Recommendation: The Commissioner of CBP should take steps to develop a streamlined enforcement approach to counterfeit goods in small packages. This may include assessing the feasibility and impact of such an approach, including any potential for cost savings. (Recommendation 1)

Agency: Department of Homeland Security: United States Customs and Border Protection
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 State should ensure that State involves federal agencies that contribute to cyber diplomacy to obtain their views and identify any risks, such as unnecessary fragmentation, overlap, and duplication of these efforts, as it implements its plan to establish the Bureau of Cyberspace Security and Emerging Technologies.

Agency: Department of State
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 Commerce should direct BIS to identify, analyze, and respond to factors in the process that may cause submission errors. (Recommendation 1)

Agency: Department of Commerce
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 Commerce should direct BIS to identify, assess, and make program changes to address issues that have impeded timeliness and created the backlog of exclusion requests. (Recommendation 2)

Agency: Department of Commerce
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 Commerce should assign responsibility for regularly reviewing the impact of the tariffs on steel and aluminum imports, including tariff exclusions, and document the results. (Recommendation 3)

Agency: Department of Commerce
Status: Open

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

(Recommendation 8).

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

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

Recommendation: The Secretary of State, in consultation with the Administrator of USAID, should develop performance indicators that would enable State to assess progress toward the strategic objectives and goal of the U.S. conflict minerals strategy going forward. (Recommendation 1)

Agency: Department of State
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 for USAID should communicate to all missions and bureaus the expectation that they report data on all funding attributed to the key issue of indirect climate adaptation. (Recommendation 1)

Agency: United States Agency for International 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 U.S. commissioners of the International Joint Commission should work with the Canadian commissioners to update the Lake Ontario-St. Lawrence River Board communications plan and ensure that the plan incorporates best practices for public relations efforts, in particular defining target audiences and developing mechanisms to monitor and inform adjustments to strategies, and generally accepted principles for communicating risk-related information. (Recommendation 1)

Agency: International Joint Commission--United States and Canada
Status: Open

Comments: The International Joint Commission (IJC) agreed with our recommendation. IJC stated that it intends to develop an updated communications plan that incorporates best practices for public relations efforts by December 31, 2020. We will continue to monitor IJC's actions in response to this recommendation.

Recommendation: The U.S. commissioners of the International Joint Commission should work with the Canadian commissioners to develop and enter into written agreements with entities that the Great Lakes-St. Lawrence River Adaptive Management Committee identifies as having information or resources that the committee needs to effectively monitor and evaluate the impacts of Plan 2014. (Recommendation 2)

Agency: International Joint Commission--United States and Canada
Status: Open

Comments: The International Joint Commission (IJC) agreed with our recommendation. IJC is compiling a list of entities with which it shares information to explore formal data and information sharing arrangements with them. We will continue to monitor IJC's actions in response to this recommendation.

Recommendation: The U.S. commissioners of the International Joint Commission should work with the Canadian commissioners to ensure that IJC fully incorporates the key elements and essential characteristics of the adaptive management process into a comprehensive adaptive management strategic plan for Plan 2014. (Recommendation 3)

Agency: International Joint Commission--United States and Canada
Status: Open

Comments: The International Joint Commission (IJC) agreed with our recommendation. IJC plans to produce a comprehensive adaptive management strategic plan that fully incorporates the key elements and essential characteristics of the adaptive management process by December 31, 2020. We will continue to monitor IJC's actions in response to this recommendation.

Recommendation: The Acting Commissioner of CBP should better communicate to stakeholders the types of information stakeholders could collect and submit to CBP to help the agency initiate and investigate forced labor cases related to seafood and, as appropriate, other goods. (Recommendation 1)

Agency: Department of Homeland Security: United States Customs and Border Protection
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 State should require Chiefs of Mission at overseas missions that receive allocations for rule of law assistance to assess the sufficiency of their coordination methods to verify that this assistance is coordinated with all relevant interagency partners. (Recommendation 1)

Agency: Department of State
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 State should ensure that State/INL establishes procedures that verify that monitoring officials for Mérida Initiative projects follow the key practices. (Recommendation 1)

Agency: Department of State
Status: Open

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

Recommendation: The USAID Administrator should establish procedures to ensure that monitoring officials for Mérida Initiative projects develop monitoring plans that address risks. (Recommendation 2)

