase the retention period beyond one examination cycle for banks with satisfactory or better composite ratings. (Recommendation 3)

Agency: Federal Deposit Insurance Corporation
Status: Open

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

Recommendation: The FDIC Chairman should direct RMS and the Legal Division Ethics Unit to develop a process for systematically requesting and collecting information on where departing examiners, including examiners-in-charge, enter into employment after leaving FDIC. (Recommendation 4)

Agency: Federal Deposit Insurance Corporation
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: The Council should further clarify and document its roles and responsibilities with regard to USICH matters requiring the Council's approval, the role of the Council Chair, and actions within the Executive Director's delegated authority. (Recommendation 1)

Agency: United States Interagency Council on Homelessness
Status: Open

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

Recommendation: The FAA Administrator should assign authority to an office or other entity to oversee use of the Compliance Program across program offices. (Recommendation 1)

Agency: Department of Transportation: Federal Aviation 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 FAA Administrator should collect and analyze data to monitor use of the Compliance Program across all program offices. (Recommendation 2)

Agency: Department of Transportation: Federal Aviation 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 FAA Administrator should conduct an evaluation of the Compliance Program to assess the effectiveness of the program in meeting its goals. (Recommendation 3)

Agency: Department of Transportation: Federal Aviation 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 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 Under Secretary for Health should fully define in VHA policy the oversight roles and responsibilities related to ensuring facilities' adherence to disbursement agreement policies, including roles related to ReDPro and the role of VISNs. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should more clearly define in VHA policy the purposes of the periodic independent audits and the ReDPro checklist reviews—including differentiating their purposes from one another and ensuring that they do not unnecessarily overlap. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should ensure that OAA and CBI modify the ReDPro checklist and associated guidance, to include ensuring that checklist items are clearly stated, relevant to the updated purpose of the ReDPro checklist, and not unnecessarily duplicative of items to be addressed by the periodic independent audits. The guidance should also include detailed instruction on what the compliance officers should review, and how they should determine the appropriate response for each checklist item. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should ensure that OAA and CBI develop and provide additional ReDPro training for compliance officers, consistent with the updated checklist and guidance. This training should include general information on GME programs and disbursement agreement oversight, as well as detailed information about how ReDPro reviews should be conducted. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should ensure that OAA implements a standardized independent audit tool that is consistent with the updated purpose of the periodic independent audits, and does not unnecessarily overlap with the ReDPro checklist. This could include modifying its existing recommended checklist, or developing a new tool. (Recommendation 5)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should ensure that OAA develops guidance for periodic independent audits to assist the audit teams and facility management in understanding how audits are to be conducted. (Recommendation 6)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should ensure that OAA develops substantive training for independent audit team members, consistent with the updated audit purpose, guidance, and tools. This training should include general information on GME programs and disbursement agreement oversight, as well as detailed information about how the independent audits should be conducted. (Recommendation 7)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Secretary of the Air Force should develop and implement procedures for an ERM governance structure that includes oversight responsibilities for identifying, assessing, responding to, and reporting on the risks associated with agency material weaknesses from all relevant sources. These procedures should clearly demonstrate that risks associated with material weaknesses are considered by Air Force governance, as a whole, and are mitigated appropriately to achieve goals and objectives. (Recommendation 1)

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

Comments: The DOD concurred with this recommendation and highlighted steps taken or planned to address this recommendation. Specifically, in FY19, the Air Force assessed the current-state of the risk management programs throughout the Air Force and developed a maturity model, implementation plan, and a governance structure to comply with OMB A-123 requirements. These enhancements will be implemented and formalized in policy in FY20. Further, beginning in FY19, the Air Force Senior Assessment Team (SAT) and the Senior Management Council (SMC) monitored corrective action plans for material weaknesses identified internally and by independent public accountants, including their impact on the Air Force's ability to achieve its enterprise objectives. In addition, the Air Force developed a process for the SAT and the SMC to discuss corrective action plans for material weaknesses on a quarterly basis as opposed to an annual basis, which will be evidenced in the form of board briefings and meeting minutes. Additionally, in FY19 the Air Force engaged the Enterprise Productivity Improvement Council to serve as the Air Force Risk Management Council (RMC) to oversee enterprise risk management as defined by their Charter, which was signed in February 2020. The Air Force will refine its policies and procedures to clearly specify the risks associated with the material weaknesses being addressed by the Air Force governance boards. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies by September 2020 and publish the policies by September 2021.

Recommendation: The Secretary of the Air Force should develop policies or procedures for assessing internal control to require (1) clearly delineating who within the Air Force is responsible for evaluating the internal control components and principles, how often they are to perform the evaluation, the level (e.g., entity or transactional) of the evaluation, what objectives are covered in the assessment, to whom to communicate the results if they are relevant to others performing assessments of internal control, and what guidance to follow; (2) documenting management's determination of whether each component and principle is designed, implemented, and operating effectively; and (3) documenting management's determination of whether components are operating together in an integrated manner. (Recommendation 2)

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

Comments: The DOD concurred with this recommendation and described steps taken or planned to address the recommendation. The Air Force SAF/FM performs both entity-level control assessments against all internal control components and principles and performs process level control assessments for internal controls over financial reporting and financial systems. The Air Force Audit Agency and the Air Force Inspector General have performed assessments related to operations and compliance. The Air Force will document those roles and responsibilities in formal policies. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies by September 2020 and publish the policies by September 2021.

Recommendation: The Secretary of the Air Force should develop policies or procedures for assessing internal control to require the use of test plans that (1) tie back to specific objectives to be achieved as included in the Business Operations Plan; (2) specify the nature, scope, and timing of procedures to conduct under the OMB Circular No. A-123 assessment process; and (3) reflect a consideration of prior year self-identified control deficiencies and results of internal and external audits. (Recommendation 3)

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

Comments: The DOD concurred with this recommendation and described steps taken or planned to address this recommendation. The Air Force test plans for internal controls over financial reporting and financial systems tie back to their relevant risk frameworks embedded in authoritative audit guidance. The framework used for financial reporting is the Financial Audit Manual, and the framework used for financial systems is the Federal Information Systems Controls Audit Manual, and include the nature, scope and timing of procedures performed. The Air Force's process-level internal control test plans are aligned with business process-level risks and objectives and are not directly associated with the Air Force's strategic objectives. The Air Force Business Operations Plan identifies strategic objectives, not business process-level objectives. Additionally, the Air Force considers previously identified internal control deficiencies in its annual documented internal control assessment scoping process. The Air Force will refine its policies and procedures regarding the use of test plans including operational and compliance controls. Due to the need for policy, procedure, and documentation updates required for operational and compliance controls, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine policies, procedures, and documentation by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should develop policies or procedures for assessing internal control to require SAF/FM to validate (1) the number of organizational units reporting for its overall internal control assessment; (2) how control procedures were tested, what results were achieved, and how conclusions were derived from those results; and (3) whether the results used to compile the current year report are based on current fiscal year's assessments. (Recommendation 4)

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

Comments: The DOD concurred with this recommendation. The Air Force will design policies and procedures to determine assessable units and verify that results are current on an annual basis. Due to the need to reevaluate the Air Force's assessable unit structure and the associated change management that will be necessary to implement the changes to sustain an effective program, the Air Force plans to refine the policies by September 2021 and publish the policies by September 2022.

Recommendation: The Secretary of the Air Force should develop policies or procedures for assessing internal control to require SAF/FM to assess how waivers affect the current year assessment of internal control, the determination of systemic weaknesses, and the compilation of the Air Force's overall Statement of Assurance. (Recommendation 5)

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

Comments: The DOD concurred with this recommendation. The Air Force will design policies and procedures to consider the impact of waivers to the overall assessment of the system of internal control. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies by September 2020 and publish the policies by September 2021.

Recommendation: The Secretary of the Air Force should require that developers of the policy and related guidance associated with designing the procedures for conducting OMB Circular No. A-123 assessments receive recurring training and are appropriately skilled in conducting internal control assessments and are familiar with Standards for Internal Control in the Federal Government. (Recommendation 6)

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

Comments: The DOD concurred with this recommendation and described steps taken or planned to address the recommendation. Specifically, the Air Force is implementing multiple changes to the Air Force's ERM and internal control program, including improved governance, standardized processes and documentation for enterprise risk management, entity-level and process-level controls, training, fraud risk management, and data quality management. Training content in FY20 was updated to reflect additional information, including definitions for internal controls and considerations for determining material weaknesses for operations. The Air Force will continue to update its the policies, guidance, and training to coincide with the current progress of the program. The Air Force will continue to refine the audience of its training to verify that those responsible for implementing and assessing ERM and internal controls are trained sufficiently. Due to the need for policy, procedure, documentation, and training updates required for operational and compliance controls, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies, procedures, documentation, and training by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should analyze all definitions included in Air Force ERM and internal control assessment policy and related guidance to ensure that all definitions and concepts are defined correctly. (Recommendation 7)

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

Comments: The DOD concurred with this recommendation. The Air Force will verify that all definitions and concepts in its policies are current and consistent with other authoritative guidance. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies by September 2020 and publish the policies by September 2021.

Recommendation: The Secretary of the Air Force should require SAF/FM to design recurring training for those who will assess internal control that (1) includes enhancing their skills in evaluating the internal control system and documenting results; (2) reflects all OMB Circular No. A-123 requirements, such as those related to identifying objectives, evaluating deficiencies, and determining material weaknesses; and (3) is provided to all who are responsible for performing internal control assessments. (Recommendation 8)

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

Comments: The DOD concurred with this recommendation and described actions taken or planned to address the recommendation. Specifically, the Air Force performs annual training to Major Commands, Direct Reporting Units, and Functional Executives. In FY20, the Air Force included business process assessable leads in this training. The Air Force plans to continue to refine the audience of its training to verify that those responsible for implementing and assessing ERM and internal controls are trained sufficiently by September 2021.

Recommendation: The Secretary of the Air Force should develop policy or procedures consistent with OMB Circular No. A-123 to assess the system of internal control using a risk-based approach. (Recommendation 9)

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

Comments: The DOD concurred with this recommendation and described actions taken or planned to address the recommendation. Specifically, the Air Force's scoping procedures, beginning in FY19, consider materiality, both quantitative and qualitative risk, as well as risks identified in the enterprise risk management process. The Air Force assesses internal controls over financial reporting and financial systems using a risk-based approach as evidenced currently in documented procedures and testing templates. The Air Force will refine its procedure documentation to include the assessment of internal controls over operations and compliance using a risk-based approach. Due to the need for policy, procedure, and documentation updates required for operational and compliance controls, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies, procedures, and documentation by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should develop procedures to assess internal control over processes related to mission-critical assets, including (1) tests of design that evaluate whether controls are capable of achieving objectives, (2) tests of effectiveness only after a favorable assessment of the design of the control, and (3) a baseline that has accurate descriptions of business processes and identifies key internal controls as designed by management to respond to risks. (Recommendation 10)

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

Comments: The DOD concurred with this recommendation and described actions taken or planned to address the recommendation. The Air Force documents processes and assesses internal controls over financial reporting and financial systems related to mission critical assets that includes determinations as to internal control design, implementation, operating effectiveness and risks. The Air Force will enhance its approach for documenting processes and assessing internal controls over operations and compliance not related to financial reporting and financial systems through policy. Due to the need for policy, procedure, and documentation updates required for operational and compliance controls related to mission-critical assets, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies, procedures, and documentation by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should establish a process and reporting lines of all the sources of information, including reviews performed of internal control processes related to mission-critical assets, that will be considered in the Secretary's Statement of Assurance. (Recommendation 11)

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

Comments: The DOD concurred with this recommendation. The Air Force reports material weaknesses in internal controls over financial reporting and financial systems related to mission critical assets through SAF/FM, but it will solidify its reporting channels for material weaknesses in internal controls over operations and compliance through policy. Due to the need for policy, procedure, documentation, and training updates required to appropriately report deficiencies in internal control over operations and compliance, and the coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, the Air Force plans to refine the policies, procedures, documentation, and training by September 2021 and publish the associated policies by September 2022.

Recommendation: The Secretary of the Air Force should develop procedures to require coordination between business process leads and the Air Force's unit managers to ensure that mission-critical asset–related internal control deficiencies are considered in the unit managers' assessments of internal control and related supporting statements of assurance. These procedures should include how, when, and with what frequency the results from the business process internal control reviews should be provided to relevant organizational units for consideration in their respective assurance statements. (Recommendation 12)

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

Comments: The DOD concurred with this recommendation. The Air Force will develop procedures to enhance communication between business process leads and Air Force unit managers to verify that deficiencies are reported appropriately in supporting statements of assurance. Due to the need for coordination across multiple Air Force organizations to seek input, approve, and concur with policy changes, as well as the change management needed to implement additional communications and protocol processes, the Air Force plans to refine the policies by September 2021 and publish the policies by September 2022.

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 Commissioner of Internal Revenue should document measurable objectives for using data in selecting exempt organization returns for examination. (Recommendation 1)

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 Commissioner of Internal Revenue should document and consistently use clear criteria and decision rules on assigning point values to queries, using categories and sliding scales. (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 Commissioner of Internal Revenue should require a regular review of query descriptions and programming to ensure their accuracy and minimize queries that flag the same or similar compliance issue. (Recommendation 3)

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 Commissioner of Internal Revenue should develop procedures and criteria to test new queries prior to implementation in the models. (Recommendation 4)

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 Commissioner of Internal Revenue should more fully document how TE/GE processes data and uses data to make examination selection decisions for sources outside of the model such as research projects and other projects that use queries. (Recommendation 5)

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 Commissioner of Internal Revenue should conduct an analysis to identify the optimal interval between model runs. (Recommendation 6)

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 Commissioner of Internal Revenue should establish a process for regularly evaluating selection decisions and related outcomes for the models and other processes that use data to select returns for examinations. (Recommendation 7)

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 Commissioner of Internal Revenue should document consideration or action on recommendations from its 2018 and 2020 contractor assessments. (Recommendation 8)

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 Commissioner of Internal Revenue should document how score and query data for all returns in the models will continue to be saved over the long term. (Recommendation 9)

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 Commissioner of Internal Revenue should ensure that historical data on examination outcomes are consistently defined and used when doing analysis of examination outcomes. (Recommendation 10)

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 Commissioner of Internal Revenue should routinely analyze the reasons for not examining selected returns and identify any necessary actions to address the reasons. (Recommendation 11)

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 Commissioner of Internal Revenue should annually review and update procedures as needed in relevant IRM sections on examination selection and issue interim guidance until the affected IRM sections are updated. (Recommendation 12)

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 Commissioner of Internal Revenue should document why TE/GE has not identified any risks in its risk register for using data to select exempt organization returns for examination. If risks are subsequently identified, TE/GE should document how it plans to analyze and address them. (Recommendation 13)

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 NNSA Administrator should incorporate additional management controls to better oversee and coordinate NNSA's microelectronics activities. Such management controls could include investing the microelectronics coordinator with increased responsibility and authority, developing an overarching management plan, and developing a mission need statement and a microelectronics requirements document. (Recommendation 1)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: In a May 2020 letter signed by the NNSA Administrator that provided agency comments on our draft report, NNSA neither agreed nor disagreed with our recommendation. However, NNSA stated that by December 2020 the agency plans to complete a strategic management plan that will more clearly articulate the integration of management controls for the various components of its microelectronics activities. NNSA stated that it believes this action is consistent with our recommendation. We are encouraged by this planned action and will evaluate the completed strategic management plan to determine if it meets the intent of our recommendation.

Recommendation: The Secretary of Commerce should align the agency's contingency plan with OMB guidance by including (1) plans for a potential prolonged shutdown; (2) flexibilities available to supervisors if furloughed employees were unable to return to work after the end of the shutdown; and (3) procedures for resuming program activities, including steps to ensure appropriate oversight and disbursement of funds upon the end of a shutdown. (Recommendation 1)

Agency: Department of Commerce
Status: Open

Comments: The Department of Commerce agreed with the recommendation and stated that it will develop an action plan to address the recommendation to better align its contingency plan with OMB guidance. When we confirm what actions Commerce has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Homeland Security should align the agency's contingency plan with OMB guidance by including (1) plans for a potential prolonged shutdown; (2) flexibilities available to supervisors if furloughed employees were unable to return to work after the end of the shutdown; and (3) procedures for resuming program activities, including steps to ensure appropriate oversight and disbursement of funds upon the end of a shutdown. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: The Department of Homeland Security agreed with the recommendation and and stated that it has begun to take steps to better address OMB guidance on contingency plans. When we confirm what actions DHS has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of Internal Revenue should align the agency's contingency plan with OMB guidance by including (1) plans for a potential prolonged shutdown; (2) flexibilities available to supervisors if furloughed employees were unable to return to work after the end of the shutdown; and (3) procedures for resuming program activities, including steps to ensure appropriate oversight and disbursement of funds upon the end of a shutdown. (Recommendation 3)

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

Comments: The Internal Revenue Service (IRS) partially agreed with the recommendation. IRS agreed with one element of our recommendation to include additional detail in its agency contingency plan and stated that it is in the process of adding procedures for resuming program activities following a government shutdown into its contingency plan. IRS did not agree with the other elements of the recommendation because it believes it has already addressed plans for a potential prolonged shutdown and flexibilities for supervisors if employees are unable to return to work at the end of a shutdown in its contingency plans. We agree that while IRS has included some details on these elements in its plans, we continue to believe that it should provide more detail, such as points in time when the furlough status of an employee may change, how many employees would be affected, and the legal basis for the changes, within its publically available contingency plan to fully address these elements. We will continue to monitor IRS's efforts in this area.

Recommendation: The U.S. Trade Representative, in consultation with EOP as appropriate, should align the component's contingency plan with OMB guidance. This could be accomplished through (1) revisions to the EOP contingency plan; or (2) by creating a separate USTR plan. (Recommendation 4)

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

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has already begun addressing our recommendations on aligning its contingency plan with OMB guidance. When we confirm what actions USTR has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for International Trade should document the component's shutdown processes, including roles and responsibilities, planning processes for potential shutdowns, and recall processes for furloughed employees during a shutdown. (Recommendation 5)

Agency: Department of Commerce: International Trade Administration
Status: Open

Comments: The Department of Commerce agreed with the recommendation and stated that the International Trade Administration (ITA) has documented its shutdown planning processes and recall processes for furloughed employees during a shutdown. When we confirm what actions ITA has taken in response to this recommendation, we will provide updated information.

Recommendation: The U.S. Trade Representative should document the component's shutdown processes, including roles and responsibilities, planning processes for potential shutdowns, and recall processes for furloughed employees during a shutdown. (Recommendation 6)

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

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has already begun addressing our recommendations on documenting its shutdown processes. When we confirm what actions USTR has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of CBP should develop internal controls to track and document which employees worked and what work was performed daily during a government shutdown. (Recommendation 7)

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

Comments: The Department of Homeland Security agreed with the recommendation and stated that Customs and Border Protection plans to analyze existing systems to determine which is best suited to track and document employee work during a government shutdown and will ensure that the chosen system is available should a future shutdown occur. When we confirm what actions CBP has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of CBP should develop internal controls to limit access to physical workspaces to appropriate employees during a government shutdown. (Recommendation 8)

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

Comments: The Department of Homeland Security (DHS) agreed with the recommendation but stated that because Customs and Border Protection (CBP) does not have systems capable of efficiently restoring physical access for furloughed employees, it would have to reinstate employee access individually and the cost would be substantial. DHS stated that CBP plans to update procedures to ensure more comprehensive workspace access guidance for furloughed employees. We continue to believe that physical access controls are important during shutdowns in order to prevent misuse of government resources. We encourage CBP to improve their systems to be able to efficiently implement such controls and will monitor CBP's efforts going forward.

Recommendation: The Commissioner of Internal Revenue should develop internal controls to limit access to physical workspaces to appropriate employees during a government shutdown. (Recommendation 9)

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

Comments: The Internal Revenue Service disagreed with this recommendation. IRS stated that it believes that it has effective controls in place to manage physical workspace access during a shutdown. In addition, IRS said that it believes that implementing additional access controls do not justify the corresponding resource investments. We continue to believe that IRS should improve its access controls, which currently rely on managers and furlough letters to communicate limits on workspace access. While we recognize the costs of increased access controls, government shutdowns are unique events that require additional access controls in order to prevent potential misuse of government resources and will monitor IRS's efforts to address it.

Recommendation: The U.S. Trade Representative should develop internal controls to limit access to physical workspaces to appropriate employees during a government shutdown. (Recommendation 10)

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

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has made the Executive Office of the President (EOP) aware of the recommendations on developing controls for physical workspace access during a shutdown. We will continue to monitor USTR's efforts to address this recommendation.

Recommendation: The Commissioner of CBP should develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 11)

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

Comments: The Department of Homeland Security (DHS) agreed with the recommendation. DHS stated that Customs and Border Protection (CBP) believes that furloughed employees must be able to passively monitor the status of the government shutdown and access important agency communications using DHS-issued electronic devices. Additionally, disabling and reactivating thousands of employee user accounts during a shutdown posed a significant burden. DHS said that CBP plans to update shutdown procedures to clarify allowed use of DHS-issued electronic devices by furloughed employees. We agree that CBP should update procedures on workspace access as suggested, and continue to believe that virtual access controls are important during shutdowns in order to prevent misuse of government resources. We encourage CBP to improve their systems to be able to efficiently implement such controls and will monitor CBP's progress going forward.

Recommendation: The Commissioner of Internal Revenue should develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 12)

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

Comments: The Internal Revenue Service disagreed with this recommendation. IRS stated that it believes that it has effective controls in place to manage virtual workspace access during a shutdown. In addition, IRS said that it believes that implementing additional access controls do not justify the corresponding resource investments. We continue to believe that IRS should improve its access controls, which currently rely on managers and furlough letters to communicate limits on workspace access. While we recognize the costs of increased access controls, government shutdowns are unique events that require additional access controls in order to prevent potential misuse of government resources and will monitor IRS's efforts to address it.

Recommendation: The Under Secretary for International Trade should develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 13)

Agency: Department of Commerce: International Trade Administration
Status: Open

Comments: The Department of Commerce agreed with the recommendation and stated that the International Trade Administration (ITA) has established and documented internal controls to limit virtual workspace access to excepted or exempt employees during a government shutdown. When we confirm what actions ITA has taken in response to this recommendation, we will provide updated information.

Recommendation: The U.S. Trade Representative should, in consultation with EOP, develop internal controls to limit access to virtual workspaces to appropriate employees during a government shutdown. (Recommendation 14)

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

Comments: The Office of the U.S. Trade Representative (USTR) neither agreed nor disagreed with the recommendation. USTR stated that it has made the Executive Office of the President (EOP) aware of the recommendations on developing controls for virtual workspace access during a shutdown. We will continue to monitor USTR's efforts to address this recommendation.

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: The FEMA Administrator should develop a plan—with time frames and milestones and input from field leadership—to address identified challenges that have hindered FEMA's ability to provide reliable and complete information to field leaders and managers about staff knowledge, skills, and abilities. (Recommendation 1)

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

Comments: DHS concurred with our recommendation. In its agency comment letter, the department noted that FEMA plans to engage field leaders on enhancements to its coach-and-evaluator program to develop a plan to address identified challenges. DHS also reported that FEMA plans to increase training offerings and align its curriculum so that FEMA Qualification System status matches workforce capability. DHS anticipates completion by March 31, 2021.

Recommendation: The FEMA Administrator should develop mechanisms, including collecting relevant data, to assess how effectively FEMA's disaster workforce was deployed to meet mission needs in the field. (Recommendation 2)

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

Comments: DHS concurred with our recommendation. In its agency comment letter, the department reported that FEMA plans to convene subject matter experts to develop mechanisms that demonstrate how effectively FEMA's disaster workforce deploys to meet mission needs in the field. Expected completion is March 31, 2021.

Recommendation: The FEMA Administrator should create a staff development program for FEMA's disaster workforce that, at a minimum, addresses access to training, delivery of on-the-job training and mentoring, use of performance evaluations, and consistent developmental opportunities regardless of deployment status. (Recommendation 3)

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

Comments: DHS concurred with our recommendation. In its agency comment letter, the department stated that FEMA is working to finalize and implement some staff development initiatives we described in our report, such as the FEMA Deployment Performance Evaluation Directive, which will provide guidance on performance reviews for deployed staff. DHS anticipates that FEMA's efforts to implement will be completed by March 31, 2021.

Recommendation: We recommend that the Commissioner of Internal Revenue update and implement policies and procedures for developing a courier contingency plan to prohibit managers responsible for overseeing the preparation of taxpayer receipts for deposits from also transporting them to financial institutions. (Recommendation 20-01)

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

Comments: The IRS agreed with this recommendation and stated that the Wage and Investment organization will update the Courier Contingency Plan polices and procedures to provide for appropriate segregation of duties or other curative measures.

Recommendation: We recommend that the Commissioner of Internal Revenue establish and implement manual refund procedures to direct (1) initiators to document (e.g., record on the taxpayers' accounts or annotate on the related manual refund forms) the justification for bypassing the IAT tool warning related to potential duplicate tax refunds on taxpayers' accounts and (2) managers to monitor whether such warnings were bypassed and review the justifications for reasonableness prior to approving manual refund forms. (Recommendation 20-02)

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

Comments: The IRS agreed with this recommendation and stated that the Wage and Investment organization agrees that actions need to occur to address duplicate tax refund conditions through improved manual refund procedures to require (1) initiator to document the justification for bypassing the Integrated Automated Technologies (IAT) tool warning related to potential duplicate tax refunds on taxpayers' accounts and (2) managers to review the justification documented for bypassing the IAT tool warning for reasonableness prior to approving manual refund forms. However, IRS also stated that it was unable to commit to implementing a corrective action plan at this time due to budgetary constraints on system enhancements.

Recommendation: We recommend that the Commissioner of Internal Revenue establish and implement actions to provide reasonable assurance that business units record the acceptance of goods and services in a timely manner in accordance with IRS policies and procedures. (Recommendation 20-03)

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

Comments: The IRS agreed with this recommendation and stated that the CFO organization will determine the reasons for business unit(s) non-compliance with established policies and procedures related to timely recording of receipts and acceptance of goods and services and, based on this evaluation, develop an action plan that once completed will provide additional tools to aid the business units in reasonably ensuring compliance with established requirements.

Recommendation: We recommend that the Commissioner of Internal Revenue establish and implement actions to provide reasonable assurance that the future lease payment amounts for non-cancellable operating leases are calculated correctly. (Recommendation 20-04)

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

Comments: The IRS agreed with this recommendation and stated that the CFO organization will update policies and procedures to include additional instructions needed to calculate the future lease payments due on the non-cancelable leases with terms greater than one year and will also create an automated calculation to determine the number of remaining months of lease payments.