Agency: United States Agency for International 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 State should ensure that the Deputy Assistant Secretary for Defense Trade Controls, in consultation with university representatives, provides additional or revises existing guidance and outreach to address university-specific export control issues to further support universities' understanding and compliance with the International Traffic in Arms Regulations. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: The Department of State concurred with the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Commerce should ensure that the Under Secretary for Industry and Security, in consultation with university representatives, provides additional or revises existing guidance and outreach to address university-specific export control issues to further support universities' understanding and compliance with the Export Administration Regulations. (Recommendation 2)

Agency: Department of Commerce
Status: Open

Comments: The Department of Commerce concurred with the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of State should ensure that the Deputy Assistant Secretary for Defense Trade Controls revises existing export compliance guidelines to include information concerning periodic risk assessments to remind exporters that it is beneficial to periodically identify, analyze, and respond to new risks as part of an effective International Traffic in Arms Regulations compliance program. (Recommendation 3)

Agency: Department of State
Status: Open

Comments: The Department of State concurred with the recommendation. 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 Research and Engineering takes steps to ensure that its program officers and contracting officers are interpreting export controls consistent with regulations and guidance and consistently determining whether university research constitutes fundamental research. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense concurred with the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of State, in coordination with the Secretary of Energy, should commit to regularly scheduled, substantive briefings for the House Committee on Foreign Affairs and the Senate Committee on Foreign Relations on all initiatives and negotiations related to nuclear cooperation in order to enhance transparency and establish greater confidence with Congress on nuclear cooperation matters. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: We will update this recommendation after receiving information from State regarding its plans to address it.

Recommendation: The Secretary of Homeland Security should direct the Director of ICE to develop a strategy for the TTU program to ensure that ICE has a plan to guide its efforts to effectively partner with existing TTUs, and to expand the program, where appropriate, into additional countries. (Recommendation 1)

Agency: Department of Homeland Security: Office of the Secretary
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 Director of ICE to develop a performance monitoring framework for the TTU program that would enable the agency to systematically track program results and how effectively it is achieving the program's goals. (Recommendation 2)

Agency: Department of Homeland Security: Office of the Secretary
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 State should direct the Assistant Secretary for International Security and Nonproliferation to include additional information about the expenditures it considers in its NEA-mandated reporting for Executive Order 12938.

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

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

Recommendation: The U.S. Commissioner of the IBWC should work with the Mexican Commissioner to formalize a binational rapid response team to address sewage infrastructure failures along the U.S.-Mexico border, including the Nogales and South Bay wastewater treatment plants. (Recommendation 1)

Agency: International Boundary and Water Commission, United States and Mexico
Status: Open

Comments: In July 2020, USIBWC stated that two teams have been established with members, one in the Nogales, Arizona and Nogales, Sonora region and one in the San Diego and Tijuana region. IBWC continues to take actions to formalize the binational rapid response teams. We will review the final documents for each team when they are completed and available.

Recommendation: The U.S. Commissioner of the IBWC should direct USIBWC staff to conduct long-term capital planning for the Santa Cruz River Basin and Tijuana River Valley watersheds, following the principles in OMB Circular A-11. (Recommendation 2)

Agency: International Boundary and Water Commission, United States and Mexico
Status: Open

Comments: In July 2020, the U.S. Commissioner of the IBWC stated that it had conducted long-term capital planning for the facilities for which it is responsible. They noted the 5-year plan that USIBWC had developed for the South Bay plant and the 10-year plan that it had developed for the Nogales plant. We noted these plans in our original report and stated that they needed to be broadened to identify needs in the Santa Cruz River Basin and Tijuana River Valley watersheds. The agency only partially concurred with our recommendation in the report and noted that to the extent our report envisions USIBWC undertaking long-term capital planning for (1) nonfederal infrastructure; (2) infrastructure that does not yet exist; and/or (3) infrastructure that the USIBWC is not yet authorized to construct or maintain, it does not concur. The agency is a key player in managing water quality on the border and has the infrastructure and organization that will be part of the solution. Without the information that USIBWC would generate by comprehensively assessing its long-term needs, such as through long-term capital planning efforts, Congress cannot authorize specific work that needs to be done. We recommended that the agency conduct long-term planning, including for infrastructure that does not exist and for infrastructure that is not yet authorized specifically to address this problem. We continue to believe that USIBWC should recognize its role along the border and start planning for it, including by undertaking long-term capital planning for existing and potential future infrastructure and identifying alternatives to address the long-standing water quality problems.

Recommendation: The Secretary of State should direct the Assistant Secretary of State for Democracy, Human Rights, and Labor to develop a mechanism to facilitate the active sharing of information about democracy assistance projects between DRL and relevant staff at embassies.

Agency: Department of State
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 State should take additional steps to identify diversity issues that could indicate potential barriers to equal opportunity in its workforce. For example, State could conduct additional analyses of workforce data and of employee groups' feedback. (Recommendation 1)

Agency: Department of State
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 establish and implement a time frame for completing its drafting of the AED regulations and submitting them to the Office of Management and Budget for further review. (Recommendation 1)

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

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

Recommendation: The Secretary of State should direct the Department's relevant bureaus to work with Embassy Beirut to establish, as appropriate, and consolidate targets for each of the security-related performance indicators. (Recommendation 1)

Agency: Department of State: Office of the Secretary
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 State should direct the Department's relevant bureaus to work with Embassy Beirut to collect and review performance data for key security-related performance indicators. (Recommendation 2)

Agency: Department of State: Office of the Secretary
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 DSCA to revise the inspection due dates it establishes for items requiring enhanced EUM for the Office of Defense Cooperation in Beirut to align with DOD's standards for EUM by considering the date of last inspection. (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 Commissioner of CBP should ensure that the Office of Field Operations, in consultation with the Office of Trade, develops a plan for managing its increased workload. (Recommendation 1)

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

Comments: CBP concurred with this recommendation. According to CBP, the new ACE drawback module provides the capability to extract data for workload management. Further enhanced reporting capabilities for drawback claims are under development. CBP's Office of Field Operations and Office of Trade continue to collaborate on a plan to employ risk management principles and automation to resolve the drawback claims backlog and lay the foundation for processing current drawback claims workload. They estimate the completion of this workload management system by October 31, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade assesses the feasibility of flagging excessive export submissions across multiple claims and takes cost-effective steps, based on the assessment, to prevent over claiming. (Recommendation 2)

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

Comments: CBP concurred with this recommendation. According to CBP, the Office of Trade is exploring alternatives to track and automatically flag duplicate exports across multiple drawback claims. CBP expects to complete their assessment and plan for implementation by December 31, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade develops a plan, with time frames, to establish a reliable system of record for proof of export. (Recommendation 3)

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

Comments: CBP concurred with this recommendation. According to CBP, the Office of Trade will work to develop a plan for the use of the Automated Export System (and possibly other systems) for electronic proof of export in the future. They expect this to be complete by September 30, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade turns the claim selection feature in ACE back on and finalizes and implements procedures to target claims for review that were accepted into ACE during the period in which the selection feature was disabled. (Recommendation 4)

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

Comments: CBP concurred with our recommendation. According to CBP, the Office of Trade, in collaboration with the Office of Information Technology, will automate updates that turn the claim selection feature on in ACE. The Office of Trade plans to retroactively identify drawback claims accepted during the lapse period, and is working to implement a solution by December 31, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade analyzes the results of its targeting of claims for review and designs responses to mitigate identified risks. (Recommendation 5)

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

Comments: CBP concurred with this recommendation. According to CBP, on March 25, 2020, the Office of Trade initiated an analysis to improve automation and targeting on an ongoing basis. Based on the results of this analysis, the Office of Trade will make any needed adjustments to policy and procedures to assist with data quality, by September 30, 2020.

Recommendation: The Commissioner of CBP should ensure that the Office of Trade prioritizes developing a plan to conduct an ex post analysis of the impact on industry and government of key changes to the drawback program, including time frames and methodology. (Recommendation 6)

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

Comments: CBP concurs with this recommendation. According to CBP, the Office of Trade is finalizing a plan to conduct an ex post analysis of the impact on industry and government of key changes to the drawback program. CBP's analytical plan will include a timeline and methodology for assessing changes to the program. They expect to complete this by November 30, 2020.

Recommendation: The Director of USCIS should plan and conduct regular fraud risk assessments of the self-petition program to determine a fraud risk profile, as provided in GAO's Fraud Risk Framework. (Recommendation 1)

Agency: Department of Homeland Security: United States Citizenship and Immigration 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 Director of USCIS should develop and implement an antifraud strategy 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 2)

Agency: Department of Homeland Security: United States Citizenship and Immigration 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 Director of USCIS should develop and implement data analytics capabilities for the self-petition program, as a means to prevent and detect fraud, as provided in GAO's Fraud Risk Framework. (Recommendation 3)

Agency: Department of Homeland Security: United States Citizenship and Immigration 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 Secretary of State, working with the Administrator of the U.S. Agency for International Development, should collaborate with the Departments of Defense and Agriculture and other Departments as necessary, to develop a comprehensive approach to the monitoring and evaluation of projects that directly support the objectives of prosperity, governance, and security, and incorporate this approach into the Strategy monitoring and evaluation plan.