Recommendation: The Assistant Secretary of the Air Force for Acquisition, Technology and Logistics should direct the Chief Architect to develop a plan to attain mature technologies when needed for each ABMS development area, which includes an initial list of technologies and an assessment of their maturity that is updated to reflect changes, and update Congress quarterly. (Recommendation 1)

Agency: Department of Defense: Department of the Air Force: Office of the Assistant Secretary of the Air Force (Acquisition)
Status: Open

Comments: DOD agreed with this recommendation but, as of August 2020, has not yet taken any action to implement it. Officials indicated that in the first quarter of fiscal year 2021 the department expects to provide Congress with an initial list of technologies and an assessment of their maturity, and a plan to attain mature technologies for each development area. We will continue to monitor DOD's actions to implement this recommendation.

Recommendation: The Assistant Secretary of the Air Force for Acquisition, Technology and Logistics should direct the Chief Architect to prepare a cost estimate that is developed in accordance with cost estimating leading practices, to include regularly updating the estimate to reflect ABMS changes and actual costs, and update Congress quarterly. (Recommendation 2)

Agency: Department of Defense: Department of the Air Force: Office of the Assistant Secretary of the Air Force (Acquisition)
Status: Open

Comments: DOD agreed with this recommendation but, as of August 2020, has not yet taken any action to implement it. Officials indicated that in the first quarter of fiscal year 2021 the department expects to provide Congress with a cost estimate of ABMS development activities. We will continue to monitor DOD's actions to implement this recommendation.

Recommendation: The Assistant Secretary of the Air Force for Acquisition, Technology and Logistics should direct the Chief Architect to prepare an affordability analysis that should be regularly updated, and update Congress quarterly. (Recommendation 3)

Agency: Department of Defense: Department of the Air Force: Office of the Assistant Secretary of the Air Force (Acquisition)
Status: Open

Comments: DOD agreed with this recommendation but, as of August 2020, has not yet taken any action to implement it. Officials indicated that in the fourth quarter of fiscal year 2020 the department expects to provide Congress with the affordability analysis for the fiscal year 2021 budget request. In addition, the department plans to provide an affordability analysis as part of the fiscal year 2022 budget request submission to Congress. We will continue to monitor DOD's actions to implement this recommendation.

Recommendation: The Assistant Secretary of the Air Force for Acquisition, Technology and Logistics should formalize and document acquisition authority and decision-making responsibilities of the Air Force offices involved in the planning and execution of ABMS, to include the Chief Architect. This document should be included as part of the submission to Congress in June 2020 and communicated to the Air Force offices that support ABMS. (Recommendation 4)

Agency: Department of Defense: Department of the Air Force: Office of the Assistant Secretary of the Air Force (Acquisition)
Status: Open

Comments: DOD agreed with this recommendation but, as of August 2020, has not yet taken any action to implement it. Officials indicated that in the fourth quarter of fiscal year 2020 the department expects to provide Congress with documentation of decision-making authorities. We will continue to monitor DOD's actions to implement this recommendation.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation: The Administrator of FNS should develop and implement a process, documented in policies and procedures, to analyze SNAP state-level root causes to identify potential similarities among the states and develop and implement SNAP agency-level corrective actions, if appropriate, to help address them. (Recommendation 1)

Agency: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service
Status: Open

Comments: In commenting on our draft report, USDA stated that the Food and Nutrition Service should formalize its existing processes into a standard operating procedure to analyze the Supplemental Nutrition Assistance Programs (SNAP) state-level root causes to identify potential similarities among states, in order to improve development and implementation of SNAP agency-level corrective actions, if appropriate.

Recommendation: The Secretary of Agriculture should revise USDA's procedures to include processes for monitoring the progress and measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect USDA's corrective actions have on reducing improper payments. (Recommendation 2)

Agency: Department of Agriculture
Status: Open

Comments: In commenting on our draft report, USDA stated that a proposed action plan will be developed to revise USDA's procedures for monitoring the progress and measuring the effectiveness of improper payment corrective actions. Processes will focus on the impact corrective actions have on the root causes of improper payments.

Recommendation: The Secretary of Education should revise and document Education's process for measuring the effectiveness of its corrective actions based on its new statistical estimation methodology for Direct Loan and Pell Grant improper payments. This process should clearly demonstrate the effect Education's corrective actions have on reducing improper payments. (Recommendation 3)

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

Comments: In commenting on our draft report, Education stated that Federal Student Aid (FSA) will continue to evaluate and refine its processes to measure corrective actions and the effectiveness of these actions. Further, Education stated that FSA's measurement of corrective action effectiveness and root cause identification will gain additional precision as FSA collects annual improper payment data and builds upon the new baseline of statistically valid improper payment estimates. Education stated that FSA annually measures the overall effectiveness of its corrective action plans collectively against the improper payment reduction targets, rather than measuring the effectiveness of each individual corrective action. However, OMB guidance directs agencies to measure the effectiveness of each individual corrective action annually.

Recommendation: The Secretary of Health and Human Services should document in policies and procedures HHS's improper payment corrective action plan process. As part of these procedures, HHS should include processes for (1) establishing planned completion dates, (2) monitoring the progress of implementing corrective actions, and (3) measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect HHS's corrective actions have on reducing improper payments. (Recommendation 4)

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

Comments: In commenting on our draft report, HHS elaborated on the improper payment corrective action plan process that is called for in OMB guidance. HHS stated that OMB guidance provides agencies the flexibility to measure the effectiveness of corrective actions and believes that this flexibility is vital to its oversight processes to reduce improper payments.

Recommendation: The Secretary of the Treasury should determine whether Treasury's current improper payment root cause analysis provides sufficiently relevant information that can be used as a basis for proposed corrective actions in reducing EITC improper payments and, if not, update the analysis using more timely data to ensure their reliability for identifying root causes of EITC improper payments. (Recommendation 5)

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

Comments: In commenting on our draft report, Treasury stated that each year it indicates in its corrective action plan that IRS will continue to work with Treasury to develop legislative proposals that will improve refundable credit compliance and reduce erroneous payments.

Recommendation: The Secretary of the Treasury should update Treasury's strategy for addressing the root causes of EITC improper payments to include (1) coordinating with other agencies to identify potential strategies and data sources that may help in determining EITC eligibility and (2) determining whether legislative changes are needed, and developing proposals as appropriate, to help reduce EITC improper payments, such as those related to the inability to authenticate taxpayer eligibility. (Recommendation 6)

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

Comments: In commenting on our draft report, Treasury stated that each year it indicates in its corrective action plan that IRS will continue to work with Treasury to develop legislative proposals that will improve refundable credit compliance and reduce erroneous payments. Although Treasury has made certain legislative proposals, it has not made proposals to specifically help address EITC eligibility criteria issues. Additionally, Treasury's strategy does not include identifying and proposing additional legislative changes needed to help reduce EITC improper payments.

Recommendation: The Commissioner of SSA should develop and implement a process, documented in policies and procedures, to measure the effectiveness of SSA's corrective actions for OASDI and SSI improper payments. This process should clearly demonstrate the effect SSA's corrective actions have on reducing improper payments. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: In commenting on our draft report, SSA stated that it will determine the most cost-effective strategies to remediate the underlying causes of payment errors and monitor, measure, and revise the strategies as needed.

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 NMFS Assistant Administrator for Fisheries should work with the South Atlantic and Gulf of Mexico councils, and other councils as appropriate, to develop documented processes for conducting allocation reviews. (Recommendation 1)

Agency: Department of Commerce: National Oceanic and Atmospheric Administration: National Marine Fisheries Service
Status: Open

Comments: Commerce and NOAA agreed with this recommendation and stated that NOAA's NMFS will work to implement it to the extent possible. We will continue to monitor NMFS' efforts to do so.

Recommendation: The NMFS Assistant Administrator for Fisheries should work with the South Atlantic and Gulf of Mexico councils, and other councils as appropriate, to specify how the councils will document their allocation reviews, including the basis for their allocation decisions, whether fishery management plan objectives are being met, and what factors were considered in the reviews. (Recommendation 2)

Agency: Department of Commerce: National Oceanic and Atmospheric Administration: National Marine Fisheries Service
Status: Open

Comments: Commerce and NOAA agreed with this recommendation and stated that NOAA's NMFS will work to implement it to the extent possible. We will continue to monitor NMFS' efforts to do so.

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 Chief Counsel of the Internal Revenue Service, in coordination with appropriate offices, should identify and document parameters and procedures for applying enhanced collaborative approaches to regulation and other guidance development with IRS Business Operating Divisions. (Recommendation 1)

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

Comments: As of August 2020, IRS disagrees with this recommendation and does not plan to take action on it. IRS officials said their Chief Counsel Directives Manual provides sufficient guidance and flexibility to allow for enhanced collaboration when appropriate. However, officials acknowledged that this collaboration was particularly helpful in implementing TCJA provisions and greatly contributed to IRS's successful implementation. By implementing this recommendation, IRS can help ensure that institutional knowledge and beneficial practices from TCJA implementation will be documented and effectively leveraged to support implementation of future time-sensitive or complex tax law changes without restricting IRS's flexibility. Documenting procedures would ensure IRS can retain organizational knowledge and mitigate the risk of having that knowledge limited to a few personnel.

Recommendation: The Commissioner of Internal Revenue should develop a process to accurately and thoroughly capture implementation status of ongoing projects in accordance with Standards for Internal Control in the Federal Government. (Recommendation 2)

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

Comments: As of August 2020, IRS disagrees with this recommendation and does not plan to take action on it. IRS officials acknowledged inconsistencies in reports but said these inconsistencies were not detrimental to overall implementation. We maintain that accurately and thoroughly capturing implementation status on ongoing projects would provide accurate information to decision makers and could prevent potential misreporting, mismanagement, or inefficient resource investment in the future.

Recommendation: The Commissioner of Small Business/Self Employed should coordinate with appropriate IRS divisions or offices to identify the costs and benefits of retroactively transcribing taxpayer data resulting from TCJA. (Recommendation 3)

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

Comments: As of August 2020, IRS disagrees with this recommendation and does not plan to take action on it. IRS officials said the retroactive transcription of TCJA returns would be a time intensive activity with significant opportunity costs, and that the benefits of retroactive transcription are currently not quantifiable. A high-level analysis of costs and benefits could help IRS management determine what, if any, data would benefit compliance and enforcement efforts. IRS could use readily available existing information (such as the number of returns affected by a certain provision, LB&I and IT cost data on conversion efforts already implemented, or the usefulness of past compliance analytics in similar areas) to inform the analysis. For example, IRS staff are manually reviewing certain forms associated with one TCJA provision for compliance purposes and IRS could use information from this effort (e.g., amount of time and any compliance results) to inform a high-level estimate of costs and benefits.

Recommendation: Based on the costs and benefits identified in recommendation 3, the Commissioner of Small Business/Self Employed should determine which TCJA provisions' data should be converted into a more useful electronic format for compliance and enforcement purposes and work with the appropriate offices to obtain the transcribed data, as appropriate. (Recommendation 4)

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

Comments: As of August 2020, IRS disagrees with this recommendation and does not plan to take action on it. IRS officials said that implementing this recommendation would require identifying the costs and benefits, which they do not plan to take action on. However, IRS officials acknowledged that IRS operating divisions and offices make strategic decisions regarding how best to use TCJA-related return data for compliance and enforcement purposes. We believe that converting data in instances where the benefits outweigh the costs would better position IRS to more effectively and efficiently pursue its mission of ensuring taxpayer compliance. For example, in the case of one TJCA provision, because IRS is not collecting information in an easily accessible format, IRS staff are manually reviewing forms to help with compliance efforts.

Recommendation: The Assistant Secretary of Tax Policy should update Treasury's internal guidance to ensure that Treasury's regulatory impact analyses include examination of the distributional effects of revenue changes when regulations influence tax liability. (Recommendation 5)

Agency: Department of the Treasury: Office of the Assistant Secretary of the Treasury (Tax Policy)
Status: Open

Comments: As of August 2020, Treasury disagrees with this recommendation and does not plan to take action on it. Treasury officials said the analyses underlying Treasury's tax regulations have fully complied with the Memorandum of Agreement established with the U.S. Office of Management and Budget (OMB), which focuses on non-revenue effects. We maintain that decisions Treasury and IRS made when developing regulations to implement TCJA could potentially impact tax liability by billions of dollars per year; however, Treasury's internal guidance dictates that these revenue effects should not be included in its economic analyses of the regulations. In some regulations, Treasury has addressed revenue effects in its analyses, but this has not been done consistently. By adjusting its internal guidance to ensure that distributional effects of revenue changes are consistently reflected in its analyses, it would better inform the regulatory decision-making process, while also providing the public with greater transparency.

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 Director of the U.S. Marshals Service should take steps to ensure that supervisory review of division and district investigations is documented in accordance with USMS policy. (Recommendation 1)

Agency: Department of Justice: United States Marshals Service
Status: Open

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

Recommendation: The Director of ATF should develop policy for verifying the accuracy and completeness of information in ATF employee misconduct systems. (Recommendation 2)

Agency: Department of Justice: Bureau of Alcohol, Tobacco, Firearms and Explosives
Status: Open

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

Recommendation: The Director of the U.S. Marshals Service should develop policy for verifying the accuracy and completeness of information in USMS employee misconduct systems. (Recommendation 3)

Agency: Department of Justice: United States Marshals Service
Status: Open

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

Recommendation: The Director of ATF should develop a performance measure to monitor the timeliness of misconduct investigations, according to policy requirements. (Recommendation 4)

Agency: Department of Justice: Bureau of Alcohol, Tobacco, Firearms and Explosives
Status: Open

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

Recommendation: The Director of the U.S. Marshals Service should develop a performance measure to monitor the timeliness of district and division misconduct investigations, according to policy requirements. (Recommendation 5)

Agency: Department of Justice: United States Marshals Service
Status: Open

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

Recommendation: The Director of ATF should modify existing oversight mechanisms to include the monitoring of key internal controls related to employee misconduct investigations. (Recommendation 6)

Agency: Department of Justice: Bureau of Alcohol, Tobacco, Firearms and Explosives
Status: Open

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

Recommendation: The Director of the U.S. Marshals Service should modify existing oversight mechanisms to fully monitor key internal controls related to employee misconduct investigations. (Recommendation 7)

Agency: Department of Justice: United States Marshals Service
Status: Open

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

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

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

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

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

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

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

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

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

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

Recommendation: The Chairman of the NMB should document NMB's authorizations for its use of cloud services approved through FedRAMP and submit the authorizations to the FedRAMP Program Management Office. (Recommendation 1)

Agency: National Mediation Board
Status: Open

Comments: NMB agreed with this recommendation and said it would take action to address it, completing these actions by the end of fiscal year 2020.

Recommendation: The Chairman of the NMB should update NMB's security policies and procedures to include FedRAMP's authorization requirements. (Recommendation 2)

Agency: National Mediation Board
Status: Open

Comments: NMB agreed with this recommendation and said it would take action to address it, completing these actions by the end of fiscal year 2020.

Recommendation: The Chairman of the NMB should develop a written plan to document NMB's process for reviewing and monitoring the agency's annual appropriation to ensure that funds are used effectively. (Recommendation 3)

Agency: National Mediation Board
Status: Open

Comments: NMB agreed with this recommendation. Agency officials said they would take action to address it, but did not provide a time frame for completion.

Recommendation: The Chairman of the NMB should establish a process for the Board to effectively monitor and evaluate NMB's adherence to audit protocols and implementation of actions to address audit recommendations. (Recommendation 4)

Agency: National Mediation Board
Status: Open

Comments: NMB agreed with this recommendation. Agency officials said they would take action to address it, but did not provide a time frame for completion.

Recommendation: The Chairman of FCC should develop specific, measurable goals and performance measures for its efforts to monitor the performance of new WEA capabilities, such as enhanced geo-targeting and expanded alert message length. (Recommendation 1)

Agency: Federal Communications Commission
Status: Open

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

Recommendation: The Director of the IPAWS program should document how it plans to address key actions needed to educate alerting authorities in their use of IPAWS and implement a mechanism that will allow FEMA to regularly and systematically obtain and analyze feedback on alerting authorities' educational needs. (Recommendation 2)

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

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

Recommendation: The Director of the IPAWS program should establish procedures to prioritize pending IPAWS applications and to follow up with applicants to address these applications. (Recommendation 3)

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

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

Recommendation: The Director of 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 Commissioner of the Social Security Administration should clarify policies and procedures to remind staff that a diagnosis of a substance use disorder is not necessary to conduct a Drug Addiction and Alcoholism evaluation. (Recommendation 1)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. The agency stated that it had revised related policies in February 2020, and had planned to issue guidance and video-on-demand training to further clarify policies and procedures in this area. However, SSA said its efforts to maintain mission critical activities amid the COVID-19 pandemic have delayed further implementation of this recommendation and a specific implementation date could not be provided at this time.

Recommendation: The Commissioner of the Social Security Administration should ensure that staff document their rationale for decisions involving the Drug Addiction and Alcoholism evaluation process. (Recommendation 2)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. The agency said it had planned to issue guidance reinforcing its policy on properly documenting decisions involving the Drug Addiction and Alcoholism evaluation process. However, SSA said its efforts to maintain mission critical activities amid the COVID-19 pandemic have delayed implementation of this recommendation and a specific implementation date could not be provided at this time.

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

Agency: Department of Agriculture
Status: Open

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

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

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

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

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

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

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

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

Agency: Department of Agriculture
Status: Open

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

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

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

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

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

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

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

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

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

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

Recommendation: The SEC Chair should direct the Directors of the Division of Corporation Finance, Division of Enforcement, Office of Compliance Inspections and Examinations, and Office of Credit Ratings to develop written policies and processes to systematically assess the effectiveness of staff procedures (procedures applicable to staff who perform examinations of registered entities, enforcement investigations, and reviews of corporate financial securities filings). Examples of elements SEC could include in the policies and processes are the steps necessary to conduct such assessments, including time frames in which the assessments should be performed and reviewed; assignment of responsibilities related to the assessments; requirements for documenting assessments; and steps for staff to take to mitigate and report deficiencies identified as a result of the assessments. (Recommendation 1)

Agency: United States Securities and Exchange Commission
Status: Open

Comments: As of May 2020, SEC updated its Reference Guide for Compliance with Section 961 of the Dodd-Frank Act to require the Division of Corporation Finance, Division of Enforcement, Office of Compliance Inspections and Examinations, and Office of Credit Ratings to develop and maintain written policies and processes for conducting systematic assessments of the effectiveness of procedures applicable to the staff who perform examinations of registered entities, enforcement investigations, and reviews of corporate financial securities filings. The added requirement for each division and office to develop policies and processes is a positive step toward addressing this recommendation. However, until the divisions and offices establish such policies and processes, this recommendation remains open. SEC staff stated that the divisions and offices are currently working on developing their individual frameworks for assessing staff procedures and will likely be done by the end of fiscal year 2020. We will continue to monitor these efforts.

Recommendation: The Director of the Division of Corporation Finance should ensure that all internal supervisory controls include documentation requirements, detailed procedures, identified follow-up actions, implementation time frames, and assignment of control execution responsibility, in accordance with SEC guidance and federal internal control standards for implementing control activities through documented policies. (Recommendation 2)

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

Comments: As of May 2020, SEC staff said that the Division of Corporation Finance is working to address this recommendation through its normal Risk and Control Matrix review process. Staff said that SEC would have an update for GAO in the Fall 2020. We will update the status of the recommendation when the Division of Corporation Finance provides documentation showing the implementation of responsive actions.

Recommendation: The Director of the Division of Enforcement should ensure that all internal supervisory controls include documentation requirements, detailed procedures, identified follow-up actions, implementation time frames, and assignment of control execution responsibility, in accordance with SEC guidance and federal internal control standards for implementing control activities through documented policies. (Recommendation 3)

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

Comments: As of May 2020, SEC staff said that the Division of Enforcement is working to address this recommendation through its normal Risk and Control Matrix review process. Staff said that SEC would have an update for GAO in the Fall 2020. We will update the status of the recommendation when the Division of Enforcement provides documentation showing the implementation of responsive actions.

Recommendation: The Director of the Office of Compliance Inspections and Examinations should ensure that all internal supervisory controls include documentation requirements, detailed procedures, identified follow-up actions, implementation time frames, and assignment of control execution responsibility, in accordance with SEC guidance and federal internal control standards for implementing control activities through documented policies. (Recommendation 4)

Agency: United States Securities and Exchange Commission: Office of Compliance Inspections and Examinations
Status: Open

Comments: As of May 2020, SEC staff said that the Office of Compliance Inspections and Examinations is working to address this recommendation through its normal Risk and Control Matrix review process. Staff said that SEC would have an update for GAO in the Fall 2020. We will update the status of the recommendation when the Office of Compliance Inspections and Examinations provides documentation showing the implementation of responsive actions.

Recommendation: The Director of the Office of Credit Ratings should ensure that all internal supervisory controls include documentation requirements, detailed procedures, identified follow-up actions, implementation time frames, and assignment of control execution responsibility, in accordance with SEC guidance and federal internal control standards for implementing control activities through documented policies. (Recommendation 5)

Agency: United States Securities and Exchange Commission: Office of Credit Ratings
Status: Open

Comments: As of May 2020, SEC staff said that the Office of Credit Ratings is working to address this recommendation through its normal Risk and Control Matrix review process. Staff said that SEC would have an update for GAO in the Fall 2020. We will update the status of the recommendation when the Office of Credit Ratings provides documentation showing the implementation of responsive actions.

Recommendation: The OJJDP Administrator should set performance targets for individual grant programs. (Recommendation 1)

Agency: Department of Justice: Office of Juvenile Justice and Delinquency Prevention
Status: Open

Comments: In June 2020, DOJ reported that OJJDP is engaged in a comprehensive effort to improve performance measures. The final step of this process will be the development of performance targets. According to DOJ, OJJDP anticipates setting initial targets for its discretionary grant programs by October 2021 and for the Title II Formula Grant program by March 2023. We believe these actions, when effectively completed, will address our recommendation. We plan to provide an update on OJP's progress in late 2021.

Recommendation: The Assistant Attorney General for Administration should ensure that future department-level fraud risk profiles (1) determine the department's fraud risk tolerance for DOJ grants—which include OJJDP grant programs, and (2) prioritize residual fraud risks based on an assessment against that tolerance, consistent with leading practices in GAO's Fraud Risk Framework. (Recommendation 2)

Agency: Department of Justice: Office of the Assistant Attorney General for Administration
Status: Open

Comments: In June 2020, DOJ reported that it awarded a new contract in January 2020 that includes a requirement to continue conducting annual fraud risk assessments and update associated fraud risk profiles using the GAO Fraud Risk Framework. DOJ further reported that it will develop a fraud risk tolerance for DOJ grants and prioritize residual fraud risk against that tolerance when it conducts this assessment. We believe these actions, when effectively completed, will address our recommendation. We plan to follow-up with DOJ and provide an update in early 2021.

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 Board of Governors of the Federal Reserve System should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 1)

Agency: Federal Reserve System
Status: Open

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

Recommendation: The Comptroller of the Currency should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 2)

Agency: Department of the Treasury: Office of the Comptroller of the Currency
Status: Open

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

Recommendation: The Chairman of the Federal Deposit Insurance Corporation should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 3)

Agency: Federal Deposit Insurance Corporation
Status: Open

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

Recommendation: The Chairman of the National Credit Union Administration should, in coordination with the other federal banking regulators, and with input from BSA/AML examiners and other relevant stakeholders, take steps to improve examiners' ability to evaluate the effectiveness of banks' BSA/AML compliance controls with respect to money transmitter accounts. Steps may include providing updates to examination procedures, examiner training, or a combination of methods. (Recommendation 4)

Agency: National Credit Union Administration
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 Navy ensure that the Commander, Naval Surface Forces, in coordination with Surface Warfare Officers School Command, develop a method to regularly collect feedback from SWOs across the fleet, such as in a survey, regarding the quality of their classroom, simulator, and at-sea training on Division Officer performance; and evaluates trends in the feedback received for the purpose of improving SWO training. (Recommendation 1)

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

Comments: The Navy concurred with our recommendation. In March 2020, the Navy provided an estimated implementation date of March 2023, noting that it was considering a fleet-wide survey, timed for a later date when more Surface Warfare Officers have completed new training courses and implemented their training. In addition, the Navy listed other means it employs to collect feedback, such as student surveys at the end of training courses, leadership visits and conferences, and Commanding Officer updates. Our emphasis on collection of fleet-wide feedback from all Surface Warfare Officers and trend analysis remains critical to help the Navy understand the value of its training programs at various career stages and in the diverse operating environments across the fleet.

Recommendation: We recommend that the Secretary of the Navy ensure that the Commander, Naval Surface Forces, routinely conduct regular Officer of the Deck competency assessments using samples of sufficient size and using selection methods to gauge the level of fleet-wide ship-driving proficiency trends following the implementation of the planned ship-driving training programs. (Recommendation 2)

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

Comments: The Navy concurred with our recommendation. In March 2020, the Navy provided an estimated implementation date of March 2023, noting that it was conducting the planned fleet-wide Officer of the Deck competency checks in 2020, and that it intends to use a system of ten career milestone assessments for future performance measurement. The Navy stated that it may or may not hold subsequent rounds of the Officer of the Deck competency assessments depending on performance indicated in other career milestone assessments. In our report we identified the importance of continuing the current Officer of the Deck competency assessments through at least 2024 because that is when new officers that complete the full set of new initial ship-driving training courses will be eligible for assessment. The Navy used the Officer of the Deck competency assessments in 2018 to establish a performance baseline, and we believe that the Navy should apply the same standard to measure performance changes for Surface Warfare Officers that complete new training courses moving forward.

Recommendation: We recommend that the Secretary of the Navy ensure that the Commander, Naval Surface Forces, in coordination with Surface Warfare Officers School Command, provide Commanding Officers with standard criteria to inform their evaluation of candidates for their Officer of the Deck qualification and incorporates these criteria into surface fleet guidance. (Recommendation 3)

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

Comments: The Navy concurred with our recommendation. In March 2020, the Navy provided an estimated implementation date of March 2023. However, in its official comments on the report and in subsequent correspondence, the Navy indicated that its existing policies already meet the intent of the recommendation. Specifically, the Navy stated that its Officer of the Deck Underway Personnel Qualification Standards provide standard evaluation criteria for Officer of the Deck qualification. In our report, we noted that while the Personnel Qualification Standards provide a common list of required experiences, they do not provide a common understanding of proficiency in completing these experiences. Instead, proficiency determination is left to the discretion of the ship's Commanding Officer, which has led to wide variation in ship-driving proficiency across the fleet. Therefore, we continue to believe that the Navy should provide Commanding Officers with standard criteria to inform their evaluation of candidates for their Officer of the Deck qualification and incorporate these criteria into surface fleet guidance.