Agency: Department of State
Status: Open

Comments: State did not concur with the recommendation, indicating that it continues to collaborate with agencies regarding U.S. government activities in El Salvador, Guatemala, and Honduras. However, in May 2020, State noted that, to the extent possible, it would seek to include agencies, such as the Departments of Defense and Agriculture, into the Progress Report for the U.S. Strategy for Central America's Plan for Monitoring and Evaluation. When we confirm what actions State has taken in response to this recommendation, we will provide updated information.

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

Recommendation: The 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 Defense should direct the Director of the Defense Security Cooperation Agency to establish processes to ensure that information on the provision of Section 333 mandated human rights training is systematically and accurately entered into its tracking systems. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: In December 2019, DOD agreed with the recommendation and stated that the Defense Security Cooperation Agency needs to establish reporting procedures with geographic combatant commands and is working to determine the feasibility and requirements to modify existing systems to enable tracking of mandated human rights training. As of July 2020, DSCA was considering options for such changes.

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense for Policy to develop a timeline for implementing its activities to monitor and evaluate the effectiveness of human rights training for foreign security forces. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: In December 2019, DOD concurred with the recommendation and said it would monitor and evaluate human rights training as part of monitoring and evaluating its broader security assistance efforts. As of July 2020, DOD was considering how it would implement these changes.

Recommendation: The Secretary of State, in consultation with the Secretary of Defense, should develop a plan with a clear timeline for monitoring and evaluating the effectiveness of human rights training for foreign security forces provided under International Military Education and Training. (Recommendation 3)

Agency: Department of State
Status: Open

Comments: In December 2019, State wrote that it did not agree to separately conduct monitoring and evaluation of human rights training provided under the International Military Education and Training (IMET) program. GAO's recommendation does not call for a separate evaluation. State could meet the intent of the recommendation through evaluating the effectiveness of human rights training as part of its broader efforts to monitor and evaluate IMET. As of June 2020, State indicated they had no plans to evaluate the effectiveness of human rights training related to IMET.

Recommendation: The Director of the Office of Management of Budget should update the Guidelines to include GAO's leading practices of developing monitoring plans that are based on risks, ensuring that monitoring staff have appropriate qualifications, establishing procedures to close-out programs, developing staff skills regarding evaluations, and establishing mechanisms for following up on evaluation recommendations. (Recommendation 1)

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

Comments: OMB disagreed with the recommendation and suggested it would be more effective to remind agencies that, in addition to the guidelines, they should follow all other relevant OMB guidance affecting monitoring and evaluation. OMB asserted that this guidance contains provisions relevant to our leading practices not included in the Foreign Assistance Monitoring and Evaluation Guidelines. However, we believe it is important for OMB to incorporate this other guidance into the Foreign Assistance Monitoring and Evaluation Guidelines, if only by reference, to emphasize the importance of these practices in the context of monitoring and evaluation of foreign assistance. As of April 28, 2020, the Office of Management and Budget has not implemented this recommendation. GAO will continue to monitor this issue.

Recommendation: The Secretary of Defense should update the Department's monitoring and evaluation policies to require the agency to conduct impact evaluations on all pilot programs before replicating or expanding, or conduct performance evaluations for those programs and provide a justification for not conducting an impact evaluation. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation and noted that impact evaluations require a significant resource investment beyond what would be appropriate for more programs. However, DOD is in the process of updating its evaluation guidelines to allow for, but not require, impact evaluations in appropriate cases at all levels of evaluation activities.

Recommendation: The Department of State's U.S. Global AIDS Coordinator, in collaboration with HHS and other implementing agencies, should update the PEPFAR monitoring and evaluation policies to require these agencies to conduct impact evaluations on all pilot programs before replicating or expanding, or conduct performance evaluations for those programs and provide a justification for not conducting an impact evaluation. (Recommendation 6)

Agency: Department of State
Status: Open

Comments: State agreed with the intent of the recommendation (see appendix V for written comments). State explained that impact evaluations are often not feasible in the context of assistance provided under PEPFAR and described its alternative approach to evaluating new initiatives. State indicated it would update appropriate PEPFAR policies to clarify when agencies should conduct impact and/or performance evaluations. These clarifications will reflect how State evaluates PEPFAR programs in practice in accordance with OMB guidance and legislation, according to State.