Recommendation: We recommend that the Secretary of the Navy ensure that the Commander, Naval Surface Forces, in coordination with Surface Warfare Officers School Command, develop a plan to analyze and use Mariner Skills Logbook information to inform decision-making. (Recommendation 4)

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

Comments: The Navy concurred with our recommendation. In March 2020, the Navy provided an estimated implementation date of March 2023. In official comments on the report and in subsequent correspondence the Navy stated that its Surface Warfare Career Manual establishes guidance for the implementation and use of the Mariner Skills Logbook, and that the logbook will contribute information to allow proficiency trend analysis over time. However, while the Surface Warfare Career Manual identifies the offices responsible for logbook activities, it does not include a specific plan for the use of logbook data to analyze proficiency trends over time or to benefit individual officers. Our emphasis that the Navy develop a plan to analyze and use Surface Warfare Mariner Skills Logbook data to aid decision-making remains valid, and when implemented should assist the Navy in determining the relationship between SWO experience and ship-driving proficiency.

Recommendation: The Secretary of Transportation should direct the Administrator of FTA to identify and develop controls, such as methods to more easily identify transit expenses within applications submitted by larger entities, such as a city, county, or state government, to address the risk of duplicate funding. (Recommendation 1)

Agency: Department of Transportation
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 Administrator of FEMA to identify and develop controls, such as methods to more easily identify transit expenses within applications submitted by larger entities such as a city, county, or state government, to address the risk of duplicate funding. (Recommendation 2)

Agency: Department of Homeland Security
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 should direct DOE's Office of the Chief Financial Officer to revise DOE's PILT order to require DOE to maintain documentation of key determinants of PILT payments for each community to help ensure that payments are consistent with the agreed-upon bases of PILT payments and PILT goals. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: In May 2020, DOE officials told us that DOE convened a working group to identify high-level options for the PILT program and recommend appropriate changes to DOE leadership. According to DOE officials, the working group will consider GAO's findings and recommendations.

Recommendation: The Secretary of Energy should direct DOE's Office of the Chief Financial Officer to revise DOE's PILT order to require DOE site offices to review key determinants of PILT payments in communities' PILT invoices for accuracy and consistency with the agreed-upon bases of PILT payments and PILT goals and for DOE headquarters to document its review and validation of site office determinations. (Recommendation 2)

Agency: Department of Energy
Status: Open

Comments: In May 2020, DOE officials told us that DOE convened a working group to identify high-level options for the PILT program and recommend appropriate changes to DOE leadership. According to DOE officials, the working group will consider GAO's findings and recommendations.

Recommendation: The Secretary of Energy should direct DOE's Office of the Chief Financial Officer to revise DOE's PILT order to provide additional guidance on how communities should calculate their payment requests for their PILT invoices. (Recommendation 3)

Agency: Department of Energy
Status: Open

Comments: In May 2020, DOE officials told us that DOE convened a working group to identify high-level options for the PILT program and recommend appropriate changes to DOE leadership. According to DOE officials, the working group will consider GAO's findings and recommendations.

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 Chairman of FCC should ensure that FCC's Office of Managing Director follows the leading practices in GAO's fraud risk framework related to a dedicated entity's management of its antifraud activities, such as serving as the repository of knowledge on fraud risks and coordinating antifraud initiatives. (Recommendation 1)

Agency: Federal Communications Commission
Status: Open

Comments: As of April 2020, FCC reported that the agency was undertaking further improvements of its fraud risk management program consistent with this recommendation. FCC did not indicate a completion date. We will continue to monitor FCC's progress related to establishing a dedicated antifraud management entity.

Recommendation: The Chairman of FCC should plan regular fraud-risk assessments tailored to the high-cost program and assess these risks to determine the program's fraud risk profile, as provided in GAO's fraud risk framework. (Recommendation 2)

Agency: Federal Communications Commission
Status: Open

Comments: As of April 2020, FCC reported that the agency was working with the Universal Service Administrative Company (USAC), which is the entity responsible for the day-to-day administration of the high-cost program, to implement this recommendation. FCC stated that USAC will conduct a fraud risk assessment of the high-cost program, but did not specify a time-frame for this effort. We will continue to review FCC and USAC's progress toward completing this assessment, and any steps taken to routinize this assessment.

Recommendation: The Chairman of FCC should design and implement an antifraud strategy for the high-cost program with specific control activities, based upon the results of fraud-risk assessments and a corresponding fraud risk profile, as provided in GAO's fraud risk framework. (Recommendation 3)

Agency: Federal Communications Commission
Status: Open

Comments: As of April 2020, FCC reported that the agency was working with the Universal Service Administrative Company (USAC), which is the entity responsible for the day-to-day administration of the high-cost program, to implement this recommendation. FCC reported it will ensure the results of the high-cost program's fraud risk assessment, along with other efforts to implement the GAO fraud risk framework, result in an overall fraud risk strategy. FCC did not indicate a completion date for these efforts, and we will continue to track FCC progress in this area.

Recommendation: The Chairman of FCC should assess the model-based support mechanism to determine the extent to which it produces reliable cost estimates. (Recommendation 4)

Agency: Federal Communications Commission
Status: Open

Comments: As of April 2020, FCC reported that it was considering ways to improve the model-based support mechanism for rate-of-return carriers participating in the high-cost program. FCC did not specify a time-frame for this effort. We will continue to review FCC's efforts related to this recommendation, including FCC efforts, if any, to verify the model's cost estimates.

Recommendation: The Chairman of FCC should consider whether to make use of the model-based support mechanism mandatory depending on the results of the assessment. (Recommendation 5)

Agency: Federal Communications Commission
Status: Open

Comments: As of April 2020, FCC reported that it was considering ways to improve the model-based support mechanism for rate-of-return carriers participating in the high-cost program. FCC indicated that any such improvements may help facilitate the transition of carriers from legacy support mechanisms to the model-based support mechanism. FCC did not provide a time-frame for completion of this effort. We will continue to monitor FCC's progress and efforts in regard to this recommendation.

Recommendation: The Secretary of the Navy should ensure that the Commandant of the Marine Corps updates the Marine Corps' civilian personnel budget formulation and execution policies to include guidance for the major subordinate commands to manage civilian personnel to FTEs. (Recommendation 1)

Agency: Department of Defense: Department of the Navy
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 Navy should ensure that the Commandant of the Marine Corps identifies and reconciles any differences between the Marine Corps' internal civilian personnel data and the civilian personnel data the Department of the Navy uses to support its annual budget request. (Recommendation 2)

Agency: Department of Defense: Department of the Navy
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 Army should update Army manpower guidance, or other guidance as appropriate, to ensure that all missions conducted by EOD forces, including DSCA missions, are considered in determining the required number of EOD forces. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: As of July 15, 2020, the Department of the Army has neither concurred nor non-concurred with this recommendation.

Recommendation: The Secretary of the Air Force should update Air Force manpower guidance, or other guidance as appropriate, to ensure that all missions conducted by EOD forces, including DSCA missions, are considered in determining the required number of EOD forces. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: As of July 15, 2020, the Department of the Air Force has neither concurred nor non-concurred with this recommendation.

Recommendation: The Secretary of the Navy should update Navy and Marine Corps manpower guidance, or other guidance as appropriate, to ensure that all missions conducted by EOD forces, including DSCA missions, are considered in determining the required number of EOD forces. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: As of July 15, 2020, the Department of the Navy has neither concurred nor non-concurred with this recommendation.

Recommendation: The Secretary of Defense should ensure that the Chairman of the Joint Chiefs of Staff, in collaboration with the combatant commands, incorporate into the appropriate guidance a requirement that the military services notify the Joint Staff and the affected combatant commands when the execution of VIP support missions negatively affects the preparedness of EOD units for combat-related missions. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: As of July 15, 2020, the Department of Defense has neither concurred nor non-concurred with this recommendation.

Recommendation: The Secretary of the VA should direct the Under Secretary for Health to collect complete staffing data for the Family Caregiver Program that includes Caregiver Support Program Office funded staff, VAMC funded staff, and staff that assist the program as a collateral duty at each VAMC. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation. The Veterans Health Administration (VHA) has reported that the Caregiver Support Program Office had identified a solution for identifying VHA Family Caregiver Program staff in the Human Resource (HR) Smart system. VHA reported that current full- and part-time employees funded by the Caregiver Support Program Office will be identified with a specific specialty code in HR Smart. However, as of April 2020, this capability was not yet available in HR Smart and staffing for the program continued to be manually updated and tracked. Further, the proposed use of HR Smart will still not result in complete information that the Caregiver Support Program Office can use to track all staff who support the program because according to VHA, staff that assist the program as a collateral duty and VAMC-funded staff who support the program will not be tracked through HR Smart. As of July 2020, this recommendation remains open pending further updates from VHA.

Recommendation: The Secretary of the VA should direct the Under Secretary for Health to establish a process to ensure that the Family Caregiver Program staffing data that are collected and reported to the Caregiver Support Program Office are accurate. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: VHA concurred with this recommendation. In February 2020, the Veterans Health Administration (VHA) reported that the Caregiver Support Program Office had identified a solution for identifying full-time VHA Family Caregiver Program staff in the Human Resource (HR) Smart system through the use of a specific specialty code. VHA reported that once implemented, the use of the HR SMART specialty code would provide more accurate information regarding staffing. In April 2020, VHA stated that were would also be a static field called "position skill type" that would track positions with a skill type category of caregiver and that Veterans Integrated Service Network (VISN) leads for the Family Caregiver Program would use this field to cross check the new specialty code and identify and correct any reporting inconsistencies. As of July 2020, this recommendation remains open pending further updates from VHA.

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

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

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

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

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

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

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

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

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

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

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

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

Recommendation: The Administrator of USAID should establish outcome-oriented performance measures to assess the effectiveness of USAID's reform projects. (Recommendation 1)

Agency: United States Agency for International Development
Status: Open
Priority recommendation

Comments: USAID concurs with this recommendation, and indicates it will establish a performance-monitoring plan.

Recommendation: The Administrator of USAID should ensure that the agency completes a strategic workforce plan necessary to support its reform efforts. (Recommendation 2)

Agency: United States Agency for International Development
Status: Open

Comments: USAID concurs with this recommendation. It affirmed is in the process of finalizing the strategic workforce plan that it will complete by September 30, 2019 and will submit the plan to Congress as directed. USAID stated it will also provide a framework to meet Congressionally-directed staffing levels across the Foreign Service and Civil Service.

Recommendation: The Secretary of State should ensure that the Director of State's Office of U.S. Foreign Assistance Resources conducts a review of the Section 653(a) process to identify process steps that can be streamlined or eliminated and determine the time frame needed to prepare the annual Section 653(a) report. If State determines that the time frame exceeds 30 days, the office should coordinate with other appropriate officials to submit a legislative proposal to Congress to extend the mandated time frame for submitting Section 653(a) reports. (Recommendation 1)

Agency: Department of State
Status: Open
Priority recommendation

Comments: State indicated in their letter commenting on GAO-19-600 that they concurred with this recommendation. In their comments, State said they would determine a reasonable time frame for completing the report and will coordinate with appropriate officials regarding a potential legislative proposal to Congress.

Recommendation: The Secretary of State should ensure that the Director of State's Office of U.S. Foreign Assistance Resources improves the data collection from the many sources contributing to the Section 653(a) reports, such as by enhancing their data information systems. (Recommendation 2)

Agency: Department of State
Status: Open

Comments: State indicated in their letter commenting on GAO-19-600 that they concurred with this recommendation. In their comments, State said they are taking steps to modify their Foreign Assistance Coordination and Tracking System database to improve the collection of relevant data.

Recommendation: The Secretary of State should develop a plan to address vacancies within State's Office of U.S. Foreign Assistance Resources, consulting with the USAID Administrator as appropriate. (Recommendation 3)

Agency: Department of State
Status: Open

Comments: State indicated in their letter commenting on GAO-19-600 that they concurred with this recommendation. In their comments, State said they are developing a plan in coordination with USAID to fill existing vacancies, and are recruiting State and USAID employees to serve on details to fill existing staffing gaps.

Recommendation: The Secretary of the Treasury should ensure that the Fiscal Assistant Secretary enhances existing procedures for Treasury management to perform additional reviews for restatements, reclassifications, and adjustments to beginning net position to reasonably assure that they are properly supported and accurately reported. (Recommendation 2)

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 remains open. Treasury enhanced its procedures to include additional management reviews, particularly the Financial Reports and Advisory Division Director, for restatements, reclassifications, and adjustments to beginning net position. Although FRAD took steps to enhance its review procedures, the additional review did not prevent FRAD from including descriptions in the draft CFS that were not supported by entity financial statements or from excluding some information from the CFS notes. Further steps are needed to define procedures to ensure consistent and accurate treatment of restatements, reclassifications, and adjustments to beginning net position in the CFS. We will follow-up on progress made by Treasury as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of the Treasury should ensure that the Fiscal Assistant Secretary, working in coordination with the Controller of OMB, establishes effective processes and procedures to reasonably assure that appropriate information regarding legal contingency losses is reported in the CFS. (Recommendation 4)

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 remains open. Treasury and OMB (1) increased guidance to federal entities in the Treasury Financial Manual section 2-4700; (2) included an illustrative Contingent Loss Table in OMB Circular No. A-136 for agencies to use as guidance when reporting probable and reasonably possible losses; (3) provided guidance to agencies through monthly Central Reporting Team (CRT) meetings with the agencies' financial reporting staff and at the Government Financial Management Conference; (4) communicated regularly with Department of Justice officials regarding the preparation of the government-wide legal representation letter; and (5) increased the number of Treasury staff performing the legal letter analysis. However, we noted inconsistencies among the significant component entities' financial statement note disclosures, management schedules, and legal representation letters, and the legal contingency loss information reported in the CFS, as well as inconsistencies between entities' year-end management schedules/legal representation letters and the final government-wide legal representation letter. We will follow-up on progress made by Treasury as part of our fiscal year 2020 CFS audit.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Intelligence requires that DOD components (including the military departments and the Defense Logistics Agency) monitor the use of PACS at their installations. (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 the Army should ensure that the Office of Provost Marshal General monitors the use of PACS at Army installations. (Recommendation 2)

Agency: Department of Defense: Department of the Army
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 Navy should ensure that the Commander, Navy Installations Command, monitors the use of PACS at Navy installations. (Recommendation 3)

Agency: Department of Defense: Department of the Navy
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 Navy, in coordination with the Commandant of the Marine Corps, should ensure that the Commander, Marine Corps Installations Command, monitors the use of PACS at Marine Corps installations. (Recommendation 4)

Agency: Department of Defense: Department of the Navy
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 develops appropriate performance measures and associated goals for the timely resolution of the Defense Biometric Identification System technical issues to facilitate improved PACS performance. (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 CMO meets DOD's September 2019 deadline for review and approval of DOD's training curriculum for cross-functional team members and their supervisors. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to an OCMO official, as of April 2020, DOD's training curriculum for cross-functional team members and their supervisors had been approved. However, as of September 2020, DOD has not provided documentation of that approval.

Recommendation: The Secretary of Defense should ensure that the CMO meets DOD's September 2019 deadline for review and approval of DOD's training curriculum for presidential appointees. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to an OCMO official, as of April 2020, DOD's training curriculum for cross-functional team members and their supervisors had been approved, and the training had been provided to presidential appointees and their staffs. However, as of September 2020, DOD has not provided documentation of that approval or training.

Recommendation: The Secretary of Defense should ensure that the CMO meets DOD's November 2019 deadline for drafting, review, and approval of DOD's report on the success and failures of cross-functional teams and final submission to the Secretary for review and approval. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to an OCMO official, as of April 2020, work on the report on the successes and failures of cross-functional teams was ongoing. We will continue to monitor DOD's process of developing its report; as of September 2020, DOD has not provided documentation of the report being drafted, reviewed, or approved.

Recommendation: The Secretary of Defense should ensure that the CMO and the electromagnetic spectrum operations cross-functional team clarify roles and responsibilities for providing administrative support and funding for the team beyond fiscal year 2019 in accordance with the memorandum establishing the team. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. In its comments on a subsequent report on the department's implementation of section 911, the department stated that funding for all Secretary of Defense-empowered cross functional teams, including the electromagnetic spectrum operations cross-functional team, was in place through fiscal year 2020, and that they were exploring options for dedicated funding for cross-functional teams in future years. As of April 2020, according to an OCMO official, these dedicated funding sources had not been established. DOD has not provided evidence of their funding as of September 2020.

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 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 Attorney General should direct the Bureau of Justice Assistance to enhance quality checks to ensure the accuracy of information in its 180-day reports about Public Safety Officers' Benefits claims related to public safety officers affected by 9/11. (Recommendation 1)

Agency: Department of Justice
Status: Open

Comments: The Bureau of Justice Assistance agreed with this recommendation. The agency said it will develop and implement quality checks to confirm the accuracy of information reported in the 180-day reports related to PSOB 9/11 claims. We will consider closing this recommendation when this effort is completed.

Recommendation: The Assistant Secretary of State for Consular Affairs should provide additional training or related resources to consular officers and locally employed staff on adjudicating E-2 visas, to cover topics that include the E-2 eligibility requirements and understanding business- and tax-related documents. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: Department of State officials stated in January 2020 that the department plans to address this recommendation by increasing the frequency and specificity of E-2 content through webinars, workshops, and cables. The Department of State also plans to develop subject matter experts on business and tax related documents that can provide consultative services on an as-needed basis. As of July 2020, Department of State officials said that they had not yet implemented these actions. We will continue to monitor the status of this recommendation.

Recommendation: The Assistant Secretary of State for Consular Affairs should develop minimum standards for E-2 company registration programs, such as standards for how often companies are to be re-vetted. (Recommendation 2)

Agency: Department of State
Status: Open

Comments: Department of State officials stated in January 2020 that the department plans to address this recommendation by incorporating into policy a 5-year mandatory review of companies registered at any post using a company registration program. As of July 2020, Department of State officials said that they had not yet implemented these actions. We will continue to monitor the status of this recommendation.

Recommendation: The Assistant Secretary of State for Consular Affairs should develop and implement a process to ensure that posts maintain required E-2 visa application documentation. (Recommendation 3)

Agency: Department of State
Status: Open

Comments: Department of State officials stated in January 2020 that the department plans to communicate a reminder to posts abroad that there is a requirement to scan required E-2 documentation into each visa applicant's record. Department of State also plans to provide regular policy guidance to consular managers at posts that adjudicate E-2 visa applications. Further, Department of State officials stated in July 2020 that the department plans to incorporate the supplemental E-2 visa application (DS-156E) into the standard online application for all nonimmigrant visa applicants (DS-160). However, the officials stated that they experienced technical challenges in doing so, and was still working to resolve the challenges as of July 2020. We will continue to monitor the status of this recommendation as the Department of State works to address the technical challenges.

Recommendation: The Under Secretary of Health should require that all failures to meet quality standards are cited as deficiencies on SVH inspections. (Recommendation 2)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VA concurred with this recommendation and, as of July 2020, had taken some initial steps to address the recommendation such as modifying the SVH contractor's contract to stop the practice of using 'recommendations' for low-level deficiencies and beginning the process of revising a VA policy to address this practice.

Recommendation: The Under Secretary of Health should develop guidance for Veterans Affairs Medical Center staff conducting optional onsite CNH reviews. (Recommendation 3)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VA concurred in principle with this recommendation and indicated in January 2020 that it had begun taking actions to address this recommendation such as developing a memo of clarification and planning the release of additional guidance for staff.

Recommendation: The Under Secretary of Health should provide information on the quality of all SVHs that is comparable to the information provided on the other nursing home settings on its Access to Care website. (Recommendation 4)

Agency: Department of Veterans Affairs: Veterans Health Administration
Status: Open

Comments: VA concurred in principle and, as of July 2020, had begun taking some steps to address this recommendation such as exploring options for presenting SVH quality measure data.

Recommendation: The Director of OMB, after consulting with key stakeholders (e.g., the Chief Financial Officers Council), should develop a strategy for ensuring that agencies communicate sufficient and timely internal control plans for effective oversight of disaster relief funds. (Recommendation 1)

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

Comments: The Office of Management and Budget (OMB) disagreed with our recommendation. In the agency's comment section of the GAO report, OMB staff stated that OMB did not believe the sufficiency or timeliness of control plans present material issues that warranted OMB action. While OMB acknowledged that almost all agency control plans were submitted after the statutory deadline, OMB staff stated that this delay in itself neither indicated the absence of controls nor the effectiveness of those controls. Further, OMB staff stated that it is agency management and not OMB that has responsibility for ensuring compliance with applicable laws and regulations. While agencies were responsible for submitting their internal control plans, federal law placed the responsibility of establishing the criteria for the internal control plans with OMB. Therefore, we believe that our recommendation is warranted. In January 2020, OMB informed us that there are no additional updates at this time regarding status, actions, or timelines to develop a strategy. We will continue to monitor agency's actions to address this recommendation.

Recommendation: We recommend that the Acting Secretary of Defense direct the Under Secretary for Acquisition and Sustainment to ensure it conducts a comprehensive assessment of the effect that its contract financing and profit policies have on the defense industry and update that assessment on a recurring basis. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with the recommendation. The Department stated that it would seek fiscal year 2020 funds to contract a study on DOD contract financing policies and their effect on the defense industry. In September 2020, DOD stated that this action would be completed by December 31, 2021. The first phase of the report is estimated to be completed September 30, 2021. The department secured funds to complete the study and a contract was awarded on April 23, 2020.

Recommendation: During the next reauthorization for surface transportation programs, Congress should consider including language in the reauthorization bill that would require DOT to develop and implement transparency measures for DOT's review and selection process for discretionary grants. Such measures should, at a minimum, help to ensure that the evaluation process is clearly communicated, that applications are consistently evaluated, and that the rationale for DOT's decisions are clearly documented. Such measures should be developed in line with Office of Management and Budget guidance, federal internal control standards, and recommended practices for evaluating and selecting discretionary grant awards (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of November 2019, Congress has not enacted a reauthorization measure for surface transportation programs. The current authorization expires on September 30, 2020.

Recommendation: The Secretary of Transportation should ensure that DOT, in its notice of funding opportunity and evaluation plan for each remaining INFRA-funding cycle, clarify the circumstances under which DOT may select applicants to receive requests for additional information. (Recommendation 1)

Agency: Department of Transportation
Status: Open

Comments: As of November 2019, DOT told us that, for the fiscal year 2020 INFRA awards, it plans to provide information in the Notice of Funding Opportunity and evaluation plan explaining under the circumstances under which additional information may be sought from applicants. DOT stated that it plans to complete these actions by March 2020. We will continue to monitor DOT's actions.

Recommendation: The Secretary of Transportation should develop procedures for each remaining INFRA-funding cycle to ensure that when additional information is requested from an applicant, the specific rationale behind the request is documented (for example, to promote geographic diversity among projects), as well as to ensure that DOT documents the rationale if similar projects were not afforded an opportunity to provide additional information. (Recommendation 2)

Agency: Department of Transportation
Status: Open

Comments: As of November 2019, DOT told us it will document the basis for seeking additional information from applicants and describe the procedures for doing so in the evaluation plan for the FY 2020 INFRA awards, which it expects to conclude by September 2020. We will continue to monitor DOT's actions.

Recommendation: The Secretary of Transportation should ensure that DOT provides information to applicants in its notice of funding opportunity for each remaining INFRA-funding cycle regarding: (1) how scores on merit criteria are used, if at all, to determine whether projects advance to the Secretary for selection, and (2) how, if at all, DOT plans to use merit scores to determine which projects should receive an award. (Recommendation 3)

Agency: Department of Transportation
Status: Open

Comments: As of November 2019, DOT told us that, for the fiscal year 2020 INFRA awards, it plans to provide information in the Notice of Funding Opportunity that will more clearly state (1) that projects are advanced to the Secretary based on how they are evaluated against the selection criteria and (2) how evaluations against the selection criteria are used to determine which projects should receive awards. DOT stated that it plans to issue the Notice of Funding Opportunity by March 2020. We will continue to monitor DOT's actions.

Recommendation: The Chief Operating Officer of Federal Student Aid should obtain data in order to verify income information for borrowers reporting zero income on IDR applications. For example, Education could pursue access to federal data sources or obtain access to an appropriate private data source. (Recommendation 1)

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

Comments: Education generally agreed with this recommendation. Education stated that the President's fiscal year 2020 budget request includes a proposal that Congress pass legislation allowing the IRS to disclose tax return information directly to the department for the purpose of administering certain federal student financial aid programs. According to the agency, such legislation, if enacted, would allow borrowers to more easily certify their income on an annual basis to maintain enrollment in IDR plans, and allow the department to use the information to mitigate improper payments to borrowers as a result of misreported income data. Section 3 of the Fostering Undergraduate Talent by Unlocking Resources for Education Act (FUTURE Act), enacted in December 2019, provided Education with statutory authority to access certain Internal Revenue Service data for the purpose of determining eligibility for IDR plans, among other things (Public Law 116-91). As of August 2020, Education had begun planning for the implementation of the legislation. The Congressional Budget Office estimated that use of this authority to verify eligibility for IDR plans could result in over $2 billion in savings for 2020-2029.

Recommendation: The Chief Operating Officer of Federal Student Aid should implement data analytic practices, such as data matching, and follow-up procedures to review and verify that borrowers reporting zero income on IDR applications do not have sources of taxable income at the time of their application. (Recommendation 2)

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

Comments: Education agreed with this recommendation, and from January to March 2020 initiated a pilot program with three of its loan servicers to conduct additional verification of income or family size information on IDR plan applications for a random sample of borrowers each month. When initiated, the pilot focused on IDR borrowers who self-certified that they had no income or who reported certain family sizes. According to Education, selected borrowers would be asked to provide documentation to their servicers to support the income or family size reported on their IDR application. In the event errors were identified, servicers would work with the borrowers to update their applications. If these reviews resulted in changes to a borrower's monthly payment amount, the borrower would be expected to begin paying the new amount within the next 60 days. According to Education, as of the end of March 2020 when the pilot was put on hold, participating servicers selected 48,855 borrowers for verification. The verification pilot was put on hold as it implemented student loan relief for borrowers under the CARES Act in response to the COVID-19 global pandemic (Public Law 116-136). Specifically, on March 27, 2020, the CARES Act was enacted, which suspended student loan payments due, interest accrual, and involuntary collections for Direct and Federal Family Education Loans held by Education through September 30, 2020. According to Education, the Department suspended all IDR recertifications during this period. On August 8, 2020, the President issued a presidential memorandum directing the Secretary of Education to extend this relief to borrowers through December 31, 2020. Education reported that it will weigh options for resuming the pilot against other critical priorities and available resources, noting that its long-term strategy is to fully implement the authorities granted under the FUTURE Act, which provides Education with statutory authority to access certain Internal Revenue Service data for the purpose of determining eligibility for IDR plans, among other things (Public Law 116-91). GAO will continue to monitor Education's actions in this area, and will close the recommendation when Education provides documentation that it has implemented data analytic practices and follow-up procedures to review and verify that borrowers reporting zero income on IDR applications do not have sources of taxable income at the time of their application.