Recommendation: The Secretary of State should work with IAEA and its member states through the Board of Governors to develop detailed guidelines for prioritizing nuclear security activities. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: The Department of State (State) agreed with this recommendation and it has identified several actions it has taken to implement this recommendation. State also has identified some progress resulting from its actions. Among other actions, State reported in its January 2020 letter to GAO that it is: working with the IAEA to identify ways to better develop and implement strategic planning across the Division of Nuclear Security, potentially including through dedicated staff; conveying to IAEA that it should do more to synthesize information from donor areas of emphasis, member state requests, and the contents of Integrated Nuclear Security Support Plans into a set of inputed priorities; and doing more to coordinate among the larger donors to the Nuclear Security Fund (NSF) to optimize and enhance the way the Division of Nuclear Security prioritizes and carries out its nuclear security activities funded via the NSF. State noted several positive results stemming from these actions, including: (1) an increased emphasis in IAEA's most recent Nuclear Security Report on internal coordination and a more collaborative approach within the IAEA in the implementation of its nuclear security activities, which State believes will help reduce duplication, streamline Agency activities, increase efficiency and effectiveness, and maximize the benefits to IAEA member states; and (2) participation by number of donors to the NSF in a series of informal coordination meetings with the IAEA that included discussing how the Agency views its priorities for its nuclear security activities, which State believes are more likely to result in positive outcomes than priorities negotiated at Board of Governors meetings. GAO will follow up with State in fiscal years 2020 and 2021 to determine the extent to which these efforts lead to more concrete prioritization guidelines for IAEA's nuclear security program.

Recommendation: The Secretary of State should work with IAEA and its member states through the Board of Governors to improve the nuclear security program's performance measures by developing baselines and measurable targets. (Recommendation 2)

Agency: Department of State
Status: Open

Comments: The Department of State (State) agreed with this recommendation and agreed that more could be done by IAEA to define nuclear security program baselines and targets, especially on activities that are mostly or fully within the IAEA's remit. In its January 2020 letter to GAO, State noted that it has advocated for improved program management within the Division of Nuclear Security. State believed the advocacy is having an impact, as is evident in the most recent Nuclear Security Report, which included reference to the continued application of a results-based approach to nuclear security activities which help drive positive outcomes from Agency assistance. State also noted in its letter that it continues to pursue better performance measures during negotiations of the next IAEA Programme and Budget (for 2022-2023) and in the development of the next IAEA Nuclear Security Plan (for 2022-2025). State said that it will continue to encourage IAEA to apply program management best practices, including comprehensively establishing performance measures, documenting baselines, setting clear goals, and measuring outcomes. GAO will follow up with State officials in fiscal years 2020 and 2021 and review the next IAEA Programme and Budget and the 2022-2025 Nuclear Security Plan (which should be issued in September 2021) to assess whether IAEA has improved nuclear security program performance measures, including by incorporating baselines and measurable targets.

Recommendation: The Secretary of State should work with IAEA and its member states through the Board of Governors to improve how the Division of Nuclear Security (DNS) reports to member states by consistently including the results of performance measures in at least one of the reports. (Recommendation 3)

Agency: Department of State
Status: Open

Comments: The Department of State (State) agreed with this recommendation and its January 2020 letter to GAO it indicated that it is working with the IAEA to improve its reporting. Specifically, State reported that in conjunction with its efforts to address recommendation 2, to improve nuclear security program performance measures, it has seen IAEA's Division of Nuclear Security make improvements in an effort to be more consistent and diligent about providing performance measures and reporting results to IAEA member states. In fiscal years 2020 and 2021, GAO will review available IAEA nuclear security reports and will follow up with State to clarify improvements it has observed in IAEA's nuclear security program reporting.