Recommendation: The Chief Operating Officer of Federal Student Aid should implement data analytic practices, such as data mining, and follow-up procedures to review and verify family size entries in IDR borrower applications. For example, Education could review and verify all borrower reports of family size or a subset identified as being most susceptible to fraud or error. (Recommendation 3)

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

Comments: Education agreed with this recommendation, and from January to March 2020 established a pilot program with three of its loan servicers to conduct additional verification of income or family size information on IDR plan applications for a random sample of borrowers each month. When initiated, the pilot focused on IDR borrowers who self-certified that they had no income or who reported certain family sizes. According to Education, selected borrowers would be asked to provide documentation to their servicers to support the income or family size reported on their IDR application. Education noted that under the pilot, loan servicers were required to request additional information from borrowers to verify family sizes greater than five; specifically, a statement listing each family member residing with the borrower and for whom the borrower pays at least 51 percent of the support. In the event errors were identified, servicers would work with the borrowers to update their applications. If these reviews resulted in changes to a borrower's monthly payment amount, the borrower would be expected to begin paying the new amount within the next 60 days. According to Education, as of the end of March 2020 when the pilot was put on hold, participating servicers selected 48,855 borrowers for verification. The verification pilot was put on hold as Education implemented student loan relief for borrowers under the CARES Act in response to the COVID-19 global pandemic (Public Law 116-136). Specifically, on March 27, 2020, the CARES Act was enacted, which suspended student loan payments due, interest accrual, and involuntary collections for Direct and Federal Family Education Loans held by Education through September 30, 2020. According to Education, the Department suspended all IDR recertifications during this period. On August 8, 2020, the President issued a presidential memorandum directing the Secretary of Education to extend this relief to borrowers through December 31, 2020. Education reported that it will weigh options for resuming the pilot against other critical priorities and available resources, noting that its long-term strategy is to fully implement the authorities granted under the FUTURE Act, which provides Education with statutory authority to access certain Internal Revenue Service data for the purpose of determining eligibility for IDR plans, among other things (Public Law 116-91). GAO will continue to monitor Education's actions in this area, and will close the recommendation when Education provides documentation that it has implemented data analytic practices and follow-up procedures to review and verify family size entries in IDR borrower applications.

Recommendation: To improve VA's ability to plan for and align its facilities with estimated changes to veterans' needs and expectations, we recommend that the Secretary of Veterans Affairs ensure the appropriate offices and administrations develop and implement a process to assess veterans' changing expectations and disseminate this information to VAMCs. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation, but noted that it had already developed and implemented effective systems for obtaining Veterans' input in facility planning. However, we found that the information VA collects through these efforts may be limited based on our review of VA's surveys, including VSignals and the Survey of Enrollees, as well as our discussions with several Veterans Service Organizations. For example, we found that VA's efforts were limited because they either focused on overall veteran expectations without a means of assessing how they differed by demographics, or they focused on veteran satisfaction with their past experiences. Moreover, satisfaction with past experiences, as operationalized by VA for the surveys we reviewed, measured how someone is with what they received--while "expectations," as defined by VA, would measure or gain insight into what it is that someone would want, and which may or may not be what they are receiving. Thus, while satisfaction, as operationalized by VA, can be an indicator of an expectation, as defined by VA, the two are not synonymous. Although VA considers this recommendation closed, we are working with them to identify ways that expectations, as VA has defined the term, can be measured.

Recommendation: To improve VA's ability to plan for and align its facilities with estimated changes to veterans' needs and expectations, we recommend that the Secretary of Veterans Affairs ensure the appropriate offices and administrations instruct VAMCs on how to meet VA's strategic goal of incorporating veterans' changing needs and expectations into facility planning, such as by identifying certain resources or tools and directing VAMCs to use them. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open
Priority recommendation

Comments: VA agreed with the recommendation and indicated that it would instruct users on what data to use in planning and updates, which would help ensure veterans' input is incorporated where appropriate. As of its fiscal year 2021 budget justification, VA still had not provided this guidance to the VAMCs, but noted that it would provide it in scheduled facility planning calls that were expected to start in the second quarter of fiscal year 2020.

Recommendation: To improve VA's ability to plan for and align its facilities with estimated changes to veterans' needs and expectations, we recommend that the Secretary of Veterans Affairs ensure the appropriate offices and administrations provide additional instruction to VAMCs on how to incorporate the concept of foundational health services into facility planning. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with this recommendation and noted that it would clarify prior guidance on the foundational health services for VAMCs, which it expected to complete in June 2019. In November 2019, VA told us that it had reviewed this prior guidance from August 2017 that had defined foundational services, and has rescinded it. However, we are working with VA to determine if this decision to rescind the prior guidance was distributed to VAMCs.

Recommendation: To improve VA's ability to plan for and align its facilities with estimated changes to veterans' needs and expectations, we recommend that the Secretary of Veterans Affairs ensure the appropriate offices and administrations systematically gather feedback from facility planners and address (as necessary) their concerns with the reliability of the SCIP process, including providing additional information on how SCIP's space estimates are derived. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open
Priority recommendation

Comments: VA agreed with this recommendation and indicated that it would update its training instructions to facility planners by adding an explanation of how SCIP space estimates are derived. In addition, VA noted that it would survey facility planners about their concerns with the SCIP space estimates, and use these results to either address the concerns or make improvements to SCIP. As of November 2019, VA had not completed the training or the survey, but noted that they are in the process of updating training materials for the FY22 SCIP planning process--which was targeted to start 2019. We will work with VA to obtain relevant documentation of these efforts.

Recommendation: The administrator of CMS should require that abuse and perpetrator type be submitted by state survey agencies in CMS's databases for deficiency, complaint, and facility-reported incident data, and that CMS systematically assess trends in these data. (Recommendation 1)

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

Comments: HHS concurred with this recommendation. In February 2020, HHS said CMS is developing the ability to review survey trends related to alleged perpetrator and alleged abuse types and aims to implement this recommendation by December 2020.

Recommendation: The administrator of CMS should develop and disseminate guidance—including a standardized form—to all state survey agencies on the information nursing homes and covered individuals should include on facility-reported incidents. (Recommendation 2)

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

Comments: HHS concurred with this recommendation. In February 2020, HHS said CMS will list the elements that all nursing homes should report to state agencies and aims to implement this recommendation by December 2020.

Recommendation: The administrator of CMS should require state survey agencies to immediately refer complaints and surveys to law enforcement (and, when applicable, to Medicaid Fraud Control Units (MFCU)) if they have a reasonable suspicion that a crime against a resident has occurred when the complaint is received. (Recommendation 3)

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

Comments: HHS concurred with this recommendation. In February 2020, HHS said CMS will require state survey agencies to immediately refer complaints upon receipt and surveys to law enforcement (and, when applicable, to Medicaid Fraud Control Units) if they have a reasonable suspicion that a crime against a resident has occurred and aims to implement this requirement by December 2020.

Recommendation: The administrator of CMS should conduct oversight of state survey agencies to ensure referrals of complaints, surveys, and substantiated incidents with reasonable suspicion of a crime are referred to law enforcement (and, when applicable, to MFCUs) in a timely fashion. (Recommendation 4)

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

Comments: HHS concurred with this recommendation. In February 2020, HHS said CMS will revise guidance to ensure state survey agencies will investigate and track incidents of abuse and neglect and report substantiated findings to local law enforcement. CMS aims to implement this recommendation by December 2020.

Recommendation: The administrator of CMS should develop guidance for state survey agencies clarifying that allegations verified by evidence should be substantiated and reported to law enforcement and state registries in cases where citing a federal deficiency may not be appropriate. (Recommendation 5)

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

Comments: HHS concurred with this recommendation. In February 2020, HHS said CMS will provide clarification to the state survey agencies regarding the definition of substantiated and when cases need to be referred to law enforcement. CMS aims to implement this recommendation by December 2020.

Recommendation: The administrator of CMS should provide guidance on what information should be contained in the referral of abuse allegations to law enforcement. (Recommendation 6)

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

Comments: HHS concurred with this recommendation. In February 2020, HHS said it will provide guidance to state agencies and nursing homes on identifying and reporting potential abuse and neglect of residents and will develop a list of standardized elements that should be included when reporting an abuse allegation to law enforcement. HHS aims to implement this recommendation by July 2020.

Recommendation: The Secretary of Labor should document internal policies and procedures for managing the IRA prohibited transaction exemption process. (Recommendation 1)

Agency: Department of Labor
Status: Open

Comments: DOL agreed with this recommendation and plans to create an internal procedure manual which will document the Office of Exemption Determinations' process for managing IRA prohibited transaction exemption applications. When we confirm what actions DOL has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Labor, in consultation with the Commissioner of Internal Revenue, should establish a formal means, such as a memorandum of understanding or other mechanism, to support and guide DOL's and IRS's collaborative efforts to oversee IRA prohibited transaction exemptions. (Recommendation 2)

Agency: Department of Labor
Status: Open

Comments: DOL agreed with this recommendation and plans to periodically discuss all IRA exemption cases with IRS and did not elaborate on the formal means for this information sharing. IRS said that it has met with DOL to formalize collaboration on exemptions from prohibited transaction treatment in IRAs. DOL agreed to contact IRS within 25 days of DOL receiving an IRA prohibited transaction exemption application to determine if there are any Internal Revenue Code issues. To avoid any disclosure concerns, DOL will not identify the applicant at that time. This new process will be reflected in DOL's forthcoming internal procedure manual for the prohibited transaction exemption process.

Recommendation: The Commissioner of Internal Revenue, in consultation with the Secretary of Labor, should establish a formal means, such as a memorandum of understanding or other mechanism, to support and guide DOL's and IRS's collaborative efforts to oversee IRA prohibited transaction exemptions. (Recommendation 3)

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

Comments: IRS agreed with this recommendation and said it has met with DOL to formalize collaboration on exemptions from prohibited transaction treatment in IRAs. DOL agreed to contact IRS within 25 days of DOL receiving an IRA prohibited transaction exemption application to determine if there are any Internal Revenue Code issues. To avoid any disclosure concerns, DOL will not identify the applicant at that time. This new process will be reflected in DOL's forthcoming internal procedure manual for the prohibited transaction exemption process.

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

Agency: General Services Administration
Status: Open

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

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

Agency: General Services Administration
Status: Open

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

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

Agency: General Services Administration
Status: Open

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

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

Agency: General Services Administration
Status: Open

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

Recommendation: The Secretary of the Interior should direct BLM to collect centralized data on the acquisition method and interest acquired for the lands it obtains using LWCF funds as part of its planned update to Legacy Rehost 2000. (Recommendation 1)

Agency: Department of the Interior
Status: Open

Comments: As of November 2019, BLM reported it had awarded a contract to develop a new data system that will allow for centralized data collection on acquisition method and ownership interest. In addition, the agency issued updated guidance and procedures related to data entry to help ensure complete and accurate recording, which will improve BLM's ability to track acquisition method and interest acquired in the interim.

Recommendation: The Secretary of the Interior should direct BLM to develop more specific guidance to ensure that land acquisition data are entered correctly into the agency's data system. (Recommendation 2)

Agency: Department of the Interior
Status: Open

Comments: As of November 2019, BLM reported it was planning to develop specific guidance to ensure land acquisition data is entered correctly into its new data system.

Recommendation: The Director of ONRR should establish an accuracy goal (e.g., identifying the number of companies or percentage of royalties subject to compliance activities over a set period of time) that aligns with the agency's mission of collecting, accounting for, and verifying royalty payments. In doing so, ONRR should track the extent to which each compliance activity (audits, compliance reviews, and data mining) contributes toward achieving this goal. (Recommendation 1)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by December 31, 2021.

Recommendation: The Director of ONRR should develop a documented case selection process that includes procedures for how to select all compliance cases. (Recommendation 2)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by April 30, 2021.

Recommendation: The Director of ONRR should develop performance measures (e.g., having a specified percentage of compliance cases identify findings of royalty noncompliance or total additional royalties) that assess whether the cases the agency is selecting are helping it achieve its compliance goals. (Recommendation 3)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by December 31, 2022.

Recommendation: The Director of ONRR should periodically analyze whether the risk model is effectively identifying potential royalty noncompliance and whether the model's results are being effectively used to assist in case selection, and should use this analysis to make changes to the model (e.g., updating it) or develop a new model. (Recommendation 4)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by June 30, 2021.

Recommendation: The Director of ONRR should include requirements in ONRR's agreements with State and Tribal Royalty Audit Committee (STRAC) members to develop a documented case selection process, including procedures for how to select compliance cases and how to document which factors were considered in selection decisions. (Recommendation 5)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by November 30, 2020.

Recommendation: The Director of ONRR should require STRAC members to describe in their annual work plans how their compliance activities would align with ONRR's current compliance goals. (Recommendation 6)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by November 30, 2020.

Recommendation: The Director of ONRR should track the performance of the compliance work of each state STRAC member and the contribution that each state makes to ONRR's compliance goals. (Recommendation 7)

Agency: Department of the Interior: Office of Natural Resources Revenue
Status: Open

Comments: In August 2020, ONRR officials stated they were on track towards implementing the recommendation by March 31, 2021.

Recommendation: The Commissioner of Fiscal Service should develop and implement a mechanism to reasonably assure that all the journal entries recorded in the Schedules of the General Fund general ledgers can be readily identified and traced, such as through a unique identifier, to determine the effect of a transaction on all applicable general ledger accounts and line items of the Schedules of the General Fund, including the budget deficit. (Recommendation 1)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should develop and implement a mechanism to reasonably assure that payment transactions recorded in the Schedules of the General Fund general ledgers capture all of the key information needed, including payment schedules if applicable, to readily trace transactions to the information certified by the federal agency. (Recommendation 2)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should develop and implement additional reporting requirements with related guidance for federal agencies that better align with the General Fund financial reporting objectives and enable Fiscal Service to capture the effect of a transaction on all applicable general ledger accounts and line items of the Schedules of the General Fund, including the budget deficit. (Recommendation 3)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: We recommend that the Commissioner of Fiscal Service develop and implement a process that would enable Fiscal Service to obtain the information necessary to effectively assess the effect of the Statement of Difference on the Schedules of the General Fund for those federal agencies that have not implemented the Central Accounting and Reporting System. (Recommendation 4)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: We recommend that the Commissioner of Fiscal Service design and implement procedures to evaluate risks and monitor internal controls over financial reporting relevant to the Schedules of the General Fund. (Recommendation 5)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should develop and implement a mechanism for evaluating agencies' use of BETCs based on the enhanced guidance. (Recommendation 7)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should design and implement procedures to (1) obtain and review supporting documentation for reported activity included on Agency Submission Forms and (2) assess the overall completeness of federal agency activity reported on Agency Submission Forms. (Recommendation 8)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should design and implement procedures to periodically review all active Treasury accounts to determine whether they are valid and the related General Fund account balances are consistent with federal agency records. (Recommendation 10)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Commissioner of Fiscal Service should enhance current procedures for reviewing negative balances to include Treasury accounts with indefinite periods of availability. (Recommendation 11)

Agency: Department of the Treasury: Bureau of the Fiscal Service
Status: Open
Priority recommendation

Comments: Fiscal Service concurred with the results of our audit. As of July 2020, Fiscal Service developed a remediation plan and efforts are underway to address this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Director of the Division of Risk Management Supervision of FDIC should take steps to improve the completeness of matters requiring board attention (MRBA) data in its tracking system, in particular, by developing a structure that allows examiners to record MRBAs at progressively more granular levels (from a broad level such as examination area to more specific levels, including risk or concern type). (Recommendation 3)

Agency: Federal Deposit Insurance Corporation
Status: Open

Comments: FDIC agreed that a structure should be enhanced to allow staff to further categories MRBAs at the point of entry into the system. As of March 2020, no action has been taken on this recommendation. GAO will continue to monitor for any updates to FDIC procedures.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials implement the necessary actions to effectively address the two primary causes of the significant deficiency in IRS's internal control over unpaid assessments. These actions should (1) resolve the system limitations affecting the recording and maintenance of reliable and appropriately classified unpaid assessments and related taxpayer data to support timely and informed management decisions, and enable appropriate financial reporting of unpaid assessment balances throughout the year, and (2) identify the control deficiencies that result in significant errors in taxpayer accounts and implement control procedures to routinely and effectively prevent, or detect and correct, such errors. (Recommendation 19-01)

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2019, IRS documented the key management decisions in the design and use of the estimation process. This step should reduce the risk that IRS may perform sampling procedures inconsistent with management intent or plans. Continued management commitment and sustained efforts are necessary to build on the progress made to date and to fully address IRS's remaining unresolved issues concerning the management and reporting of unpaid assessments. We will assess IRS's progress in addressing these issues during our audit of IRS's fiscal year 2020 financial statements.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials document and implement a formal comprehensive strategy to provide reasonable assurance concerning its nationwide coordination, consistency, and accountability for internal control over key areas of physical security. This strategy should include nationwide improvements for (1) coordinating among the functional areas involved in physical security; (2) implementing and monitoring the effectiveness of physical security policies, procedures, and internal controls; and (3) ongoing communication in identifying, documenting, and taking corrective action to resolve underlying control issues that affect IRS's facilities. (Recommendation 19-02)

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that Facilities Management and Security Services is in the process of developing and documenting a formal, comprehensive strategy. According to IRS officials, this strategy will include different overarching goals, such as improving workforce effectiveness, ensuring appropriate monitoring functions and employee accountability, and improving coordination and communication of policies and procedures. IRS plans to complete the formal, comprehensive strategy during fiscal year 2020 and finalize the implementation of this strategy by March 2021.

Recommendation: The Commissioner of Internal Revenue should ensure that appropriate IRS officials determine the reasons staff did not consistently comply with IRS's existing requirement for maintaining an emergency contact list at all of its facilities and, based on this determination, establish a process to enforce compliance with the requirement. (Recommendation 19-03)

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2019, IRS used a questionnaire survey and obtained feedback from security section chiefs and physical security specialists to determine the reasons staff did not consistently comply with IRS's existing requirement to maintain an emergency contact list at all IRS facilities. IRS officials stated that during fiscal year 2020, the Facilities Management and Security Services will establish a process to better enforce compliance with the requirement based on the results of the feedback obtained.

Recommendation: The Commissioner of Internal Revenue should ensure that appropriate IRS officials establish and implement policies and procedures requiring that corrective actions be documented in the Alarm Maintenance and Testing Certification Report for malfunctioning alarms identified in the annual alarm tests. (Recommendation 19-04)

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that during fiscal year 2020, the Facilities Management and Security Services will (1) update the Internal Revenue Manual to reflect the requirement to use the Alarm Maintenance and Testing Certification Report to document alarm testing results, including any malfunctioning alarms and related corrective actions taken, as appropriate;, and (2) review the Alarm Maintenance and Testing Certification Report Form and incorporate any additional instructions and fields to document the specific alarms tested, the testing results, and related corrective actions taken, as appropriate.

Recommendation: The Commissioner of Internal Revenue should ensure that the appropriate IRS officials establish and implement policies or procedures, or both, to provide reasonable assurance that the video surveillance systems at all IRS facilities record activity at the correct time and are properly secured. The policies or procedures should include periodic checks and adjustments, as needed, as part of the annual service and maintenance of security equipment and systems. (Recommendation 19-05)

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that during fiscal year 2020, the Facilities Management and Security Services will develop, document, and implement policies or procedures, or both, to provide reasonable assurance of the accuracy and physical security of the video surveillance systems at all IRS facilities by including periodic checks and adjustments, as needed, as part of the annual service and maintenance of security equipment.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials update and implement policies or procedures, or both, to clarify (1) who is responsible for conducting the annual review of the visitor access logs, (2) the date by which the review is to be conducted, and (3) how the review should be documented. (Recommendation 19-06)

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that during fiscal year 2020, the Information Technology and the Criminal Investigation organizations will update and implement their policies or procedures, or both, to clarify (1) who is responsible for conducting the annual review of the visitor access logs, (2) the date by which the review is to be conducted, and (3) how the review should be documented.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials (1) identify the reason IRS's policies and procedures related to the transmittal forms were not always followed and (2) design and implement actions to provide reasonable assurance that SB/SE units comply with these policies and procedures. (Recommendation 19-07)

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that the Small Business/Self-Employed (SB/SE) Field Collection organization determined that the reasons the policies and procedures were not always followed were either a lack of understanding of the requirements or a lack of consistency in adhering to them. In order to address this, in October 2019, Field Collection distributed a memorandum to its area directors, territory managers, and group managers, reminding them of the required remittance processing procedures, emphasizing the importance of following the procedures, and requesting that they distribute the information in the memorandum within their organization. IRS officials stated that the memorandum will help assure that SB/SE Field Collection units comply with the applicable policies and procedures. Since this memorandum was issued after the end of our fiscal year 2019 audit, we will review the implementation of this action during our fiscal year 2020 audit. Further, IRS officials stated that during fiscal year 2020, the SB/SE Examination organization will identify the reason that IRS's policies and procedures for transmittal forms were not followed, and based on this, it will add guidance to the applicable Internal Revenue Manual sections to clarify and supplement the service-wide guidance for the appropriate control, monitoring, and review of the forms used to transmit packages containing personally identifiable information.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials update and implement policies or procedures, or both, to clearly define the roles and responsibilities of second-level managers and IDRS security account administrators for validating the information on USR designation forms, including specifying how the information should be validated. (Recommendation 19-08)

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2019, the Information Technology (IT) organization updated IRS's Integrated Data Retrieval System (IDRS) security policy contained in the Internal Revenue Manual to ensure that the IDRS account administration process complies with IRS's personnel security policy regarding background investigation completion dates. In addition, IRS officials stated that by November 2020, the IT organization will update the Unit Security Representative (USR) designation form, as well as policies and procedures, to clearly define the roles and responsibilities of second-level managers and IDRS security account administrators for validating the information on USR designation forms, including how the information should be validated.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials update and implement procedures to clearly specify the tax refund data elements that PVS COs are required to verify before certifying the tax refunds in SPS. (Recommendation 19-09)

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

Comments: During fiscal year 2019, the Information Technology organization updated its standard operating procedures to clearly specify the tax refund data elements that the Processing Validation Section Certifying Officers are required to verify before certifying the tax refunds in the Secure Payment System. Since IRS completed this action after we had already performed our fiscal year 2019 testing related to the certification of tax refunds, we will evaluate IRS's actions to address this recommendation during our fiscal year 2020 audit.

Recommendation: The Commissioner of Internal Revenue should ensure that the appropriate IRS officials establish and implement a review process to provide reasonable assurance that the RSNs that Data Conversion key entry operators enter into the ISRP system and post to the master files are correct. (Recommendation 19-10)

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

Comments: IRS actions to address this recommendation are ongoing. IRS officials stated that during fiscal year 2020, the Wage & Investment organization will establish and implement a review process to provide reasonable assurance that the Refund Schedule Numbers on manual refund forms are transcribed accurately into the Integrated Submission and Remittance Processing system.

Recommendation: The Commissioner of Internal Revenue should ensure that the appropriate IRS officials implement a validity check in the ISRP system to confirm that RSNs that Data Conversion key entry operators enter into the system have the required 14 digits. (Recommendation 19-11)

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

Comments: IRS officials stated that the Wage and Investment organization agrees that developing and implementing a Unified Work Request for programming changes is needed to systemically validate the refund schedule numbers input into the Integrated Submission and Remittance Processing system; however, IRS officials indicated that the organization is unable to commit to implementing a corrective action because of budgetary constraints. As a result, IRS will place this recommendation on hold until funds are available.

Recommendation: We recommend that the Commissioner of Internal Revenue ensure that the appropriate IRS officials update and implement policies or procedures, or both, to require that reviewers follow up with tax examiners to verify the errors that tax examiners made in working on cases related to suspicious or questionable tax returns are corrected. (Recommendation 19-12)

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

Comments: IRS's actions to address this recommendation are ongoing. IRS officials stated that by April 2020, IRS will update and implement policies or procedures, or both, requiring that reviewers follow up with tax examiners to verify that the errors tax examiners made in working a case related to suspicious or questionable tax returns are corrected.

Recommendation: The Secretary of Commerce should direct the Director of the Census Bureau to direct the Census Bureau's Chief Information Officer (CIO) to take steps to ensure that identified corrective actions for cybersecurity weaknesses are implemented within prescribed time frames. (Recommendation 1)

Agency: Department of Commerce
Status: Open
Priority recommendation

Comments: Commerce agreed with our recommendation. It provided an action plan in August 2019. We will review the Bureau's progress in addressing this recommendation as part of our ongoing work on the 2020 Census.

Recommendation: The Secretary of Commerce should direct the Director of the Census Bureau to direct the Bureau's CIO to implement a formal process for tracking and executing appropriate corrective actions to remediate cybersecurity weaknesses identified by DHS, and expeditiously address the identified deficiencies. (Recommendation 2)

Agency: Department of Commerce
Status: Open
Priority recommendation

Comments: Commerce agreed with our recommendation. In August 2019, the Bureau stated that it is developing a process for tracking and executing corrective actions identified by governing bodies and external entities. We will review the Bureau's progress in addressing this recommendation as part of our ongoing work on the 2020 Census.

Recommendation: The Secretary of Defense should ensure that the F-35 program office assesses whether the Operational Requirements Document (ORD) R&M targets are still feasible and revise the ORD accordingly. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation and stated that it would review its Reliability & Maintainability (R&M) requirements and possibly revise them. In late 2019, the F-35 Program Executive Officer (PEO) developed an initiative to clearly identify what, if any, revisions DOD should make to the ORD. As of July 2020, no additional actions have been taken.

Recommendation: The Secretary of Defense should ensure that the F-35 program office, as it revises its Reliability and Maintainability Improvement Program (RMIP), identifies specific and measurable R&M objectives in its RMIP guidance. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation and stated that it would update its Reliability & Maintainability (R&M) RMIP guidance. In late 2019, DOD reported that a revised RMIP will be delivered to program leadership for approval. As of July 2020, no additional actions have been taken.

Recommendation: The Secretary of Defense should ensure that the F-35 program office, as it revises its RMIP, identifies and documents which RMIP projects will achieve the identified objectives of the RMIP guidance. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation and stated that it would update its RMIP guidance. In late 2019, DOD reported that a revised RMIP will be delivered to program leadership for approval. As of July 2020, no additional actions have been taken.

Recommendation: The Secretary of Defense should ensure that the F-35 program office prioritizes funding for the RMIP. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation and stated that it would plan for R&M funding going forward. In Sept. 2019, the F-35 Program Office reported that it was coordinating with the services to increase its Reliability & Maintainability investment. In Nov. 2019, the F-35 Program Office reported that it would allocate significant additional funding for RMIP for calendar year 2020. As of July 2020, no additional actions have been taken.

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 Administrator of CMS should develop and communicate a policy that defines when changes to a pending section 1115 demonstration application are considered major and should prompt a new review of the application against the transparency requirements applicable to the pending application. (Recommendation 1)

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

Comments: In response to this recommendation, HHS stated that existing regulations permit CMS at its discretion to direct an additional public comment period when states make a modification to an application that substantially changes the design. In July 2020, CMS officials said the agency would continue to exercise its regulatory discretion as needed and planned no further action in response to this recommendation. In light of past CMS decisions to not require states to first seek public comment before submitting major changes to their demonstration applications, we maintain that a policy is needed defining when changes are considered major and should prompt a new review of the application against transparency requirements. We will continue to monitor CMS's actions in this area.

Recommendation: The Administrator of CMS should develop and communicate a policy whereby applications for section 1115 demonstration amendments that may have significant impact are subject to transparency requirements comparable to those for new demonstrations and extensions. (Recommendation 2)

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

Comments: HHS stated that it plans to implement a policy applying state public input processes and application criteria to amendments proposing significant or substantial changes in the same manner as for new demonstrations. In July 2020, CMS stated the agency plans to develop criteria for determining whether an amendment application proposes a substantial change to an existing demonstration and to include this in guidance by early 2021. We will continue to monitor CMS's actions in this area and will close this recommendation once this policy guidance is issued.

Recommendation: The Secretary of the Navy should ensure that the Deputy Commandant for the Office of Programs and Resources oversee development and implementation of an approach to enable tracking of unit-level training funds through the budget cycle. This approach should include aligning MCPCs across the Marine Corps and ensuring consistent use of SIC codes. (Recommendation 1)

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

Comments: As of August 2020, the Navy has informed GAO that efforts to address this recommendation are underway. The Marine Corps has in process a Planning, Programming, Budgeting, and Execution (PPBE) reform initiative that it expects to provide visibility and traceability throughout the budget cycle, to include enabling the tracking of unit-level training funds throughout the budget cycle. DOD expects to complete implementation by the end of fiscal year 2025. We will continue to monitor actions taken related to this recommendation and provide updates as appropriate.

Recommendation: The Secretary of the Navy should ensure that the Commandant of the Marine Corps designates a single entity responsible for directing, overseeing, and coordinating efforts to achieve the objective of establishing an enterprise-wide performance management process that links resources to readiness. (Recommendation 2)

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

Comments: As of August 2020, the Navy has informed GAO that efforts to address this recommendation are underway through its Planning, Programming, Budgeting, and Execution (PPBE) reform initiative. The initiative is expected to result in the addition of an "Assessment" phase to the PPBE process, which will be known as "PPBEA." The new phase is expected to include a system that incorporates campaign planning against traceability of funding, among other factors, and will be documented in a new Marine Corps Order to replace existing PPBE guidance. The Marine Corps expects to complete this process by the end of fiscal year 2025. We will continue to monitor actions taken related to this recommendation and provide updates as appropriate.

Recommendation: The Secretary of the Navy should ensure that the Commandant of the Marine Corps assesses C2RAM to determine the extent to which this system, or elements of this system, should be adapted for use in an enterprise-wide performance management process linking resources to readiness. (Recommendation 3)

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

Comments: As of August 2020, the Navy has informed GAO that efforts to address this recommendation are underway. The Marine Corps' Programs and Resources Department is supporting the transition of the Cost to Run a MEF (C2RAM) from a stand-alone database to a web-enabled platform within the Marine Corps Training Information Management System (MCTIMS) program. The Marine Corps expects this platform to provide the ability to track ground unit-level training costs as they pertain to readiness goals and provide data to more effectively assess readiness investments for subsequent budget cycles. The Marine Corps expects the platform to attain initial operational capability for data input and data management by the end of fiscal year 2020, and to support analytics reporting and predictive resourcing functions by the end of fiscal year 2021. We will continue to monitor actions taken related to this recommendation and provide updates as appropriate.

Recommendation: The Secretary of Energy should take action to educate and communicate the agency's scientific integrity polices to staff through, for example, regular training. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: In July 2020, DOE provided an update on the status of this recommendation. In that update, DOE said the scientific integrity official will be responsible for leading and coordinating with other elements of the Department, in the development of measures to educate and communicate DOE's scientific integrity policies to staff.

Recommendation: The Secretary of Energy should establish steps and a time frame for designating a scientific integrity official to oversee the department's scientific integrity activities. (Recommendation 3)

Agency: Department of Energy
Status: Open

Comments: In July 2020, DOE provided an update on the status of this recommendation. In that update, DOE said that it was still in the process of identifying an individual to serve as a scientific integrity official.

Recommendation: The Secretary of Energy should develop mechanisms to regularly monitor and evaluate implementation of the department's scientific integrity policy, including mechanisms to remediate identified deficiencies and make improvements where necessary. (Recommendation 4)

Agency: Department of Energy
Status: Open

Comments: In July 2020, DOE provided an update on the status of this recommendation. In that update, DOE stated that the Department's scientific integrity official will have the responsibility to lead and coordinate with other elements of the Department in developing procedures to monitor and evaluate the implementation of DOE's scientific integrity policy, including mechanisms to remediate identified deficiencies and make improvements where necessary.

Recommendation: The Secretary of Transportation should develop mechanisms to regularly monitor and evaluate implementation of the department's scientific integrity policy, including mechanisms to remediate identified deficiencies and make improvements where necessary. (Recommendation 5)

Agency: Department of Transportation
Status: Open

Comments: In September 2020, the Department of Transportation provided an update on the status of this recommendation. In that update, officials said that DOT was still working on this action. According to officials, the department will implement several mechanisms to address the recommendation, including conducting annual reviews of the scientific integrity policy and making the policy available to all relevant employees. DOT estimated it would complete these actions by the end of March 2021.

Recommendation: The Director of NIST should develop mechanisms to regularly monitor and evaluate implementation of the agency's scientific integrity policy, including mechanisms to remediate identified deficiencies and make improvements where necessary. (Recommendation 6)

Agency: Department of Commerce: National Institute of Standards and Technology
Status: Open

Comments: In Commerce's written comments, NIST had stated that, beginning in fiscal year 2019, the agency would review implementation of its policy at least annually and make recommendations to the Director of NIST as to whether any improvements were needed. In a September 2020 update, NIST provided a memorandum reporting that in fiscal year 2019 the Scientific Integrity Officer and General Counsel had discussed an allegation related to scientific integrity, and that it was determined that programmatic factors, not a lapse in scientific integrity, had occurred. According to NIST, it monitors the effectiveness of the implementation of its documented scientific integrity policy, order, and procedure by means of informal feedback from NIST researchers and supervisors, as documented in the memorandum.

Recommendation: The NOAA Administrator should develop mechanisms to regularly monitor and evaluate implementation of the agency's scientific integrity policy, including mechanisms to remediate identified deficiencies and make improvements where necessary. (Recommendation 7)

Agency: Department of Commerce: National Oceanic and Atmospheric Administration
Status: Open

Comments: In Commerce's written comments, NOAA stated that it will identify additional metrics for monitoring and evaluating its policy. As of October 2020, we have requested an update from the agency but have not yet received information to evaluate implementation of this recommendation.

Recommendation: The Director of USGS should develop mechanisms to regularly monitor and evaluate implementation of the agency's scientific integrity policy, including mechanisms to remediate identified deficiencies and make improvements where necessary. (Recommendation 8)

Agency: U.S. Geological Survey
Status: Open

Comments: In September 2020, the Department of the Interior provided an update on this recommendation. In that update, officials stated that the expected completion date is the end of November 2022.

Recommendation: The Secretary of Energy should develop documented procedures for identifying and addressing alleged violations of its scientific integrity policy. (Recommendation 9)

Agency: Department of Energy
Status: Open

Comments: In July 2020, DOE provided an update on the status of this recommendation. In that update, DOE stated that the department's scientific integrity official will be responsible for leading and coordinating with other elements of the Department in developing procedures for identifying and addressing alleged violations of DOE's scientific integrity policy.

Recommendation: The Administrator of NASA should develop documented procedures for identifying and addressing alleged violations of its scientific integrity policy. (Recommendation 10)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: NASA officials stated that the agency is undergoing additional internal and external reviews-with NASA officials working through the National Science and Technology Council's Joint Committee on Research Environments, which supports scientific security, rigor, and integrity-and that completion of the implementation of the recommendation is due October 31, 2020.

Recommendation: The Commissioner of Internal Revenue should finalize the PDC program objectives so that they are clearly defined in consistent terms, and assure that the key program risks, measures, and targets are linked with the objectives. (Recommendation 1)

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

Comments: IRS partially agreed with recommendation. IRS said it would use consistent terms in developing measures that link to its PDC program objectives, but did not agree that program objectives are necessarily framed in terms of program risks. In December 2019, IRS provided new objectives linked with proposed measures to assess collection agencies. In February 2020, IRS said it intends to award new contracts in 2021 that will include performance measures linked to program objectives. To fully address GAO's recommendation, IRS also needs to identify targets for measures linked to program objectives.

Recommendation: The Commissioner of Internal Revenue should include the Department of the Treasury Inspector General for Tax Administration (TIGTA) costs in IRS's reporting of PDC program costs. (Recommendation 2)

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

Comments: IRS disagreed with the recommendation. In October 2019 IRS said that including TIGTA costs in reporting program costs would be inconsistent with legislative requirements that define program costs as IRS's costs and with IRS cost-accounting practices. However, we maintain that the FAST Act set minimum reporting requirements to which IRS can add more information. Also, the existing cost accounting standards and practices to which IRS refers govern IRS's accounting for and reporting of costs incurred by IRS, not to fuller reporting of the PDC program's costs to the federal government. We will continue to pursue this recommendation and update its status in response to any changes.

Recommendation: The Commissioner of Internal Revenue should report the amount of collected revenue sent to the general fund of the Treasury and amounts retained by IRS to pay its costs. (Recommendation 3)

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

Comments: IRS agreed with our recommendation and in October 2019 said it plans to report PDC revenue amounts going to the Treasury and to IRS's retained funds by February 2020. As of March 2020, we had not received documentation from IRS to demonstrate it had done so.

Recommendation: The Commissioner of Internal Revenue should analyze PDC program results to identify the types of cases that are not potentially collectible and should not be assigned to collection agencies. (Recommendation 4)

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

Comments: IRS disagreed with the recommendation and said such analysis is unnecessary due to a legal requirement to assign all such cases to collection agencies and because there is very little cost in doing so. Our report noted that IRS has the authority and responsibility for efficient program operations to not assign uncollectible debt cases. In February 2020, IRS said that the assignment and recall of cases add nothing to the cost. We disagree, noting that IRS has not supported this assertion. IRS incurred some portion of its PDC costs from assigning and recalling cases that collected no revenue. Even if these costs are minor, they would be greater than the amount collected. We maintain the importance of this recommendation because IRS has incurred tens of millions of dollars in costs with little or no revenue collected for most of the PDC cases that IRS has closed.

Recommendation: The Commissioner of Internal Revenue should analyze PDC program results and the cases not assigned to the PDC program to identify the types of inactive cases IRS will not pursue that could be assigned to collection agencies to improve PDC program results. (Recommendation 5)

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

Comments: IRS agreed and noted that it already had the recommended analyses built into the PDC case identification process. IRS also provided documentation to GAO in December 2019 and its comments in February 2020 repeated its view that its process already identified other inactive cases that have not been assigned to PDC. IRS's documentation during the review and provided in December did not show how IRS analyzes its debt inventory and PDC results to identify inactive cases that are not being assigned to PDC but may be worth pursuing.

Recommendation: The Commissioner of Internal Revenue should clearly document and distinguish the complete list of identified risks to taxpayers in the PDC program risk register, and align the risks with PDC program objectives. (Recommendation 6)

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

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019, on actions taken to implement the recommendation. IRS actions included a risk register with related information on the analyses and response to the listed risks.

Recommendation: The Commissioner of Internal Revenue should clearly document the severity of impacts of the taxpayer risks, as well as the likelihood of each taxpayer risk after responding to it, in the PDC program risk register, and use this information to prioritize risks to address and guide selection of risk responses. (Recommendation 7)

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

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019, on actions taken to implement the recommendation. IRS actions included a risk register with related information on the analyses and response to the listed risks.

Recommendation: The Commissioner of Internal Revenue should clearly document how each risk response aligns with specific taxpayer risks in the PDC program risk register. (Recommendation 8)

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

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019, on actions taken to implement the recommendation. IRS actions included a risk register with related information on the analyses and response to the listed risks.

Recommendation: The Commissioner of Internal Revenue should document how IRS's monitoring of the PDC program provides information on specific taxpayer risks and how well specific responses are working to address each risk, and should supplement IRS's monitoring of taxpayer complaints with Federal Trade Commission (FTC) complaint data. (Recommendation 9)

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

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019 on actions taken to implement the recommendation, such as outreach to FTC on its system to record the complaints.

Recommendation: The Commissioner of Internal Revenue should more fully seek and document feedback from external stakeholders representing vulnerable taxpayers to identify and appropriately respond to possible PDC taxpayer risks. (Recommendation 10)

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

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019 on actions taken to implement the recommendation, such as a system to record feedback received.

Recommendation: The Commissioner of Internal Revenue should clearly document an assessment of fraud risks related to the PDC program. (Recommendation 11)

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

Comments: IRS agreed with the recommendation and said that by June 2020, it would conduct a fraud risk assessment based on the Fraud Reduction and Data Analytics Act of 2015 and OMB guidance. We will update the status when we complete review of any documentation IRS provides on actions taken to implement the recommendation.

Recommendation: The Commissioner of Internal Revenue should ensure that its printed guidance to PDC taxpayers includes information about reporting scams to TIGTA. (Recommendation 12)

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

Comments: IRS agreed with the recommendation. We will update the status after completing review of documentation IRS provided in December 2019 on actions taken to implement the recommendation.

Recommendation: The Administrator of CMS should institute a process to routinely assess, and take steps to ensure, as appropriate, that Medicare and Medicaid documentation requirements are necessary and effective at demonstrating compliance with coverage policies while appropriately addressing program risks. (Recommendation 1)

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

Comments: The Department of Health and Human Services concurred with this recommendation. In February 2020, the Centers for Medicare & Medicaid Services (CMS) noted that it had clarified and amended several Medicare documentation requirements as part of an agency initiative to assess such requirements. CMS further stated that Medicaid documentation requirements are generally established at the state level, and that the agency has taken steps to identify best practices for documentation requirements and share them with states. However, we believe that CMS still needs to take steps to assess documentation requirements in both programs to better understand how the variation in the programs' requirements affects estimated improper payment rates. Without an assessment of how the programs' documentation requirements affect estimates of improper payments, CMS may not have the information it needs to ensure that Medicare and Medicaid documentation requirements are effective at demonstrating compliance and appropriately address program risks.

Recommendation: The Administrator of CMS should take steps to ensure that Medicaid medical reviews provide robust information about and result in corrective actions that effectively address the underlying causes of improper payments. Such steps could include adjusting the sampling approach to reflect state-specific program risks, and working with state Medicaid agencies to leverage other sources of information, such as state auditor and the Department of Health and Human Services' Office of the Inspector General findings. (Recommendation 2)

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

Comments: The Department of Health and Human Services (HHS) did not concur with this recommendation. As of September 2020, HHS has stated that it does not plan to implement this recommendation because the agency believes the resource requirement is not justified based on the potential improper payment findings. HHS further stated that the agency already uses a variety of sources to identify and take corrective actions to address underlying causes of improper Medicaid payments. However, we found that the Centers for Medicare & Medicaid Services (CMS) and state Medicaid agencies are expending time and resources developing and implementing corrective actions that may not be representative of the underlying causes of improper payments in their states. Without robust information to effectively identify the underlying causes of improper payments, CMS and state Medicaid agencies may not develop corrective actions that effectively address Medicaid program risks.

Recommendation: The Administrator of CMS should take steps to minimize the potential for Payment Error Rate Measurement (PERM) medical reviews to compromise fraud investigations, such as by directing states to determine whether providers selected for PERM medical reviews are also under fraud investigation and to assess whether such reviews could compromise investigations. (Recommendation 3)

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

Comments: The Department of Health and Human Services (HHS) concurred with this recommendation. In October 2019, the Centers for Medicare & Medicaid Services (CMS) updated Medicaid Payment Error Rate Measurement (PERM) program guidance to strongly encourage state Medicaid agencies to proactively review providers selected for the state's PERM review; determine whether any of the selected providers are subjects of current or impending fraud investigations; and assess whether a PERM review could compromise the fraud investigation. CMS included this clarification in updated contractor guidance and in information provided to state Medicaid agencies. CMS plans to include the updated guidance in the fiscal year 2019 PERM program manual, which CMS anticipates completing by the end of 2019. Such revisions to the PERM manual will further codify and encourage state efforts to prevent PERM reviews from potentially compromising ongoing fraud investigations. As of September 2020, CMS has not informed us of any additional actions taken to implement this recommendation, including of any revisions to the PERM manual; we will update the status of this recommendation when we receive additional information.

Recommendation: The Administrator of CMS should address disincentives for state Medicaid agencies to notify the PERM contractor of providers under fraud investigation. This could include educating state officials about the benefits of reporting providers under fraud investigation, and taking actions such as revising how claims from providers under fraud investigation are accounted for in state-specific FFS improper payment rates, or the need for corrective actions in such cases. (Recommendation 4)

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

Comments: The Department of Health and Human Services (HHS) concurred with this recommendation. In October 2019, the Centers for Medicare & Medicaid Services (CMS) noted that the agency updated Medicaid Payment Error Rate Measurement (PERM) guidance regarding state Medicaid agencies' corrective action plans for providers under fraud investigation. If a state Medicaid agency opts to remove a provider from the state's PERM review due to a fraud investigation, claims associated with the provider are determined to be improper, due to no documentation. Under the updated guidance, states are no longer required to develop a corrective action plan for such claims, since the state is already addressing the issue through a fraud investigation. CMS included this updated guidance in the fiscal year 2017 PERM corrective action plan template, and plans to include the updated guidance in the fiscal year 2019 PERM program manual, which CMS anticipates completing by the end of 2019. Such revisions to the PERM manual will remove a disincentive for state Medicaid agencies to notify the PERM contractor of providers under fraud investigation. As of September 2020, CMS has not informed us of any additional actions taken to implement this recommendation, including of any revisions to the PERM manual; we will update the status of this recommendation when we receive additional information.

Recommendation: The Commissioner of the IRS should fully implement the workforce planning initiative, including taking the following actions: (1) conducting enterprise strategy and planning, (2) conducting workforce analysis, (3) creating a workforce plan, (4) implementing the workforce plan, and (5) monitoring and evaluating the results. (Recommendation 1)

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

Comments: IRS agreed with this recommendation. As of February 2020, the Internal Revenue Service (IRS) reported it has hired or made final offers to new members of its Workforce Planning branch that will help implement the Workforce Planning initiative. According to IRS, the agency is updating its workforce planning policy, and will establish a workforce plan including an enterprise strategy and initiate related workforce analysis by December 2020. By December 2021, IRS expects to implement the workforce plan and a process to monitor and evaluate the results of the workforce plan. Full implementation of a workforce plan that provides a comprehensive inventory of its current workforce will allow IRS to develop competency and staffing requirements to conduct agency-wide activities associated with identifying and addressing skills gaps.

Recommendation: The Secretary of the Treasury should issue clarifying guidance to IRS about the Integrated Talent Management system, including when the workforce planning and talent management modules will be deployed and available for IRS's use, the functions it will include, and how IRS's existing systems and processes within business divisions and program offices will be affected. (Recommendation 2)

Agency: Department of the Treasury
Status: Open

Comments: Treasury agreed with the recommendation. Treasury stated that it has taken actions to ensure that IRS and all Treasury bureaus have a clear understanding of when the ITM workforce planning module will be available and how it will be used. Treasury stated that they conducted a Workforce Planning offsite in May 2019 to (1) ensure a common understanding of the workforce planning process as it relates to ITM; 2) document the process in preparation of utilizing ITM; and 3) agree on how the agency will accomplish workforce planning in ITM. According to Treasury, goals 1 and 2 were achieved during the offsite and the workforce planning community continues to work on the third goal. Treasury expects to complete the discussion on how to accomplish workforce planning in ITM by the end of calendar year 2019. Treasury's Offices of the Chief Human Capital Officer and the Chief Information Officer are responsible for ensuring effective communication and training are completed as each ITM module is implemented. We will continue to monitor Treasury's progress in implementing this recommendation.

Recommendation: The Commissioner of IRS should ensure the Human Capital Officer improves reporting for its workforce planning initiative in its bi-monthly HRstat information submissions to Treasury. The submissions should include the original implementation schedule, changes to the original schedule, delays in implementation and each of their causes, and IRS's strategy to address the causes of those delays. (Recommendation 3)

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

Comments: IRS agrees with this recommendation. In its recommendation status letter to us, IRS wrote that they will include workforce planning in their bi-monthly HRstat information submissions to Treasury, and will have an approved implementation schedule for the workforce planning initiative by December 2019. IRS identified the Human Capital Officer as the responsible official for addressing this recommendation. We will continue to monitor IRS's progress in implementing this recommendation.

Recommendation: The Commissioner of IRS should ensure the Human Capital Officer and Deputy Commissioner for Services and Enforcement report the results of efforts to close skills gaps among revenue agents, including lessons learned, that may help inform strategies for conducting skills gap assessment efforts for other mission critical occupations. (Recommendation 4)

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

Comments: IRS agrees with this recommendation. In its recommendation status letter to us, IRS provided a timetable for implementation. By January 2021, IRS will initiate use of Integrated Talent Management's (ITM) capability to enable workforce planning and analytics. They are still working through requirements and the implementation plan for using this system. By December 2021, IRS will report the results of efforts to close skills gaps among revenue agents, including lessons learned on an annual basis over the next three fiscal years. IRS identified the Human Capital Officer and Deputy Commissioner for Services and Enforcement as the officials responsible for addressing this recommendation. In our 2019 Duplication, Overlap, and Fragmentation report, we determined implementing this recommendation is needed to address IRS's fragmented human capital activities to improve its strategic workforce planning so it can better meet challenges to achieving its mission. We will continue to monitor IRS's progress in implementing this recommendation.

Recommendation: The Commissioner of IRS should ensure the Human Capital Officer and Deputy Commissioner for Services and Enforcement collaborate to develop a work plan or other mechanism that prioritizes and schedules skills assessments for mission critical occupations at highest risk of skills gaps, such as those identified by Treasury or where key activities have been scaled back, for the purposes of developing a strategy to close the gaps. (Recommendation 5)

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

Comments: IRS agreed with the recommendation. As of February 2020, IRS reported that it expects to fully implement this action by June 15, 2020. IRS reported that full implementation of related actions has been delayed due to limited resources. To date, the IRS Human Capital Officer has (1) identified mission critical occupations (MCOs), (2) collaborated with the Employment, Talent and Security (ETS) Division to develop an implementation schedule for the assessments, (3) obtained the Worklife Benefits and Performance Division and ETS Division Directors' approval of the implementation schedule, and (4) published and distributed the schedule. Going forward, the IRS Human Capital Office will coordinate with the Chief Financial Office and the Deputy Commissioner for Services and Enforcement in developing a work plan or other mechanism that prioritizes and schedules skills assessments for mission critical occupations. IRS will also validate its list of 22 positions established in coordination with Treasury. A work plan for addressing MCOs and skills gaps could help IRS identify and close skills gaps on a timely basis. Without such a plan, IRS risks continuing to scale back on mission-critical activities, adding to the existing fragmentation of its human capital planning efforts.

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should conduct a comprehensive review of the physical inspection process. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should resume calculating the sampling error associated with the physical inspection score for each property, identify what changes may be needed for HUD to use sampling error results, and consider those results when determining whether more frequent inspections or enforcement actions are needed. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should develop comprehensive and organized documentation of REAC's sampling methodology and develop a process to ensure that documentation is maintained going forward. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should track on a routine basis whether REAC is conducting inspections of multifamily housing properties in accordance with federal guidelines for scheduling and coordinate with the Deputy Assistant Secretary for Multifamily Housing to minimize the number of properties that can cancel or reschedule their physical inspections. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should design and implement an evaluation plan to assess the effectiveness of the Indefinite Delivery/Indefinite Quantity pilot in ensuring timely and quality inspections for properties in hard-to-staff geographic areas. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for Multifamily Housing and the Deputy Assistant Secretary for the Real Estate Assessment Center should expedite implementation of the recommendations from the Rapid Response and Resolution Team. (Recommendation 6)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should follow through on REAC's plan to create a process to verify candidate qualifications for contract inspectors—for example, by calling references and requesting documentation from candidates that supports their completion of 250 residential or commercial inspections. The plan should also consider whether certain types of inspections—such as Federal Emergency Management Agency inspections and U.S. Army Office of Housing inspections—satisfy REAC's requirements. (Recommendation 7)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should develop a process to evaluate the effectiveness of REAC's training program—for example, by reviewing the results of tests or soliciting participant feedback. (Recommendation 8)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should revise training for quality assurance inspectors to better reflect their job duties. Revised training should be documented, include expanded subject matter training, and address skills that may not be included in training for contract inspectors—for example, instructing contract inspector candidate trainings and coaching and providing feedback. (Recommendation 9)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should develop continuing education requirements for contract and quality assurance inspectors. (Recommendation 10)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should develop and implement a plan for meeting REAC's management targets for the timeliness and frequency of collaborative quality assurance reviews and quality control inspections. The plan should include consideration of resources of and demands on quality assurance inspectors, including the effect of natural disasters and other special assignments. (Recommendation 11)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should ensure that Quality Control's policies and procedures for overseeing quality assurance inspectors are implemented. (Recommendation 12)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for the Real Estate Assessment Center should review quality assurance inspector performance standards and revise them to better reflect the skills and supporting behaviors that quality assurance inspectors need to effectively contribute to REAC's mission. (Recommendation 13)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Assistant Secretary for Multifamily Housing should report to Congress on why the agency has not complied with the 2017 and 2018 Consolidated Appropriations Acts requirement to issue notices to properties when the REAC score is 60 or below, including seeking any statutory flexibilities or exceptions believed appropriate. (Recommendation 14)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Deputy Secretary of the Department of Homeland Security should develop a mechanism that aligns processes and information sources for collecting R&D project data from DHS components to ensure that the information can be collected, integrated and result in a comprehensive accounting of R&D projects DHS-wide. (Recommendation 2)

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

Comments: As of September 2020, DHS reported that S&T was revising the related DHS Directive to improve R&D project data collection and that detailed procedures for the data collection would be described in an associated guidance document. DHS further reported that S&T would be coordinating with the Undersecretary for Management, and meeting with DHS components regarding the data collection efforts. We will continue to monitor DHS's efforts to implement this recommendation.