Recommendation: The Secretary of State should work with IAEA and its member states through the Board of Governors to analyze options to stabilize DNS's funding within current fiscal and political constraints to enhance the sustainability of IAEA's nuclear security program. (Recommendation 4)

Agency: Department of State
Status: Open

Comments: The Department of State (State) agreed with this recommendation, and in its January 2020 letter to GAO, State noted that the sustainability of the Division of Nuclear Security's budget remains a major area of focus. State noted that many IAEA member states maintain a position of zero real growth in IAEA's budget and are reluctant to reapportion funding to nuclear security activities from other IAEA programs. State reported that it will advocate for priority areas in IAEA budget negotiations, such as nuclear security, to gain a greater share of any agreed budget increases as an alternative to shifting funds from other programs. State noted that this remains a challenge, but that it will continue to identify options to enhance the sustainability of the IAEA's nuclear security program, including how best to also strengthen governance of the Nuclear Security Fund. GAO will follow up with State in fiscal years 2020 and 2021 regarding the options it has identified and pursued to improve the sustainability of the nuclear security program and its funding.

Recommendation: The Secretary of State should work with IAEA and its member states through the Board of Governors to strengthen the agency's central coordinating role by following key practices for collaboration. (Recommendation 5)

Agency: Department of State
Status: Open

Comments: The State Department (State) agreed with this recommendation, and in its January 2020 letter to GAO it generally stated that it is working with IAEA and its member states to improve collaboration among nuclear security stakeholders and strengthen the Agency's central coordinating role. However, State's letter did not specify actions that State is undertaking in this regard. Instead, State's letter reiterated coordinating actions that IAEA had already been undertaking at the time of our report. GAO will follow up with State in fiscal years 2020 and 2021 to better understand the actions, if any, it is taking or has planned to strengthen IAEA's central coordinating role, as well as any actions IAEA is taking independently to improve its coordinating role consistent with key practices for effective collaboration.

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 Attorney General should develop and document goals that explain the common outcomes DOJ seeks to achieve through its elder justice efforts. (Recommendation 1)

Agency: Department of Justice
Status: Open

Comments: In its comments on a draft of our report in May 2019, DOJ did not explicitly state whether or not it concurred with the two recommendations we directed to the department, but stated that it is taking our recommendations under serious review. Specifically, DOJ stated that it planned to form a subcommittee within its Elder Justice Working Group to consider the development or clarification of goals and the development of outcome measures. In a follow-up response dated December 17, 2019, DOJ noted that the subcommittee had been formed, and had met to explore the development of additional---or clarification of present---goals, including those referenced in our report. We will continue to monitor DOJ's efforts towards implementing this recommendation.

Recommendation: The Attorney General should develop and document outcome measures to track the progress the agency is making toward achieving its elder justice goals. (Recommendation 2)

Agency: Department of Justice
Status: Open

Comments: In its comments on a draft of our report in May 2019, DOJ did not explicitly state whether or not it concurred with the two recommendations we directed to the department, but stated that it is taking our recommendations under serious review. Specifically, DOJ stated that it planned to form a subcommittee within its Elder Justice Working Group to consider the development or clarification of goals and the development of outcome measures. In a follow-up response dated December 17, 2019, DOJ noted that the subcommittee had been formed, and had met to begin developing and documenting appropriate outcome measures that can better track the Department's progress on its overall elder justice efforts. This will include consideration of the specific suggestions cited in our report, as well exploring opportunities for additional data collection to enhance the Department's efforts and better measure outcomes. We will continue to monitor DOJ's efforts towards implementing this recommendation.

Recommendation: EXIM's chief operating officer should direct EXIM's Credit Review and Compliance Division to assess and document the practicality of incorporating into its preauthorization Character, Reputational, and Transaction Integrity (CRTI) reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants, and, if practical, implement relevant approaches—such as manual searches or batch matching. (Recommendation 1)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In June 2020, we met with EXIM to discuss its efforts to assess the practicality of incorporating into its preauthorization CRTI reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants. Prior to the discussion, EXIM provided some information on its efforts. As part of the June 2020 discussion, we requested that EXIM provide additional information on its assessment. EXIM agreed to do so. We will provide an update on the status of this recommendation when we confirm what actions EXIM has taken in response to this recommendation.

Recommendation: EXIM's chief operating officer should direct EXIM's Credit Review and Compliance Division to assess and document the practicality of incorporating into its postauthorization CRTI reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants and participants, and, if practical, implement relevant approaches—such as manual searches or batch matching. (Recommendation 2)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In June 2020, we met with EXIM to discuss its efforts to assess the practicality of incorporating into its postauthorization CRTI reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants and participants. Prior to the discussion, EXIM provided some information on its efforts. As part of the June 2020 discussion, we requested that EXIM provide additional information on its assessment. EXIM agreed to do so. We will provide an update on the status of this recommendation when we confirm what actions EXIM has taken in response to this recommendation.