Recommendation: The Deputy Secretary of the Department of Homeland Security should direct Office of the Chief Financial Officer program officials to ensure that S&T take steps to more fully incorporate leading practices, such as those included in DHS's budget preparation guidance, into R&D milestones. (Recommendation 3)

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

Comments: As of September 2020, S&T reported preparing Budget Justification documents, which will include key milestones for R&D projects, and indicated that the documents will be reviewed by the DHS Office of the Chief Financial Officer. We will continue to monitor DHS's efforts related to this recommendation.

Recommendation: The Deputy Secretary of the Department of Homeland Security should develop standard processes and procedures for collecting and analyzing customer feedback, applicable to components conducting R&D, for improving the usefulness of existing customer feedback mechanisms to assess R&D efforts and for implementing such mechanisms where absent. (Recommendation 4)

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

Comments: As of September 2020, DHS stated that a new DHS Directive and Instruction is being developed related to R&D customer and program feedback. This recommendation remains open, and we will continue to monitor DHS's efforts to address it.

Recommendation: The Secretary of State should continue to work with the Permanent Representative to the United Nations to ensure that UN peacekeeping operations fully meet principles of effective peacekeeping. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: The Department of State (State) agreed with this recommendation and stated that, as the report details, the United States has achieved significant successes increasing the effectiveness and efficiency of UN peacekeeping operations. According to State officials, the five peacekeeping principles provide a framework for honest, strategic reviews of peacekeeping operations in order to continue working to ensure that the UN is performing at its highest level in-country, and that the United States and United States taxpayers are receiving the best value for our financial contributions. U.S. leadership and effective collaboration within the UN Security Council has led to smart reductions of over $800 million in the UN peacekeeping budget since July 2016. In response to analysis of conditions on the ground, State has worked with the UN to reconfigure missions in Haiti and Darfur, bolstered the mission in the Central African Republic, made the mission in Lebanon more relevant to the challenges to peace presented by Hizballah, closed the mission in Cote d'Ivoire, and more. The United States will continue to engage in close interagency cooperation, as well as strong advocacy within the UN Security Council to continue improving UN peacekeeping. GAO will continue to monitor State's actions related to this recommendation and update information accordingly.

Recommendation: The Secretary of State should work with the Permanent Representative to the United Nations to ensure that the United Nations provides information to member states on the estimated costs of mandated peacekeeping tasks to provide better cost information when the Security Council adjusts peacekeeping mandates. (Recommendation 2)

Agency: Department of State
Status: Open

Comments: The Department of State (State) agreed with this recommendation, noting that the report correctly states that there is a need for better financial information related to UN peacekeeping operations. While the UN Secretariat provides a large volume of financial information to the Fifth Committee of the General Assembly, that information does not correlate well with changes that the Security Council makes to specific peacekeeping mandates. Instead, the financial information represents the totality of resources that the UN Secretariat estimates needing to accomplish a given peacekeeping mission's overall mandate. Achieving the desired level of detail will require changes to UN financial management practices and reporting to the Fifth Committee. The United States will work to advance these changes, which may require adoption through a resolution by the UN General Assembly. In the meantime and in the absence of that structural change, the United States will continue to closely scrutinize all proposed UN peacekeeping budgets to ensure to the extent possible that approved resource levels are realistic and afford missions the ability to implement their mandates, based in part on historical forecasting and expenditure patterns. With the implementation of the UN reform agenda and the expected and related UN cultural shift to one that is results based in 2019 and beyond, the United States will continue to advocate for greater transparency and accountability in the use of peacekeeping resources. GAO will continue to monitor State's actions related to this recommendation and update information accordingly.

Recommendation: The Secretary of State should continue to work with the Permanent Representative to the United Nations to ensure that the United Nations takes additional steps to address member states' concerns about complete and timely information on the performance of United Nations peacekeeping operations. (Recommendation 3)

Agency: Department of State
Status: Open

Comments: The Department of State (State) agreed with this recommendation, noting that the United States has been a leader on the UN Security Council in order to create a "culture of performance" in UN peacekeeping. The United States drafted and achieved Security Council approval of resolution 2436 in September 2018, the first-ever resolution focused on improving the performance of UN peacekeeping, and implementing a system of accountability. This resolution calls for a timely and transparent reporting process for performance failures, real accountability measures for when these failures occur, and the application of objective criteria - data, not politics - to match the right police and troops with the right peacekeeping roles. The United States will continue to work with the UN Secretary-General, the Security Council, General Assembly, UN Secretariat, as well as troop- and police-contributing countries in order to ensure effective implementation of resolution 2436 going forward. GAO will continue to monitor State's actions related to this recommendation and update information accordingly.

Recommendation: The Director of ICE should build on existing efforts to use data analytics by employing techniques, such as network analysis, to identify potential fraud indicators in schools petitioning for certification. (Recommendation 2)

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

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ICE should develop an implementation plan for the project aimed at strengthening background checks for DSOs; that plan should outline how the project will be executed, monitored, and controlled. (Recommendation 5)

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

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ICE should implement mandatory DSO training and verify that the training is completed. (Recommendation 6)

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

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ICE should complete the development and implementation of its plans for mandatory fraud-specific training for DSOs. (Recommendation 7)

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

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. 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 (1) develop a process for periodically reviewing Federal Procurement Data System-Next Generation (FPDS-NG) data to determine the extent to which agencies are awarding WOSB program set-asides under ineligible North American Industry Classification System (NAICS) codes and (2) take steps to address any issues identified, such as providing targeted outreach or training to agencies making awards under ineligible codes. (Recommendation 1)

Agency: Small Business Administration
Status: Open

Comments: In May 2019, SBA analyzed FPDS-NG data to review the use of ineligible NAICS codes in the WOSB program. SBA officials also noted that they plan to conduct these reviews on an ongoing basis. As part of their May 2019 analysis, SBA identified federal agencies that had used ineligible NAICS codes. As of October 2019, SBA officials said that they were taking steps, including drafting presentation materials, to provide training on NAICS codes to agencies and planned to present quarterly at the Small Business Procurement Advisory Council FY 2020 meetings. SBA officials also noted that they had also provided training on NAICS codes as part of its FY 2019 performance reviews of procurement centers.

Recommendation: The Secretary of Labor should direct its subagencies, other than ETA, to design and implement a process to manage and administer grantees' compliance with the Stevens Amendment, including determining to what extent to provide guidance to grantees on calculations. (Recommendation 1)

Agency: Department of Labor
Status: Open

Comments: In responding to the report, DOL stated that it concurs with the recommendation. DOL's subagency, OSHA, provided written comments and stated that it generally agreed with GAO's recommendation. On March 3, 2020, DOL staff said the agency will provide an update to its response to this recommendation, along with responses to open recommendations from other GAO reports, in several months.

Recommendation: The Secretary of Education should design and implement a process to manage and administer grantees' compliance with the Stevens Amendment, including determining to what extent to provide guidance to grantees on calculations. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: In a subsequent response to the report, Education stated that it concurred with GAO's recommendation and is considering enhancing its current approach to overseeing compliance with the Stevens Amendment through post-award monitoring activities. On March 9, 2020, an Education Department Official stated that the planned date that work is due to be completed by the applicable program office is 9/30/2020. According to the official, the work will promote consistency across applicable grant programs and enhance their monitoring efforts. The official further stated that Education will develop general monitoring guidance to further check on compliance with the Stevens Amendment for implementation across Education's grantmaking Principal Offices. As a part of monitoring, program offices will be expected to review the Stevens Amendment statutory requirements with grantees and plans to reiterate that grantees are required to disclose for their grant project the percent of the costs financed with federal funds, the federal dollar amount, and the percentage and dollar amount financed by nongovernmental funds when issuing statements, press releases, bid solicitations, and other documents describing their grant project. Education also plans to remind grantees that they must document how the dollar amounts and percentages were calculated in the disclosures and maintain this documentation with their grant file. We will update the action taken in response to this recommendation when further action is confirmed.

Recommendation: Congress should consider legislation requiring comprehensive and timely information on political appointees serving in the executive branch to be collected and made publicly accessible. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of April 2020, no bills have been introduced related to this matter. When we determine what steps the Congress has taken, we will provide updated information.

Recommendation: The Administrator of the Small Business Administration should implement procedures to track and verify that required employees complete initial ethics training and that completion of this training is documented. (Recommendation 1)

Agency: Small Business Administration
Status: Open

Comments: SBA officials provided documentation, including internal operating procedures for certifying and tracking initial ethics training, to support that they have taken initial steps to address our recommendation. In a letter dated September 13, 2019, SBA's Designated Agency Ethics Official stated that, since February 2019, SBA has used those procedures to document the provision of initial ethics training to political appointees. In that letter, SBA stated that it planned to provide additional documentation to GAO to support this action. When we receive this documentation, we will assess the implementation of SBA;s new procedures to confirm that, in operation, these procedures meet the intent of our recommendation.

Recommendation: The Secretary of the Interior should direct the Departmental Ethics Office, in conjunction with the Chief Human Capital Officer, to develop, document, and implement a strategic workforce planning process that aligns with its ongoing departmental reorganization and that is tailored to the specific needs of the ethics program. As part of this process, Interior should monitor and assess the critical skills and competencies that its ethics program needs presently and is projected to need in the future. (Recommendation 2)

Agency: Department of the Interior
Status: Open

Comments: In a letter dated September 10, 2019, Interior's Assistant Secretary for Policy, Management and Budget stated that Interior concurred with this recommendation and is in the process of reorganizing the Department's ethics program, including working with the Chief Human Capital Officer to develop and implement strategic workforce planning. Interior expects to complete this action by December 31, 2021. When we can confirm what actions Interior has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of the Interior should ensure that the department's ethics program policies and procedures are documented and easily accessible to program staff. (Recommendation 3)

Agency: Department of the Interior
Status: Open

Comments: In a letter dated September 10, 2019, Interior's Assistant Secretary for Policy, Management and Budget stated that Interior concurred with this recommendation and is in the process of developing ethics program policies and procedures. Interior expects to complete this action by December 31, 2021. Once finalized, Interior plans to make ethics program policies and procedures easily accessible to the program staff. When we can confirm what actions Interior has taken in response to this recommendation, we will provide updated information.

Recommendation: The Commissioner of Internal Revenue should direct USCA to ensure that APMA staff record and track contact with taxpayers. (Recommendation 2)

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

Comments: IRS agreed with GAO's recommendation. As of July 2020, IRS has taken steps to develop and implement an integrated case inventory and management system capable of recording and tracking taxpayer contacts. It expects this system to be deployed by October 2020.

Recommendation: The Commissioner of Internal Revenue should direct USCA to ensure that APMA staff record and track the hours they spend on MAP cases. (Recommendation 3)

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

Comments: IRS agreed with GAO's recommendation. As of July 2020, IRS has taken steps to develop and implement an integrated case inventory and management system capable of tracking actual time worked on cases. It expects this system to be deployed by October 2020.

Recommendation: The Commissioner of Internal Revenue should direct USCA to ensure that Advance Pricing and Mutual Agreement Program (APMA) identify and record the dates of key milestones throughout MAP case resolutions. (Recommendation 4)

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

Comments: IRS agreed with GAO's recommendation. As of July 2020, IRS plans to review its current practices in order to ensure they are in line with the GAO's recommendation with respect to MAP cases, as well as APA cases. IRS has taken steps to develop and implement an integrated case inventory and management system that it expects to deploy by October 2020.

Recommendation: The Commissioner of Internal Revenue should direct USCA to ensure that APMA puts procedures in place to review the quality of inventory data. (Recommendation 5)

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

Comments: IRS agreed with GAO's recommendation. As of July 2020, IRS has taken steps to develop and implement an integrated case inventory and time management system for APMA's MAP (and other) cases that it believes will help it quickly identify when case and inventory data do not meet quality standards. The new system is expected to be deployed by October 2020.

Recommendation: The Commissioner of Internal Revenue should direct USCA to ensure that APMA records the dollar amounts of MAP case outcomes in its database. (Recommendation 6)

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

Comments: IRS agreed with GAO's recommendation. As of July 2020, IRS has taken steps to record these amounts in the inventory management system that is expected to be deployed by October 2020.

Recommendation: The Commissioner of Internal Revenue should direct USCA to ensure that APMA analyzes trends in case characteristics as part of routine program management activities. (Recommendation 7)

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

Comments: IRS agreed with GAO's recommendation. As of July 2020, IRS is exploring ways to examine correlations between case management and administrative characteristics as part of ongoing, routine measurement of stages of the MAP.

Recommendation: The Commissioner of Internal Revenue should direct USCA to ensure that APMA identify and record categories of the tax issue relevant in the dispute. (Recommendation 8)

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

Comments: IRS agreed with GAO's recommendation. APMA already tracks issue classification data for completed APA cases for its annual report to Congress on the APA program, and IRS agrees that a similar system can and should be pursued for MAP cases. Implementing an integrated inventory management system capable of tracking these data across both MAP and APA cases would be especially informative and helpful for APMA management. As of July 2020, the IRS has taken steps to develop and implement such a system. It is expected to be deployed by October 2020..

Recommendation: The Secretary of Defense should ensure that the Army, in coordination with CYBERCOM and the National Cryptologic School, where appropriate, establish a time frame to validate all of the phase two foundational training courses for which it is responsible. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with the recommendation. According to a DOD status report on implementing the recommendations for GAO-19-362 that was provided to us in February 2020, the Army is performing a validation pilot for its Cyberspace Operations Planners Course. After that validation pilot is complete, the Army will establish a time frame for validating its other courses.

Recommendation: The Secretary of Defense should ensure that the Air Force, in coordination with CYBERCOM and the National Cryptologic School, where appropriate, establish a time frame to validate all of the phase two foundational training courses for which it is responsible. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with the recommendation. According to a DOD status report on implementing the recommendations for GAO-19-362 that was provided to us in February 2020, the Air Force is coordinating with U.S. Cyber Command to obtain a final determination on the validated knowledge, skills, and abilities; proficiency standards, and skills for the various work roles supported by this training. The Air Force is responsible for developing curriculum for seven of the Cyber Mission Force workroles. DOD estimates that it will take 2 to 4 years to complete validation for all of the courses supporting these workroles.

Recommendation: The Secretary of the Army should ensure that Army Cyber Command coordinate with CYBERCOM to develop a plan that comprehensively assesses and identifies specific CMF training requirements for phases two (foundational), three (collective), and four (sustainment), in order to maintain the appropriate sizing and deployment of personnel across the Army's CMF teams. (Recommendation 3)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: 3. DOD agreed with the recommendation. According to a DOD status report on implementing the recommendations for GAO-19-362 that was provided to us in February 2020, the Army's implementation of this recommendation is dependent upon U.S. Cyber Command establishing master training task lists for phases 2 and 3 of the training. The Army estimates it will complete all required actions to validate phase 2 of its Cyber Mission Force training requirements by June 2020, phase 3 by October 2020, and phase 4 by January 2021.

Recommendation: The Secretary of the Navy should ensure that Fleet Cyber Command coordinate with CYBERCOM to develop a plan that comprehensively assesses and identifies specific CMF training requirements for phases three (collective) and four (sustainment) in order to maintain the appropriate sizing and deployment of personnel across the Navy's CMF teams. (Recommendation 4)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD agreed with the recommendation. According to a DOD status report on implementing the recommendations for GAO-19-362 that was provided to us in February 2020, the Navy plans to identify the specific training requirements for phase 3 Cyber Mission Force training by October 31, 2020. Additionally, the Navy reported that it published a policy memorandum establishing a 24-month continuous training and certification cycle for its Cyber Mission Force Teams to address its phase 4 training requirements.

Recommendation: The Secretary of the Air Force should ensure that Air Forces Cyber coordinate with CYBERCOM to develop a plan that comprehensively assesses and identifies specific CMF training requirements for phases two (foundational), three (collective), and four (sustainment), in order to maintain the appropriate sizing and deployment of personnel across the Air Force's CMF teams. (Recommendation 5)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD agreed with our recommendation. According to a DOD status report on implementing the recommendations for GAO-19-362 that was provided to us in February 2020, the Air Force's phase 2 training plan is contingent upon the completion of U.S. Cyber Command validating the tasks, knowledge, skills, abilities, and proficiency levels that establish the training baseline. Those products are still in coordination and are not finalized. The Air Force did not provide timeframes by which it would be able to develop training plans for its phase 2, 3, and 4 training requirements.

Recommendation: The Commandant of the Marine Corps should ensure that Marine Corps Forces Cyberspace coordinate with CYBERCOM to develop a plan that comprehensively assesses and identifies specific CMF training requirements for phases two (foundational), three (collective), and four (sustainment), in order to maintain the appropriate sizing and deployment of personnel across the Marine Corps' CMF teams. (Recommendation 6)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD agreed with our recommendation. According to a DOD status report on implementing the recommendations for GAO-19-362 that was provided to us in February 2020, the Marine Corps is still developing its response to comprehensively assess and identify Cyber Mission Force training requirements for phases two , three, and four.

Recommendation: The Secretary of Defense should ensure that the commander of CYBERCOM develops and documents a plan for establishing independent assessors to evaluate CMF phase three collective training certification events. (Recommendation 7)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with our recommendation. According to a DOD status report on implementing the recommendations for GAO-19-362 that was provided to us in February 2020, U.S. Cyber Command established procedures for assessing teams participating in Joint Exercise Program collective training events. These procedures include the use of highly skilled and independent assessors from deployable training teams and other units to conduct standard assessments using U.S. Cyber Command criteria. DOD reports that the command has captured lessons learned from these procedures and will promulgate a command-wide instruction to further standardize assessments across the force and guide the development of automated assessments conducted with the Persistent Cyber Training Environment. DOD further reports that the procedures described above were first used in the CYBERFLAG 19-1 exercise in June 2019. We are in the process of obtaining documentation from that exercise to verify these procedures.

Recommendation: The Secretary of Defense should ensure that the commander of CYBERCOM establishes and disseminates the master training task lists covered by each phase two foundational training course and convey them to the military services, in accordance with the CMF Training Transition Plan. (Recommendation 8)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with our recommendation. According to a DOD status report on implementing the recommendations for GAO-19-362 that was provided to us in February 2020, U.S. Cyber Command will complete this task in September 2020. DOD reports that U.S. Cyber Command has established and made individual training standards available through the Joint Cyber Training and Certification Standards to all services prior to the training transition in October 2018. In October 2019, DOD approved a new organizational structure and new Mission Essential Tasks for Cyber Protection Teams. The training standards were updated and provided to the services, who are using them to validate and develop Joint Curriculum. DOD is currently reviewing a U.S. Cyber Command proposal for the organization and mission essential tasks for Cyber Mission Teams and Cyber Support Teams. Pending DOD approval, U.S. Cyber Command will update and publish revisions to the individual training standards.

Recommendation: The Director of BLM should identify the reasons internal control reviews were not completed (e.g., human capital and workforce), develop and implement a plan to address those reasons, and monitor state offices' progress toward completing required reviews. (Recommendation 1)

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

Comments: In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. Specifically, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook or Instruction Memorandum. BLM also wrote that it is establishing teams to conduct internal control reviews, monitoring the status of any past-due reviews and actively engaging across its multiple state offices to ensure timely resolution. In late August 2020, BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: The Director of BLM should develop and document procedures for implementing internal control reviews under the July 2012 oversight policy. (Recommendation 2)

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

Comments: In responding to our report, BLM stated that its July 2012 oversight policy, which expired in September 2013, should not have been allowed to lapse and given the importance of internal control reviews, the bureau will continue to use the July 2012 policy to conduct future reviews. In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. In addition, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook, or Instruction Memorandum. In late August 2020. BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: The Director of BLM should implement a risk-informed approach to scheduling and conducting internal control reviews that takes into account the risks to BLM's mission, such as those inherent in field offices' workload and workforce. (Recommendation 3)

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

Comments: In July 2019, BLM's Assistant Secretary for Land and Minerals Management wrote a letter to GAO stating that the bureau agreed that there are additional opportunities to improve the Inspection and Enforcement program's internal control reviews and that policies should be updated and widely circulated. Specifically, BLM wrote that by early August 2020, the bureau will issue updated guidance and procedures for conducting internal control reviews and that this guidance would take the form of a manual, handbook, or Instruction Memorandum. In addition, BLM noted that the guidance will help ensure that the bureau completes internal control reviews in a timely manner using a consistent risk-based approach. In late August 2020. BLM's Audit Liaison Officer informed GAO that due to competing workload priorities and key management vacancies, BLM now plans to implement this recommendation by the end of June 2021.

Recommendation: We recommend that the Director, DCMA, in collaboration with the Director, DCAA, develop a mechanism to monitor and assess whether contractor business systems reviews are being completed in a timely manner. (Recommendation 1)

Agency: Department of Defense: Defense Contract Management Agency
Status: Open

Comments: DCMA concurred with our recommendation and the department notified us in March 2019 that collaboration between DCMA and DCAA to develop a mechanism to increase oversight and improve management of contractor business system audits and determinations had begun. In September 2019, DCMA and DCAA provided lists of the business system reviews planned to be conducted during fiscal year 2020, showing that the data needed for oversight of all CBS reviews is available between the two agencies. Further, an April 2019 DCMA memorandum indicated that DCAA data on planned reviews for fiscal years 2019 and 2020 had been transferred to DCMA and that administrate contracting officers were to conduct risk assessments to identify additional reviews for DCAA to complete in the future. In August 2020, DCMA and DCAA specified the sources of the data provided earlier; DCAA data is collected through its strategic workload and resource initiative and inputted into the DCAA Management Information System while DCMA business system review data continues to be maintained by the functional offices responsible for those reviews. Both agencies stated that progress against planned reviews is tracked and status is reported to management at regular intervals. DCMA also noted a series of new tools designed to enhance surveillance of contractor business systems and implementation of corrective actions. These steps indicate progress towards increased insight into both the completion CBS review and the follow-up that occurs afterward. However It remains unclear to what extent data sharing between DCAA and DCMA to support CBS review planning has been formalized and will continue or the extent to which DCMA headquarters uses this data to assess implementation of its policies for the conduct of CBS reviews.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in coordination with the Chairman of the Joint Chiefs of Staff, issue a more detailed implementation plan or include implementation plan details in identified formal department-wide guidance to include a description of the resources (i.e., relevant operational and financial information) required to implement the plan including dollar and personnel amounts. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. On February 25, 2020, DOD issued its revised Pre-Positioned War Reserve Materiel Strategic Implementation Plan. However, the updated plan did not include a description of the resources-- including dollar and personnel amounts--required to implement the plan. Instead, the updated plan states that no additional personnel or resources will be required to execute and manage the plan, and that those personnel executing and managing the plan are expected to do so in addition to their normal duties. In May 2020, DOD stated it intends to include additional information about the required resources in the plan's next revision. We will keep this recommendation open pending our review of the next iteration of the plan.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in coordination with the Chairman of the Joint Chiefs of Staff, take steps to fully implement joint oversight of DODs prepositioned stock programs, including providing detailed information on how to implement such an oversight approach in department guidance and reviewing other joint oversight efforts, in order to synchronize the military services' preposition stock strategies to avoid fragmentation. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. On February 25, 2020, DOD issued its revised Pre-Positioned War Reserve Materiel Strategic Implementation Plan which lays out a method for joint oversight. While GAO is encouraged and will monitor DOD's implementation efforts, it is too soon to determine the extent to which these efforts-when completed-will address DOD's fragmented management of its prepositioned stock programs. To fully address this recommendation, DOD needs to fully implement the joint oversight method outlined in the plan.

Recommendation: The Director of EPA's Office of Superfund Remediation and Technology Innovation should develop a regular review process to ensure the quality of Superfund Enterprise Management System (SEMS) data identifying NPL sites on tribal property and revise automated reports used to check the accuracy of SEMS data to include on tribal property data. (Recommendation 1)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA concurred with our recommendation. EPA stated that during the course of our work on this report, SEMS tribal data was reviewed for quality control and corrections were made to the existing data. In addition, EPA's Office of Superfund Remediation and Technology Innovation plans to create a schedule to review tribal data in SEMS and disseminate tribal data to Superfund regional coordinators annually for their quality assurance review starting in April 2019.

Recommendation: The Director of EPA's Office of Superfund Remediation and Technology Innovation should clarify agency guidance regarding tribal consultation for the Superfund program to clearly identify the circumstances under which the agency should consider consulting with tribes. (Recommendation 3)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA concurred with our recommendation. EPA plans to issue a memo to regions that clarifies circumstances under which regions may consider tribal consultation for the Superfund program by March 2020.

Recommendation: The Assistant Administrator of EPA's Office of International and Tribal Affairs should develop or revise existing guidance to clearly direct regional officials to document all invitations to consult with tribes in the Tribal Consultation Opportunity Tracking System database and provide the guidance to those officials. (Recommendation 4)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA concurred with our recommendation and planned four actions in response. According to EPA, it (1) issued a memorandum to all Assistant Administrators and Regional Administrators on the importance of tribal consultation in April 2019; (2) plans to issue monthly TCOTS report to Deputy Assistant Administrators and Regional Assistant Administrators on the status of consultations recorded in TCOTS; (3) developed training slides targeted to EPA's Regional Superfund staff on when and how to document consultation actions in TCOTS, presented during the annual 2019 National Association of Remedial Project Managers training in August 2019; and (4) revised a training module and draft TCOTS User Guide with particular emphasis on entering consultation information into TCOTS, with trainings scheduled in 2019.

Recommendation: The IRS Commissioner should work with the Department of the Treasury to consider clarifying if transfers of unclaimed savings from employer-based plans (such as 401(k) plans) to states are distributions, what, if any, tax reporting and withholding requirements apply, and when they apply. (Recommendation 1)

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

Comments: IRS agreed with this recommendation and stated that it would work with Treasury to consider clarifying the issues raised by this recommendation.

Recommendation: The IRS Commissioner should work with the Department of the Treasury to consider adding retirement savings transferred to states from terminating DC plans to the list of permitted reasons for rolling over savings after the 60-day rollover period, in a form consistent with the rules adopted on the taxation of transfers of unclaimed retirement savings. (Recommendation 2)

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

Comments: IRS agreed with this recommendation and stated that it would work with Treasury to consider addressing the issues outlined in this recommendation.

Recommendation: The Secretary of Labor should specify the circumstances, if any, under which uncashed distribution checks from active plans can be transferred to the states. (Recommendation 3)

Agency: Department of Labor
Status: Open

Comments: DOL neither agreed nor disagreed with this recommendation. However, DOL stated it plans to continue to evaluate whether there are circumstances in which the transfer of uncashed distribution checks from an ongoing plan to the states advances the goal of reuniting missing participants with their savings, which is consistent with this recommendation. We commend DOL for recognizing the importance of this issue and will monitor the agency's efforts to address this recommendation.

Recommendation: The Secretary of Health and Human Services should revise HHS's process for conducting improper payment risk assessments for Head Start to help ensure that it results in a reliable assessment of whether the program is susceptible to significant improper payments. This should include preparing sufficient documentation to support its risk assessments. (Recommendation 1)

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: The Department of Health and Human Services (HHS) concurred with this recommendation. In fiscal year 2019, HHS reported that it utilized Microsoft SharePoint to facilitate and begin to automate the Improper Payment Risk Assessment process. According to HHS, the SharePoint risk assessment form included the added ability to track the status of submissions and collect any applicable supporting documentation. Also, HHS stated that the Assistant Secretary for Financial Resources staff discussed the importance of maintaining supporting documentation during the fiscal year 2019 Improper Payment Risk Assessment Kick-Off meeting with HHS's operating divisions, and also built this feature into the SharePoint form. In fiscal year 2020, HHS reported that the implementation of the long-term solution to conducting improper payment risk assessments, the Risk Assessment Portal (previously called the Automated Improper Payment Framework), is underway and went into production in March 2020. Additionally, HHS indicated that it has revised its improper payment questionnaire and scoring process to ensure HHS performs a reliable assessment of susceptibility to significant improper payments. Also, HHS stated that it will leverage the Risk Assessment Portal, new questionnaire, and revised scoring process in the fiscal year 2020 risk assessment reporting period. Further, HHS stated that it is reviewing GAO reports and resources, capturing best practices from other agencies, and soliciting feedback from HHS's operating divisions to further improve its processes. Last, HHS stated that it will continue to develop policies, procedures, and supporting tools throughout calendar year 2020. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Secretary of Health and Human Services should revise HHS's procedures for conducting improper payment risk assessments to help ensure that all programs and activities are assessed for susceptibility to significant improper payments at least once every 3 years, as required by IPIA. (Recommendation 2)

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: The Department of Health and Human Services (HHS) concurred with this recommendation. In fiscal year 2019, HHS reported that it utilized DATA Act information to create an inventory of programs and activities that could potentially be subject to improper payment risk assessment requirements. According to HHS, it developed a risk-based methodology for selecting programs and activities for review using the DATA Act files. Data fields within the DATA Act files allow HHS to further analyze the program and activity inventory. For example, the object class data enabled HHS to categorize the program's spending to provide insight into each program's unique risks. HHS stated that this methodology was used and documented in fiscal year 2019 but HHS plans to further refine and finalize this approach. In fiscal year 2020, HHS reported that its Office of the Inspector General (OIG) is currently reviewing the methodology as part of the Annual Inspector General review of HHS's improper payment reporting under the Improper Payments Elimination and Recovery Act of 2020. HHS stated that it will implement any feedback from the OIG, as well as lessons learned from the fiscal year 2019 and fiscal year 2020 risk assessment reporting period, in fiscal year 2021. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: The Attorney General should revise DOJ's process for conducting improper payment risk assessments for Law Enforcement to help ensure that it results in a reliable assessment of whether the program is susceptible to significant improper payments. This should include preparing sufficient documentation to support DOJ's risk assessments. (Recommendation 4)

Agency: Department of Justice
Status: Open
Priority recommendation

Comments: The Department of Justice (DOJ) did not concur with this recommendation. In January 2020, DOJ reiterated that it continues to not concur with the recommendation. DOJ stated that its risk assessment methodology provides DOJ management with a reasonable basis for determining whether the law enforcement program, as well as DOJ's other four mission-aligned programs, are susceptible to significant improper payments. In addition, DOJ reiterated that it continues to not concur with GAO's conclusion that DOJ's risk assessment documentation is not adequate. DOJ stated that its documentation meets all of the requirements in the Improper Payments Information Act of 2002 (IPIA), as amended, and the Office of Management and Budget's (OMB) implementing guidance. Therefore, DOJ stated that it does not believe it would be a prudent use of limited resources to expand on the documentation that already exists. DOJ stated that notwithstanding its differences from GAO on the recommendation, it will continue to examine its risk assessment methodology. Finally, DOJ stated that its goal has been, and continues to be, meeting the requirements of IPIA, as amended, and OMB's implementing guidance in a cost effective manner. We continue to believe this recommendation is appropriate because DOJ's risk assessment documentation did not adequately demonstrate how DOJ determined the weighting of the risk factors or the numerical risk level ranges or whether a program is or is not susceptible to significant improper payments. We will continue to monitor the agency's actions to address the recommendation.

Recommendation: The Assistant Secretary for Financial Institutions should annually collect and evaluate HFAs' risk assessments, which include HFAs' risk levels. (Recommendation 1)

Agency: Department of the Treasury
Status: Open

Comments: According to Treasury, as of March 2019, the agency had requested that each Housing Finance Agency evaluate its controls and update its Risk and Control Matrix to ensure that it reflects the risk assessment level of each control that has been assessed and to provide this information to Treasury. Treasury stated that it would evaluate the risk assessments to verify that the appropriate risk level had been assessed and that proper segregation of duties exists. As of August 2020, Treasury had not demonstrated that it had annually collected or evaluated HFA's risk assessments.

Recommendation: The Secretary of the Army should ensure that the Surgeon General of the Army Medical Command (1) collaborate with the Navy Bureau of Medicine and Surgery and the Air Force Medical Service to develop a common set of planning standards to be used to help determine dental clinic staffing needs, and (2) incorporate these standards into the Army's dental corps staffing model. (Recommendation 1)

Agency: Department of Defense: Department of the Army
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 Navy should ensure that the Surgeon General of the Navy Bureau of Medicine and Surgery (1) collaborate with the Army Medical Command and the Air Force Medical Service to develop and implement a common set of planning standards to be used to help determine dental clinic staffing needs, and (2) incorporate these standards into the Navy's dental corps staffing model. (Recommendation 2)

Agency: Department of Defense: Department of the Navy
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 Air Force should ensure that the Surgeon General of the Air Force Medical Service (1) collaborate with the Army Medical Command and the Navy Bureau of Medicine and Surgery to develop and implement a common set of planning standards to be used to help determine dental clinic staffing needs, and (2) incorporate these standards into the Air Force's dental corps staffing model. (Recommendation 3)

Agency: Department of Defense: Department of the Air Force
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 Army should ensure that the Surgeon General of the Army Medical Command evaluates the effectiveness of its recruitment and retention programs for military dentists, including the need for and effectiveness of the recruitment and retention incentives currently offered. (Recommendation 4)

Agency: Department of Defense: Department of the Army
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 Navy should ensure that the Surgeon General of the Navy Bureau of Medicine and Surgery evaluates the effectiveness of its recruitment and retention programs for military dentists, including the need for and effectiveness of the recruitment and retention incentives currently offered. (Recommendation 5)

Agency: Department of Defense: Department of the Navy
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 Air Force should ensure that the Surgeon General of the Air Force Medical Service evaluates the effectiveness of its recruitment and retention programs for military dentists, including the need for and effectiveness of the recruitment and retention incentives currently offered. (Recommendation 6)

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

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

Recommendation: The Director of OMB should enhance the guidelines for agencies to establish the controls required by FRDAA, by clarifying the difference between FRDAA and ERM requirements, and through collaboration with agencies to determine what additional information agencies need to implement the controls. (Recommendation 1)

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

Comments: In March 2020, the Payment Integrity Information Act of 2019 (PIIA) was enacted to improve efforts to identify and reduce government-wide improper payments, including payments that are the result of fraud. PIIA repealed and replaced FRDAA. However, OMB and the other agencies subject to PIIA essentially must satisfy the same requirements established under FRDAA, including adhering to OMB's related guidelines. OMB has not updated its published guidelines for FRDAA as we recommended. If OMB takes additional actions to supplement guidelines under PIIA, we will review the guidelines to determine whether it addresses our recommendation.

Recommendation: The Director of OMB should enhance FRDAA reporting guidelines by directing agencies to report complete and detailed information on each of the reporting elements specified by FRDAA, which should include information related to financial and nonfinancial fraud. (Recommendation 2)

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

Comments: In March 2020, the Payment Integrity Information Act of 2019 (PIIA) was enacted to improve efforts to identify and reduce government-wide improper payments, including payments that are the result of fraud. PIIA repealed and replaced FRDAA, but maintained similar reporting requirements for federal agencies regarding fraud risks and also extended the time line for reporting by a year. OMB did not update its previous reporting guidance for FRDAA as we recommended. If OMB takes additional actions to supplement reporting guidelines under PIIA, we will review the guidelines to determine whether it addresses our recommendation.

Recommendation: The Administrator of USAID should establish additional controls to improve the consistency and completeness of performance information that USAID uses to monitor counter-trafficking in persons projects. (Recommendation 5)

Agency: United States Agency for International Development
Status: Open
Priority recommendation

Comments: USAID concurred with GAO's recommendation and has begun to take corrective action in response. In a March 11, 2019 letter to congressional committees, USAID noted its commitment to address GAO's recommendation through implementing additional controls for the agency's counter-trafficking in persons projects. Specifically, USAID commented that it was implementing data systems and taking additional steps intended to strengthen data management, improve record-keeping, increase data quality, and build capacity of local partners, with a target completion date of April 2020. As of January 2020, USAID officials noted that the agency has piloted its information management system, the Development Information Solution (DIS), in 7 USAID missions and is considering a strategy to deploy the DIS agency-wide by the end of 2021. According to USAID officials and documents, work has been completed to build DIS features that will help to improve the consistency and completeness of performance information, such as the ability to create and centrally manage customized indicators within DIS as well as centrally track and manage project activities, targets, and results. USAID has also updated its performance monitoring policy to require the completion of Performance Management Plans, within 3 months of completion of the mission's Country Development Cooperation Strategy, instead of the previously required 6 months. In addition, according to USAID officials and documents GAO reviewed, USAID and the Department of State's (State) Office of U.S. Foreign Assistance Resources have developed additional administrative reports and processes that encourage increased ownership and review of data in the FACTSinfo NextGen system, the system of record for performance information related to the expenditure of foreign assistance funds. According to USAID officials and documents GAO reviewed, in order to improve quality control for this data, USAID and State will conduct a high level administrative review of the performance reporting process, including of the participation of key stakeholders in this process, beginning in March 2020. Once USAID provides additional information to GAO, including information on steps to more fully deploy the DIS and implement changes resulting from its review of the PPR process under its new grants management data system, GAO will determine whether USAID has established additional controls to improve the consistency and completeness of performance information.

Recommendation: The Administrator of CMS should take steps to collect all of the data from all laboratories that are required to report. If only partial data can be collected, CMS should estimate how incomplete data would affect Medicare payment rates and address any significant challenges to setting accurate Medicare rates. (Recommendation 1)

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

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

Recommendation: The Administrator of CMS should phase in payment-rate reductions that start from the actual payment rates Medicare paid prior to 2018 rather than the national limitation amounts. CMS should revise these rates as soon as practicable to prevent paying more than necessary. (Recommendation 2)

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

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

Recommendation: The Administrator of CMS should use bundled rates for panel tests, consistent with its practice prior to 2018, rather than paying for them individually; if necessary, the Administrator of CMS should seek legislative authority to do so. (Recommendation 3)

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

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

Recommendation: The Administrator of the Food and Nutrition Service (FNS) should identify and disseminate strategies to states and service providers for increasing the participation of SNAP recipients referred to the SNAP E&T program. (Recommendation 1)

Agency: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service
Status: Open

Comments: FNS officials agreed with this recommendation and indicated they are taking steps towards closing it. Specifically, FNS officials said they plan to take the following actions to disseminate strategies on increasing participation among SNAP recipients referred to the SNAP E&T program: 1) update the SNAP E&T Best Practices Study to include strategies on increasing participation by December 2021; 2) publish results from Pilot Projects to Reduce Dependency and Increase Work Requirements and Work Effort Under the Supplemental Nutrition Assistance Program that include information regarding which outreach, referral, and enrollment processes are most effective by 2021; and 3) provide technical assistance through SNAP to Skills with new attention on increasing SNAP E&T participation and engagement among eligible SNAP participants. We will continue to monitor FNS's efforts to disseminate strategies through these mechanisms with a particular focus on ensuring these strategies reach both state officials and service providers.

Recommendation: The Administrator of FNS should take additional steps to address data reliability issues in the state-reported data on SNAP E&T participant characteristics and outcomes, including steps to address imprecise instructions on data collection forms and staff confusion at the state level. (Recommendation 2)

Agency: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service
Status: Open

Comments: FNS generally agreed with this recommendation. They noted that they have been providing continued technical assistance to states to improve data quality and in October 2018 made updates to the SNAP E&T data report. FNS plans or has additional changes pending to the SNAP E&T data report and SNAP Quality Control guidance that it plans to use to collect improved SNAP E&T data in fiscal year 2021. In addition, FNS plans to leverage results from data and technical assistance grants upon their completion in September 2020 to disseminate best practices to help states improve outcome reporting data. We are encouraged by FNS's efforts in these areas and will evaluate the results of these actions as we continue to monitor the agency's progress in addressing this recommendation.

Recommendation: The Administrator of FNS should determine and communicate to states how the agency will use newly reported outcome and participant characteristics data to assess the effectiveness of state SNAP E&T programs. (Recommendation 3)

Agency: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service
Status: Open

Comments: FNS officials agreed with this recommendation. FNS officials noted that with the submission of January 2019 outcome reporting measures, the agency has a complete year of data which FNS will use to establish a baseline for each State's SNAP E&T program. However, FNS has not yet articulated how the data will be used to assess effectiveness of the programs, or provided examples of how FNS has used the data to provide feedback on the effectiveness of SNAP E&T programs. We will continue to monitor FNS's efforts to communicate to the states how the outcome data can be used to assess program effectiveness.

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

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

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

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

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

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

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

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

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

Recommendation: The Secretary of Defense should ensure that the Director of the Corrosion Office, in coordination with the military departments, issues guidance to require a standard process for identifying and documenting the rationale for the annual funding levels needed to perform the duties of each Corrosion Executive. The guidance should, at a minimum, identify and define the cost elements and the methods that may be used to estimate the funding levels and describe the supporting documentation that should be maintained. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. The Corrosion Office plans to develop a standardized process for identifying annual funding levels to perform the duties of each Corrosion Executive. It plans to include this process in a new DOD manual on corrosion that it has a goal of creating by the end of calendar year 2020. We will monitor the extent to which DOD implements this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of the Corrosion Office documents, within existing or new guidance, its process for reviewing the Military Departments' Corrosion Executive Reports prior to submitting the Corrosion Office Annual Report to Congress, including a process to consistently maintain documentation of its reviews. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. The Corrosion Office plans to develop and implement a standardized operating procedure for processing and documenting its review of the Corrosion Executive Reports. It plans to complete and implement this standardized operating procedure by November 1, 2019 . We will monitor the extent to which DOD implements this recommendation.

Recommendation: The Secretary of Defense should ensure that the Director of the Corrosion Office develops a process to consistently maintain documentation of its reviews and evaluations of corrosion planning for major weapon system programs. These records, at a minimum, should show what comments were made by the Corrosion Office in its reviews and evaluations, and track the actions taken to resolve those comments. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. The Corrosion Office plans to develop and maintain a process for documenting the Office's reviews, evaluations, and comments, and to track the weapon system programs' actions on corrosion planning. It plans to include this process in a new DOD manual on corrosion that will include information on considering corrosion during the weapon system program-planning evaluation process, and to develop an internal data system for tracking purposes. Its goal is to create this new manual and internal data system is by the end of calendar year 2020. We will monitor the extent to which DOD implements this recommendation.

Recommendation: The Secretary of the Army should ensure that its Corrosion Executive issues clear guidance establishing a process for reviewing, evaluating, and documenting the adequacy of corrosion planning and oversight efforts for major weapon systems throughout the systems' life cycle, including during the early phases of the acquisition life cycle, and maintain documentation of the oversight actions. (Recommendation 4)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of the Air Force should ensure that its Corrosion Executive issues clear guidance establishing a process for reviewing, evaluating, and documenting the adequacy of corrosion planning and oversight efforts for major weapon systems throughout the systems' life cycle, including during the early phases of the acquisition life cycle, and maintain documentation of oversight actions. (Recommendation 5)

Agency: Department of Defense
Status: Open

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

Recommendation: The Director of the Departmental Enforcement Center and the Assistant Secretary for Community Planning and Development should develop written guidance for CPD's field offices to use when determining whether to make a referral to the Departmental Enforcement Center. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Director of the Departmental Enforcement Center and the Assistant Secretary for Public and Indian Housing should develop written guidance for PIH's field offices to use when determining whether to make a referral to the Departmental Enforcement Center. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Director of the Departmental Enforcement Center and the Assistant Secretary for Community Planning and Development should develop targets for the number of referrals that CPD should make to DEC that are based on program risk. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Director of the Departmental Enforcement Center and the Assistant Secretary for Public and Indian Housing should develop targets for the number of referrals that PIH should make to DEC that are based on program risk. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Director of the Departmental Enforcement Center should develop and implement performance measures that assess the outcomes, or desired results, of its enforcement activities. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Director of the Departmental Enforcement Center should develop and implement performance measures of its timeliness in completing oversight reviews. (Recommendation 6)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Director of the Departmental Enforcement Center should track the implementation of the recommendations that it makes to program offices as a result of its oversight reviews. (Recommendation 7)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Director of the Departmental Enforcement Center should develop controls to ensure that analysts consistently and reliably record dates related to referral activity, corrective action taken, and other key information used to determine DEC's impact. (Recommendation 8)

Agency: Department of Housing and Urban Development
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 Air Force should (a) establish and implement a formal process to collect and monitor information on the extent to which all implemented IGSAs have resulted in financial and nonfinancial benefits and (b) document that process in Air Force IGSA policy or procedures. (Recommendation 4)

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

Comments: The Air Force concurred with this recommendation. When we confirm what actions the Air Force has taken in response to it, we will provide updated information.

Recommendation: The Secretary of the Navy should (a) establish and implement a process to monitor whether Navy installations are evaluating opportunities for using IGSAs and to obtain explanations from installations on the outcome of their evaluations and (b) document that process in Navy IGSA policy or procedures. (Recommendation 6)

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

Comments: The Navy concurred with this recommendation, and in March 2019 the Department of the Navy directed Commander, Navy Installations Command to implement the recommendation. When we confirm any further actions the Navy has taken in response to it, we will provide updated information.

Recommendation: The Commandant of the Marine Corps should (a) establish and implement a process to monitor whether Marine Corps installations are evaluating opportunities for using IGSAs and to obtain explanations from installations on the outcome of their evaluations and (b) document that process in Marine Corps IGSA policy or procedures. (Recommendation 7)

Agency: Department of Defense: United States Marine Corps
Status: Open

Comments: The Marine Corps did not concur with this recommendation. However, in written comments, DOD stated that the Department of the Navy would implement this recommendation and that it would be applicable to both the Navy and Marine Corps. In March 2019, the Department of the Navy directed Marine Corps Installation Command to implement the recommendation. When we confirm what actions the Marine Corps has taken in response to this direction, we will provide updated information.

Recommendation: The Secretary of the Air Force should document in Air Force IGSA policy or procedures its process for monitoring whether Air Force installations are evaluating opportunities for using IGSAs. (Recommendation 8)

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

Comments: The Air Force concurred with this recommendation. When we confirm what actions the Air Force has taken in response to it, we will provide updated information.

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: FERC should provide standard language and procedures to its staff on how to record information collected during inspections, including how and where to record information about safety deficiencies, in order to facilitate analysis of safety deficiencies across FERC's portfolio of regulated dams. (Recommendation 1)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: In February 2020, GAO confirmed that FERC had developed new standard operating procedures related for tracking deficiencies and follow-up items arising from dam safety inspections and other dam safety reviews. In addition, FERC told GAO that they plan to update their tracking system beginning in fiscal year 2021, which will facilitate the complete recording and subsequent analysis of safety deficiencies from inspections across FERC's portfolio of regulated dams. GAO will continue to monitor FERC's efforts to implement this recommendation.

Recommendation: FERC should use information from its inspections to assess safety risks across its portfolio of regulated dams to identify and prioritize safety risks at a national level. (Recommendation 2)

Agency: Federal Energy Regulatory Commission
Status: Open

Comments: In January 2019, FERC told GAO that it had begun developing a screening-level risk-assessment program to assess safety risks across the inventory of regulated dams and to help guide safety decisions. In February 2020, GAO confirmed that FERC had completed this screening-level risk assessment, and conducted some preliminary analysis of the results. In addition, FERC told GAO that the results of the screening level risk analyses will be used to revise the potential timing, frequency, and technical disciplines represented on dam safety inspections; to confirm or revise the urgency of existing and potential new follow up dam safety actions; and to identify previously unrecognized dam safety concerns and issues; to identify new dam safety priorities. GAO will continue to monitor FERC's efforts to implement this program.

Recommendation: The Under Secretary for Benefits should develop and implement a new regional office performance measure that allows it to better measure the accuracy of each regional office's work. (Recommendation 3)

Agency: Department of Veterans Affairs: Veterans Benefits Administration
Status: Open

Comments: VBA is working to develop and implement a new measure to assess the accuracy of each regional office. We will close this recommendation once VA has finalized and implemented the new measure.

Recommendation: The Commissioner of Internal Revenue should ensure that the Deputy Commissioner for Services and Enforcement develops and documents improved controls for the validity, completeness, and accuracy of data on FBAR exams and enforcement actions. (Recommendation 2)

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

Comments: In a letter dated October 15, 2018, IRS's Deputy Commissioner for Services and Enforcement stated that IRS is in the process of designing a new FBAR database solution using the FISMA-compliant Entellitrak case management system. The solution will include data fields and systemic controls to ensure the accurate recording and reporting of FBAR case information essential to the whistleblower program. As of December 2019, IRS officials said they are on track to complete this action by June 2020. When we can confirm that IRS has completed this action, we will provide updated information.

Recommendation: The Postmaster General should identify and adopt a set of internal control standards that can be used as the basis for operational internal-control activities, such as those for scanning competitive products. (Recommendation 1)

Agency: United States Postal Service
Status: Open

Comments: USPS has completed a cost study to adopt an operational internal control framework. USPS has targeted December 31, 2020, for completion and implementation of this new internal control framework.

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 the VA should direct the Undersecretary for Health to designate a focal point for overseeing VAMCs' pharmacy inventory management system-wide and define the focal point's responsibilities. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: VA officials provided documentation showing approval as of September 2019 for the procurement of a perpetual inventory management system that would allow VA medical facilities to keep track of inventory for all prescription drugs and assist VA with system-wide oversight. As of January 2020, this contract has yet to be awarded. In January 2020, VA officials also stated that Pharmacy Benefits Management (PBM) Services has been designated as the focal point for overseeing VA medical facilities' inventory management system-wide. VA officials stated that PBM is responsible for developing VA medical facility inventory management policy; however, VA did not provide documentation on PBM's defined responsibilities for system-wide oversight in the absence of an inventory system and once the system is procured. We plan to keep this recommendation open until we receive documentation of PBM's defined responsibilities for overseeing VAMC's pharmacy inventory management system-wide.

Recommendation: The Administrator of SBA should conduct and document reviews of staff compliance with procedures associated with HUBZone certification and recertification. (Recommendation 2)

Agency: Small Business Administration
Status: Open

Comments: In January 2020, SBA officials told us that the agency is re-aligning resources and developing standards to reflect new processing times for certifications and recertifications, which will include revised employee performance elements and quarterly performance reviews. When SBA has completed these changes, we will assess whether the agency is conducting and documenting reviews of staff compliance.

Recommendation: The Director of OMB, working with CFOC, should (1) collect data metrics regularly on the Career Roadmap Builder online tool and Grants Training 101 to determine how widely the resources are being used, and (2) obtain periodic feedback from federal agencies on the usefulness of these tools and any needed improvements. (Recommendation 2)

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

Comments: OMB staff provided us with oral comments stating that the agency partially concurred with our recommendations. For our second recommendation, OMB agreed that user feedback data regarding the Career Roadmap Builder and Grants Training 101 is useful. However, OMB stated that while it will continue to collect data on the number of users, it believes that federal agencies should be responsible for collecting specific, detailed user data if they are using those resources. We continue to believe that OMB and CFOC would benefit from collecting specific, detailed user data on these tools, which they devoted time and multiple resources to developing. Collecting detailed data metrics that go beyond the number of users can help OMB and CFOC to better evaluate the effectiveness of these grants training tools. Additionally, OMB stated the agency is committed to working with CFOC to review the Grants Training 101 module to determine how useful it is and if any improvements or adjustments are needed. In May 2019, OMB staff said that no action had been taken to date in response to this recommendation. In January 2020, OMB responded in writing to this recommendation stating that it was continuing to collect data on usage for both training tools on the CFO.gov site. OMB specified, however, that the usage data was for the number of visitors on the two sites and on users by agency. OMB went on to say that each agency is responsible for the professional development of its own workforce, and that Federal agencies can, at their discretion, collect user data if the Roadmap and Grant Training 101 are part of their official training program. In addition, OMB stated it had made the Grants Training 101 available publicly for federal and non-federal personnel on CFO.Gov, and that collecting specific user data is not considered by them to be beneficial to demonstrate the usefulness of the materials. Based on this response, we will continue to inquire as to the availability and use of metrics and effectiveness measures for the Career Roadmap and the Grants Training 101 modules.