Recommendation: The Chief Operating Officer of EXIM should consider establishing documented policies and procedures for (1) determining medium-term delegated authority lenders' eligibility for continued participation in EXIM's programs and (2) decertifying or taking other appropriate actions for such lenders that do not meet compliance or eligibility standards. (Recommendation 1)

Agency: Export-Import Bank of the United States
Status: Open

Comments: EXIM concurred with our recommendation and stated that it will consider establishing documented policies and procedures for determining medium-term delegated authority lenders' eligibility for continued participation in EXIM's programs and decertifying or taking other appropriate actions for such lenders that do not meet compliance or eligibility standards. If implemented effectively, EXIM's planned actions should address the intent of our recommendation. An EXIM official indicated that actions to address this recommendation would be completed during 2020.

Recommendation: The Chief Operating Officer of EXIM should establish documented policies and procedures for periodically reviewing credit programs in which the government bears more than 80 percent of any loss to determine whether private sector lenders should bear a greater share of the risk. (Recommendation 2)

Agency: Export-Import Bank of the United States
Status: Open

Comments: EXIM concurred with this recommendation and stated that it will establish documented policies and procedures for periodically reviewing credit programs in which the government bears more than 80 percent of any loss to determine whether private sector lenders should bear a greater share of the risk. If implemented effectively, EXIM's planned actions should address the intent of our recommendation. An EXIM official indicated that actions to address this recommendation would be completed during 2020.

Recommendation: The Director of DOT's Office of Aviation Analysis should provide periodic external reporting, at a time interval DOT determines appropriate, to the public and policymakers, on the effects of antitrust immunity—based on the range of monitoring activities undertaken by DOT—including whether grants of immunity have achieved anticipated benefits and the status of remedies—such as airport slot divestitures—imposed as part of DOT's approval. (Recommendation 1)

Agency: Department of Transportation: Office of Aviation Analysis
Status: Open

Comments: In September 2020, DOT provided information on updates to how research and other information on antitrust immunity is shared on its web site. We are reviewing this information to determine if it is sufficient to close the recommendation.

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 Secretary of State should, in consultation with USAID and other stakeholders as appropriate, create an initiative-wide planning and reporting mechanism for CBSI that includes the ability to monitor, evaluate, and report the results of their collaborative efforts (Recommendation 1).

Agency: Department of State
Status: Open

Comments: In their formal response to the report, State agreed with the recommendation and noted that they plan to develop an updated Results Framework for CBSI that will provide the basis for initiative-wide planning and reporting. As of November 2019, State indicated that they are developing this updated CBSI Results Framework.

Recommendation: The Secretary of State should ensure that INLs Office of Western Hemisphere Programs develops and implements a data management system for centrally collecting reliable program monitoring data for all INL-funded CBSI activities through its current program monitoring contract or by some other means (Recommendation 2).

Agency: Department of State
Status: Open

Comments: State agreed with the recommendation, noting that INL's Office of Western Hemisphere Programs is working through its existing monitoring and evaluation contract to improve centralized data collection and is developing plans for an enhanced data management system that will facilitate the collection and management of both strategic and implementer-reported data. In addition, State reported that INL is developing complementary bureau-wide monitoring and evaluation guidance and procedures to ensure the consistency and reliability of collected data across INL programs, which include CBSI activities. As of November 2019, State has not yet completed these efforts.

Recommendation: The Secretary of State should ensure that the Director of the Office of U.S. Foreign Assistance Resources provides missions with guidance that clearly documents the department's process for climate change risk assessments for integrated country strategies. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: As of January 2020, the Department of State has revised its integrated country strategy guidance to inform posts that they have the option to include a climate risk assessment annex when they change or update their strategies. State noted that they plan to disseminate this guidance to posts in 2020.

Recommendation: The Secretary of State should, in consultation with other U.S. agencies involved in counternarcotics efforts in Colombia, conduct an evaluation of the long-term effectiveness of eradication and interdiction in reducing the cocaine supply. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: State generally agreed with our recommendation. As of February 2020, State reported that, working with the Department of Defense, it had signed a contract with RAND for an evaluation of counternarcotics efforts in Colombia. The evaluation will, among other things, asses the effectiveness of U.S. government-funded counternarcotics assistance programs in Colombia from 2000 through 2018. RAND plans to complete the evaluation within 16 months of the contract's execution. We will continue to monitor progress on the evaluation and State's efforts to implement our recommendation.