Recommendation: The Secretary of HHS should establish a process to monitor and evaluate HHS's grants training at the central office level. This process should include (1) a method for identifying all employees working on grants across the agency, and (2) oversight procedures to evaluate the sufficiency of sub-agencies' grants training efforts including the incorporation of leading practices related to assessing competencies, training approaches, accountability, and training results. (Recommendation 3)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS concurred with our findings and recommendation. In its comment letter, HHS stated that its Office of Grants Policy, Oversight, and Evaluation, within the Office of Grants and Acquisition Policy and Accountability, Division of Grants, in conjunction with the HHS ReInvent Grants Initiative would be developing and implementing a department-wide financial assistance training and certification program to improve the functional effectiveness of the financial assistance management workforce in the areas of internal controls and risk mitigation. The program is designed to support the professional development of the HHS grants management workforce through both instructor-led and online courses. HHS' ReInvent Grants Management (RGM) staff and GAO held a conference call on November 30th, 2018 to discuss how RGM intended to address the recommendation in GAO-18-491 by developing a generalized framework for the Grants Management Training and Certification (GMTC) program for HHS. An HHS official reported that at its December 2019 quarterly meeting, the HHS Division of Workforce Development (DWD) reported they had in the past quarter: briefed the HHS Executive Committee on Grants Administration Policy (ECGAP) on the DWD mission and goals for training the grants workforce; developed briefing documents and presentations based on a RGM developed framework to develop competencies and outline curriculum of the GMTC program; continued to review and refine the program framework to incorporate DWD mission and goals; drafted the initial policy to further inform the structure and procedures of the GMTC program (e.g. certification levels, required coursework, career development requirements), which should be issued by HHS Office of Grants within Federal Fiscal Year 2020; and collaborated with the HHS Grants Closeout Business Process Reengineering Team to discuss current grants closeout status and how DWD can support grant staff and grant recipient closeout training efforts. Given the ongoing nature of HHS efforts, GAO will continue to monitor progress on a quarterly basis.

Recommendation: WMATA's General Manager should conduct a comprehensive assessment of the financial risks to which WMATA is exposed from its pension plans and communicate the results to its pension plan trustees and other stakeholders, such as its Board of Directors. This assessment should include information about WMATA's current and potential future required payments and unfunded liabilities, including under potentially adverse economic scenarios. (Recommendation 1)

Agency: Washington Metropolitan Area Transit Authority
Status: Open

Comments: As of June 2020, WMATA stated that the authority periodically evaluates the risks posed by the unfunded liabilities for its pension plans and other post-employment benefits. Specifically, WMATA officials stated that consulting agencies are used to conduct sensitivity analysis regarding the funded status of WMATA's five pension plans under various economic scenarios. However, WMATA has not yet provided GAO with these analyses to assess what information they contain and whether they include information on potential future required payments and unfunded liabilities under adverse scenarios. GAO will continue to work with WMATA to obtain these analyses and monitor WMATA's progress in addressing this recommendation.

Recommendation: WMATA's General Manager should develop a strategic workforce planning process that (1) sets a strategic direction for WMATA's workforce planning and involves employees and other stakeholders in developing and communicating the process, and (2) includes a data-driven assessment of the critical skill and competencies WMATA needs to fill any gaps. (Recommendation 2)

Agency: Washington Metropolitan Area Transit Authority
Status: Open

Comments: As of June 2020, WMATA officials stated that the Authority did not provide funding in 2019 to obtain a consultant to assist with authority-wide strategic workforce planning, as WMATA had previously planned. WMATA officials told us that the Authority is evaluating funding availability for this effort in the upcoming fiscal year, but in consideration to the impacts of the coronavirus crisis, broad economic uncertainties, and other challenges facing the Authority. WMATA did not provide information as to whether it would be conducting additional workforce planning efforts using its in-house staff and resources. GAO will continue to monitor WMATA's efforts to address this recommendation.

Recommendation: WMATA's General Manager should establish comprehensive policies and procedures for both of its performance management systems that document the goals of the systems and individuals' responsibilities for implementing these systems; align employee performance objectives with all of WMATA's strategic goals; and define performance objectives, rating categories, and competencies tailored to individual positions' responsibilities. (Recommendation 3)

Agency: Washington Metropolitan Area Transit Authority
Status: Open

Comments: As of June 2020, WMATA created documented procedures for managers and staff who are not represented by a union to use in the performance management cycles for fiscal years 2019 and 2020. These included guidance, instructional videos, or other tools for setting employee performance objectives in relation to WMATA's strategic priorities, and conducting mid-year reviews and end-of year performance evaluations. WMATA reported that it also intends to develop procedures to support performance management for some of its union-represented employees, starting in fiscal year 2021 with the Metro Transit Police Department. WMATA expects to implement changes for other represented employee groups beginning in fiscal year 2022. GAO will continue to monitor WMATA's progress in addressing this recommendation.

Recommendation: WMATA's General Manager should establish controls to ensure supervisors fully and accurately complete employee performance reviews and submit them to human resources within established timeframes. (Recommendation 4)

Agency: Washington Metropolitan Area Transit Authority
Status: Open

Comments: As of June 2020, WMATA has taken steps to establish controls for its employee performance management system. Specifically, WMATA developed an automated tool to track employee and supervisor compliance with WMATA's performance management requirements, and provided GAO with information on how WMATA used this tool to set employee performance objectives and complete mid-year reviews in the fiscal year 2020 performance cycle. WMATA reported that end-of-year performance evaluations would be completed by the end of July 2020. GAO will review WMATA's completion of the 2020 performance cycle to process to assess whether WMATA has fully implemented our recommendation.

Recommendation: WMATA's General Manager should develop a documented process to use employee performance management information to monitor progress toward WMATA's strategic goals. (Recommendation 5)

Agency: Washington Metropolitan Area Transit Authority
Status: Open

Comments: As of June 2020, WMATA officials told us that its automated performance management tool will provide information on employee performance information across the organization and allow for data-driven decision making. Specifically, WMATA stated that managers can view year-end ratings and other information for every employee within their chain of command, and WMATA's senior leadership have a global view of the ratings to compare performance ratings distributions across departments. WMATA reported that it is currently completing its fiscal year 2020 performance cycle, which ends July 31, 2020. GAO will continue to follow WMATA's progress addressing this recommendation, including assessing whether the information in its automated performance management tool will help WMATA monitor progress toward achieving its strategic goals.

Recommendation: The Secretary of Defense should ensure that the CMO, with input from the human resources management team, requires that all DOD human resources providers adopt consistent time-to-hire measures, as one process for assessing performance. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and noted planned actions. DOD's Human Resources Reform Team has 3 objectives as part of its reform agenda, including civilian hiring improvements. DOD issued its initial plan for business operations reform in April 2019, which includes detailed information and timelines for actions carried out and planned for this reform team. It stated that the team would conduct an annual review of components' time-to-hire plans and work towards establishment of common DOD process and metrics for civilian hiring and establishing baselines and goals for quality metrics through the end of fiscal year 2019. Further, quarterly assessment of survey data using baseline quality metrics is planned to begin in early fiscal year 2020. DOD officials stated that a departmentwide Time-to-Hire Workgroup was established in March 2019 and conducted six workshops to develop a reengineered process map for civilian hiring and an associated implementation plan. Implementation is to occur along with a new IT system for civilian human resources that is expected to be deployed in fiscal year 2021, but we have not received documentation of the specific requirements for implementation.

Recommendation: The Secretary of Defense should ensure that the CMO, through the human resources management reform team, identifies time frames and deliverables for identifying and adopting optimal IT solutions for human resources and fully assessing, identifying, and implementing the most effective and efficient means of human resources service delivery. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and noted planned actions. In its written comments, DOD stated the department is on track to achieve substantial savings through its reform team efforts and CMO emphasis on strong management practices, integrated processes, and best value business investments. DOD issued its initial plan for business operations reform in April 2019, which included detailed information regarding the department's plans for reforming its human resources service delivery. Subsequently, DOD identified 3 human resources management IT system reform projects aimed as identifying and adopting optimal IT systems for its overall civilian human resource management, the defense travel program, and overall training and learning. The reform management group has overseen these reform projects. DOD officials stated that it expects these optimal IT systems to be fully operational later in fiscal year 2020 and 2021. Further, DOD has identified timeframes throughout fiscal year 2023 for identifying and implementing an effective and efficient shared service delivery model for human resources. DOD has made considerable progress in identifying optimal IT systems and service delivery model for its human resources services, and we will continue to monitor the assessment and implementation of these systems and delivery models.

Recommendation: The Secretary of Defense should ensure that the CMO, through the human resources management reform team, collects information on the overhead costs charged by all DOD human resources service providers to assist in determining the most effective, economical, and efficient model of human resources service delivery within the department. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and noted planned actions. In its written comments, DOD stated the department is on track to achieve substantial savings through its reform team efforts and CMO emphasis on strong management practices, integrated processes, and best value business investments. DOD issued its initial plan for business operations reform in April 2019, which included detailed information regarding the department's plans for reforming its human resources service delivery. As part of this effort, DOD officials stated that the department has collected data and information on services, performance, and pricing to provide basis for common definitions and standards as they determine the most effective, economical, and efficient model of human resources service delivery. Further, efforts are continuing to develop a standardized costing model for human resources service delivery, which officials estimate will be approved for use by early fiscal year 2021.

Recommendation: The Secretary of Defense should ensure that the CMO routinely and comprehensively monitors and evaluates ongoing efficiency initiatives within the department, including those related to the reform teams. This monitoring should include establishing baselines from which to measure progress, periodically reviewing progress made, and evaluating results. (Recommendation 5)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation. In April 2019, DOD submitted to Congress its initial plan for business operations reform. It included an initial plan, schedule, and cost estimate for conducting these reforms. The plan states that a reform initiative framework was implemented to track and report progress of initiatives, and that financial savings will be monitored by a validation process. In December 2019, DOD issued a follow-up report providing additional baseline estimates related to the four areas. DOD officials stated that a reform initiative framework has been implemented to track and report progress of initiatives and that financial savings will be monitored by a validation process. The charter for the Reform Management Group, issued February 2019, directs the governance body to reform and align business functions of the department as well as tracking the progress of those reform efforts. Further, DOD reported on baselines in its January 2020 report to Congress to fulfill the requirements of Section 921 from the FY2019 National Defense Authorization Act. As of June 2020, DOD provided a corrective action plan that details plans to further evaluate results and financial savings associated with its efficiency initiatives. We will continue to review DOD's efforts throughout the year to ensure this monitoring and evaluation is occurring.

Recommendation: The Secretary of State should ensure that the Bureau of International Narcotics and Law Enforcement Affairs (INL) designs internal control mechanisms to ensure human rights content is included in INL-funded police training for El Salvador, Guatemala, and Honduras as appropriate. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: State concurred with this recommendation in its official comment letter included as an appendix in GAO-18-618, published in September 2018. State noted that it intends to amend templates for relevant implementing documents to address human rights as appropriate. In February 2020, State officials indicated that they had expressly included requirements for human rights components in new police training agreements established since we made our recommendation, and in May 2020 provided some examples of those requirements. We continue to work with State to learn about internal control mechanisms they may have established to help ensure they continue to include human rights content in police training as appropriate.

Recommendation: The Secretary of State should ensure that the Bureau of International Narcotics and Law Enforcement Affairs (INL) develops and implements a process to collect more reliable data on the number of police trained through INL-funded efforts in El Salvador, Guatemala, and Honduras. (Recommendation 2)

Agency: Department of State
Status: Open

Comments: State concurred with this recommendation in its official comment letter included as an appendix in GAO-18-618, published in September 2018. State commented that, partly in response to our report, it was developing specific indicators related to INL-funded police training. In February 2020, State officials indicated that contractors hired to work on developing measures to track the impact of INL efforts would be developing a database to store results, including the number of police trained. In addition, State told us that INL's implementing partner working in El Salvador, Guatemala, and Honduras also keeps a list of individuals who attend training. In May 2020, officials noted an effort to pilot the implementation of improved data collection was underway in Honduras. We continue working with State officials as they make progress developing and implementing their new process to collect and maintain police training data. As we confirm actions taken by State in response to this recommendation, we will provide updated information.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should develop a timeline for issuing a comprehensive guidance and instructions document for PSLF servicing. This could involve developing a new servicing manual or expanding upon the PSLF servicer's existing processing handbook. (Recommendation 1)

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

Comments: Education agreed with this recommendation and reported in September 2019 that it was continuing its efforts to improve and streamline guidance for the PSLF servicer. While Education said it is working on developing its comprehensive PSLF servicing manual, it does not yet have a timeline for how it will complete this manual and has indicated that it intends to deliver completed chapters on an iterative basis based on servicing priorities. To implement this recommendation, Education needs to develop a timeline for completing the PSLF servicing manual and demonstrate that it will provide comprehensive guidance and instructions for PSLF servicing.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should provide additional information to the PSLF servicer and borrowers to enhance their ability to determine which employers qualify for PSLF. This could involve Education developing an authoritative list of qualifying employers or improving the PSLF servicer's existing database, and making this information available to borrowers. (Recommendation 2)

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

Comments: Education agreed with this recommendation, and in December 2018, the agency released a new online tool to help borrowers better understand the PSLF eligibility requirements. Education has indicated that this tool could eventually be expanded to incorporate additional qualifying employer information. Education has also indicated that implementation of the recommendation is tied to the rollout of a new loan servicing system, which it expects to be fully operational in October 2021. To implement this recommendation, Education needs to demonstrate that it is providing information that will help the PSLF servicer and borrowers determine whether employment with specific employers will qualify borrowers for the program.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should ensure that borrowers receive sufficiently detailed information from the PSLF servicer to be able to identify any errors in the servicer's counts of qualifying payments, including information on whether or not each payment qualified toward forgiveness. (Recommendation 4)

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

Comments: Education agreed with this recommendation, and in June 2020, reported that it is reviewing communications from the PSLF servicer to ensure that borrowers receive sufficiently detailed information regarding payment counts and payment history. Education also indicated that implementation of the recommendation is tied to the rollout of a new loan servicing system, which it expects to be fully operational in October 2021. We will close the recommendation once Education provides documentation of the changes in communications from the PSLF servicer that demonstrate borrowers are receiving sufficiently detailed information regarding payment counts and payment history.

Recommendation: The Administrator of the U.S. Seaway Corporation should establish a process to identify, analyze, and monitor risks to the system's use to inform future actions to address those risks. (Recommendation 1)

Agency: Department of Transportation: Saint Lawrence Seaway Development Corporation
Status: Open

Comments: As of August 2020, DOT reported that the St. Lawrence Seaway Development Corporation (SLSDC) is in the process of completing development of its new risk management program and anticipates having a final product that will be implemented by the end of 2020. GAO will continue to monitor the SLSDC's progress in implementing this recommendation.

Recommendation: The Secretary of Defense should ensure that the Commander, U.S. Transportation Command, fully implements a process to obtain projected airlift workload from the military services and Combatant Commanders on a routine basis to improve the accuracy of its workload forecasts. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation and stated that it plans to take specific actions in response. As of July 31, 2020. DOD had not demonstrated that the commendation has been implemented. we will provide updated information when it becomes available.

Recommendation: The Secretary of Defense should ensure that the Commander, U.S. Transportation Command, uses forecast performance metrics and establishes forecast accuracy goals for the airlift workload. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation and stated that it plans to take specific actions in response. As of July 31, 2020. DOD had not demonstrated that the commendation has been implemented. we will provide updated information when it becomes available.

Recommendation: The Secretary of Defense should ensure that the Commander, U.S. Transportation Command, develops a corrective action plan to improve the accuracy of its workload forecasting. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation and stated that it plans to take specific actions in response. As of July 31, 2020. DOD had not demonstrated that the commendation has been implemented. we will provide updated information when it becomes available.

Recommendation: The Chief of the Forest Service should determine whether new regulations governing timber export and substitution are appropriate. If the agency determines new regulations are appropriate, it should issue them in accordance with the 1997 act, in consultation with BLM. Otherwise, the agency should seek legislative relief from the act's requirement. (Recommendation 1)

Agency: Department of Agriculture: Forest Service
Status: Open

Comments: In its May 15, 2020 correspondence, the Forest Service stated that it is putting together a Corrective Action Plan for addressing the recommendation. It expects leadership review of the plan to be completed in June 2020.

Recommendation: The Director of the BLM should determine whether new regulations governing timber export and substitution are appropriate. If the agency determines new regulations are appropriate, it should issue them in accordance with the 1997 act, in consultation with the Forest Service. Otherwise, the agency should seek legislative relief from the act's requirement. (Recommendation 2)

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

Comments: In its April 9, 2020 correspondence, BLM stated that a proposed rule continues to be reviewed by Departmental officials. BLM identified December 31, 2020 as a new target date for completing this recommendation.

Recommendation: The Chief of the Forest Service should review agency policies for continued relevance and effectiveness in addressing the risk of illegal timber export and substitution, and based on that review--and in accordance with applicable regulations--should issue new policies as necessary. (Recommendation 3)

Agency: Department of Agriculture: Forest Service
Status: Open

Comments: In its May 15, 2020 correspondence, the Forest Service stated that it is putting together a Corrective Action Plan for addressing the recommendation. It expects leadership review of the plan to be completed in June 2020.

Recommendation: The Director of the BLM should review agency policies for continued relevance and effectiveness in addressing the risk of illegal timber export and substitution, and based on that review--and in accordance with applicable regulations--should issue new policies as necessary. (Recommendation 4)

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

Comments: In its April 9, 2020 correspondence, BLM stated that any action to address this recommendation is contingent upon the completion of Recommendation #2. Once BLM's response to that recommendation is completed, the agency will address this recommendation.

Recommendation: The Secretary of Defense ensures that the Offices of the Under Secretary of Defense for Personnel and Readiness and Under Secretary of Defense for Acquisition and Sustainment in coordination with the Secretaries of the Army, Navy, and Air Force take interim steps to help ensure that standardized aviation mishap data elements are collected by the safety centers. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to a corrective action plan that DOD updated in July 2020, the department has taken some steps to implement this recommendation. According to the plan, DOD is developing standards for mishap data through the Safety and Information Management Working Group and is making progress towards finalizing mishap data element standards. DOD's internal tracking indicates that the draft business process model has been completed, but standardizing the DOD data elements is a work in-progress. DOD's estimated completion date for this effort is June 2021. Completing these actions would allow the military services' safety centers to collect relevant training-related data as part of the update of aviation mishap data elements, as GAO recommended in August 2018.

Recommendation: The Secretary of Defense ensures that the Offices of the Under Secretary of Defense for Personnel and Readiness and Under Secretary of Defense for Acquisition and Sustainment in coordination with the Secretaries of the Army, Navy, and Air Force update department-wide and service instructions and policies to clarify the responsibility of the Office of the Secretary of Defense for conducting analysis and its access to the military services' information on human factors that contributed to aviation mishaps. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to a corrective action plan that DOD updated in July 2020, the department has taken some steps to implement this recommendation. According to the plan, DOD is revising DOD Instruction 6055.07, which will clarify the department's policy that it is the responsibility of the Office of the Secretary of Defense for conducting analysis and its access to the military services' information on human factors that contributed to aviation mishaps. DOD's estimated completion date for this effort is July 2021. Completing this action would clarify the Office of the Secretary of Defense's role for conducting analyses and access to the military services' safety centers' data on aviation mishaps, as GAO recommended in August 2018.

Recommendation: The Secretary of Defense ensures that the DOD Chief Management Officer in coordination with the offices of the Under Secretary of Defense for Personnel and Readiness and Under Secretary of Defense for Acquisition and Sustainment and the Secretaries of the Army, Navy, and Air Force identify relevant training-related data to collect as part of any update of the aviation mishap data elements and incorporate these data into future analyses. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to a corrective action plan that DOD updated in July 2020, the department has taken some steps to implement this recommendation. According to the plan, DOD is developing standards for mishap data through the Safety and Information Management Working Group and is making progress towards finalizing mishap data element standards. DOD's internal tracking indicates that the draft business process model has been completed, but standardizing the DOD data elements is a work in-progress. DOD's estimated completion date for this effort is June 2021. Completing these actions would allow the military services' safety centers to collect relevant training-related data as part of the update of aviation mishap data elements, as GAO recommended in August 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 Homeland Security should direct Homeland Security's members of the interagency working group for protection of Native American cultural property to implement selected leading collaboration practices, such as taking steps to agree on outcomes and objectives, clarify roles and responsibilities, and document these decisions. (Recommendation 1)

Agency: Department of Homeland Security
Status: Open

Comments: As of August 2019, we have reached out to the Department of Homeland Security and are awaiting a response on actions they may have taken in response to this recommendation.

Recommendation: The Secretary of the Interior should direct Interior's members of the interagency working group for protection of Native American cultural property to implement selected leading collaboration practices, such as taking steps to agree on outcomes and objectives, clarify roles and responsibilities, and document these decisions. (Recommendation 2)

Agency: Department of the Interior
Status: Open

Comments: Since August 2018, Interior's Office of International Affairs has updated its contact list for international repatriation assistance with information on the Department's roles and responsibilities in support of international repatriation. In addition, Interior's interagency working group members have developed a description of the interagency working group. However, the statement does not include outcomes and objectives for the group's work. GAO made the same recommendation to each of the four agencies covered in the review because implementing leading collaboration practices will require the collective participation of group members. GAO will keep the recommendation open until further collaborative actions are taken.

Recommendation: The Attorney General should direct Justice's members of the interagency working group for protection of Native American cultural property to implement selected leading collaboration practices, such as taking steps to agree on outcomes and objectives, clarify roles and responsibilities, and document these decisions. (Recommendation 3)

Agency: Department of Justice
Status: Open

Comments: As of August 2019, we have reached out to the Department of Justice and are awaiting a response on actions they may have taken in response to this recommendation.

Recommendation: The Secretary of State should direct State's members of the interagency working group for protection of Native American cultural property to implement selected leading collaboration practices, such as taking steps to agree on outcomes and objectives, clarify roles and responsibilities, and document these decisions. (Recommendation 4)

Agency: Department of State
Status: Open

Comments: Since August 2018, the Department of State shared a statement of its roles and responsibilities with other working group members. However, the statement does not include outcomes and objectives for the group's work. GAO made the same recommendation to each of the four agencies covered in the review because implementing leading collaboration practices will require the collective participation of group members. GAO will keep the recommendation open until further collaborative actions are taken.

Recommendation: The Secretary of Homeland Security should direct Homeland Security's members of the interagency working group for protection of Native American cultural property to identify and externally communicate to tribes points of contact within the agency that are responsible for responding to tribes' requests for assistance with repatriating cultural items from overseas auctions. (Recommendation 5)

Agency: Department of Homeland Security
Status: Open

Comments: As of August 2019, we have reached out to the Department of Homeland Security and are awaiting a response on actions they may have taken in response to this recommendation.

Recommendation: The Attorney General should direct Justice's members of the interagency working group for protection of Native American cultural property to identify and externally communicate to tribes points of contact within the agency that are responsible for responding to tribes' requests for assistance with repatriating cultural items from overseas auctions. (Recommendation 7)

Agency: Department of Justice
Status: Open

Comments: As of August 2019, we have reached out to the Department of Justice and are awaiting a response on actions they may have taken in response to this recommendation.

Recommendation: The Secretary of Homeland Security should direct Homeland Security's members of the interagency working group for protection of Native American cultural property to collaborate with the interagency working group members from other agencies to assess, in consultation with Indian tribes, whether and how amending the U.S. legal framework governing the export, theft, and trafficking of Native American cultural items would facilitate the repatriation of these items from auctions overseas and report its findings to Congress. (Recommendation 9)

Agency: Department of Homeland Security
Status: Open

Comments: As of August 2019, we have reached out to the Department of Homeland Security and are awaiting a response on actions they may have taken in response to this recommendation.

Recommendation: The Secretary of the Interior should direct Interior's members of the interagency working group for protection of Native American cultural property to collaborate with the interagency working group members from other agencies to assess, in consultation with Indian tribes, whether and how amending the U.S. legal framework governing the export, theft, and trafficking of Native American cultural items would facilitate the repatriation of these items from auctions overseas and report its findings to Congress. (Recommendation 10)

Agency: Department of the Interior
Status: Open

Comments: As of September 2019, Interior is working to develop an assessment of legislative options for discussion with the interagency working group, and plans to meet with tribes later this fall to discuss the assessment. Interior anticipates a September 30, 2020, completion date for the assessment of these legislative options. Interior has also reviewed legislative proposals related to the export, theft, and trafficking of Native American cultural items and has prepared for Congressional hearings on this topic.

Recommendation: The Attorney General should direct Justice's members of the interagency working group for protection of Native American cultural property to collaborate with the interagency working group members from other agencies to assess, in consultation with Indian tribes, whether and how amending the U.S. legal framework governing the export, theft, and trafficking of Native American cultural items would facilitate the repatriation of these items from auctions overseas and report its findings to Congress. (Recommendation 11)

Agency: Department of Justice
Status: Open

Comments: As of August 2019, we have reached out to the Department of Justice and are awaiting a response on actions they may have taken in response to this recommendation.

Recommendation: The Secretary of State should direct State's members of the interagency working group for protection of Native American cultural property to collaborate with the interagency working group members from other agencies to assess, in consultation with Indian tribes, whether and how amending the U.S. legal framework governing the export, theft, and trafficking of Native American cultural items would facilitate the repatriation of these items from auctions overseas and report its findings to Congress. (Recommendation 12)

Agency: Department of State
Status: Open

Comments: In November 2019, the Department of State, in conjunction with other interagency working group members, circulated a draft legal assessment and draft legislative options. The interagency working group members conducted a listening session with tribal members in November 2019, and conducted a tribal consultation in January 2020. GAO will continue monitoring the agencies' efforts toward implementing this recommendation.

Recommendation: OAPM should monitor how field offices currently manage older, existing Management and Operating contract documents and use the results to improve its process for accessing such documents. (Recommendation 2)

Agency: Department of Energy: National Nuclear Security Administration
Status: Open

Comments: NNSA agreed with this recommendation. Per NNSA, as of October 2018, it was developing a plan and schedule for implementing Procurement Management Reviews (PMRs), which will include monitoring how NNSA field offices manage older management and operating contract documents and use the results to improve access to such documents. As of April 2020, we will continue to monitor how NNSA carries out its oversight of field offices contract document management practices.

Recommendation: The Commissioner of Internal Revenue should take steps to improve the implementation of IRS's information security program by entering correct contractor password expiration dates, per IRS's policy, in the system used for managing user access authorizations. (Recommendation 1)

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

Comments: During GAO's audit of FY 2019 IRS financial statements, IRS did not submit this recommendation for closure, nor did the agency provide evidence that it had implemented this recommendation. When IRS indicates that it has implemented this recommendation, we will review relevant IRS actions.

Recommendation: The Commissioner of Internal Revenue should take steps to improve the implementation of IRS's information security program by documenting access authorizations for non-unique accounts. (Recommendation 2)

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

Comments: During GAO's audit of FY 2019 IRS financial statements, IRS did not submit this recommendation for closure, nor did the agency provide evidence that it had implemented this recommendation. When IRS indicates that it has implemented this recommendation, we will review relevant IRS actions.

Recommendation: The Commissioner of Internal Revenue should take steps to improve the implementation of IRS's information security program by reviewing non-unique accounts at least annually, per IRS's policy. (Recommendation 3)

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

Comments: During GAO's audit of FY 2019 IRS financial statements, IRS did not submit this recommendation for closure, nor did the agency provide evidence that it had implemented this recommendation. When IRS indicates that it has implemented this recommendation, we will review relevant IRS actions.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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