Recommendation: The Secretary of State should, in consultation with other U.S. agencies involved in counternarcotics efforts in Colombia, undertake a comprehensive review of the U.S. counternarcotics approach in Colombia and identify what changes, if any, should be made to the types and combination of U.S. activities, taking into consideration how the relative benefits and limitations between eradication, interdiction, and alternative development may impact the effectiveness of these efforts. (Recommendation 2)

Agency: Department of State
Status: Open

Comments: State generally agreed with our recommendation. As of February 2020, State reported that, working with the Department of Defense, it had signed a contract with RAND for an evaluation of counternarcotics efforts in Colombia. The evaluation will include, among other things, a comprehensive review of the U.S. counternarcotics approach in Colombia that considers the relative benefits and limitations between eradication, interdiction, and alternative development efforts. RAND plans to complete the evaluation within 16 months of the contract's execution. We will continue to monitor progress on the evaluation and State's efforts to implement 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 Secretary of Defense should develop and, as appropriate, implement options for collecting reliable information on the ANDSF conventional forces' ability to operate and maintain U.S.-purchased equipment. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: In commenting on the report, DOD concurred with the recommendation and stated DOD advisors will continue to work with their Afghan counterparts to build their capacity to reliably report information on equipment status. As of September 2020, DOD had not provided an update on actions taken in response to this recommendation.

Recommendation: The Secretary of State should determine the estimated effects of cost inflation on planned CSCP embassy construction capacity and time frames and update this information for stakeholders on a regular basis, such as through the annual budgeting process. (Recommendation 1)

Agency: Department of State
Status: Open
Priority recommendation

Comments: State concurred with this recommendation. As of March 2020, State/OBO had developed a worldwide construction inflation rate and had integrated this rate into its bureau budget request for fiscal year 2021. According to OBO officials, OBO is working to update its budget guidance to ensure the inflation rate is updated and integrated into future bureau budget requests on a regular basis. We will continue to monitor State's implementation of this recommendation.

Recommendation: The Secretary of State should ensure that the Director of OBO conducts an OBO-wide workforce analysis to assess staffing levels and workload capacity needed to carry out the full range of OBO's mission goals, to include the CSCP. Such an assessment could provide a basis for broader stakeholder discussion of OBO's human capital needs and potential prioritization of activities. (Recommendation 3)

Agency: Department of State
Status: Open
Priority recommendation

Comments: State concurred with this recommendation. As of March 2020, State/OBO was working with the Institute for Defense Analysis to conduct an OBO-wide workforce analysis, with initial findings and recommendations planned for early 2020. We will continue to monitor State's implementation of this recommendation.

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open

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

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

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

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

Recommendation: The acting Bank president and Board chairman should ensure that the Bank evaluates and implements methods to further promote and sustain an antifraud tone that permeates the Bank's organizational culture, as described in GAO's Fraud Risk Framework. This should include consideration of requiring training on fraud risks relevant to Bank programs, for new employees and all employees on an ongoing basis, with the training to include identifying roles and responsibilities in fraud risk management activities across the Bank. (Recommendation 1)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM told us it continues work in this area and will provide us information on this work as it is completed. We will continue to monitor EXIM's progress in this area.

Recommendation: The acting Bank president and Board chairman should ensure that the Bank develops and implements an antifraud strategy 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 4)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM told us it was in the final stages of its process for completing its antifraud strategy. We will continue to monitor EXIM's efforts in this area.

Recommendation: The acting Bank president and Board chairman should ensure that the Bank identifies, and then implements, the best options for sharing more fraud-related information--including details of fraud case referrals and outcomes--among Bank staff, to help build fraud awareness, as described in GAO's Fraud Risk Framework. (Recommendation 5)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM stated that it is continuing to work with its Inspector General to implement this recommendation. We will continue to monitor EXIM's progress in this area.

Recommendation: The acting Bank president and Board chairman should lead efforts to collaborate with the Bank's OIG to identify a feasible, cost-effective means to systematically track outcomes of fraud referrals from the Bank to the OIG, including creating a means to link the OIG's proven cases of fraud to the specific Bank transactions from which the OIG actions arose. If any such means are found to be feasible and cost-effective, the acting Bank president and Board chairman should direct appropriate staff to implement them, with such information to be used for purposes consistent with GAO's Fraud Risk Framework, such as data analytics. (Recommendation 6)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM stated that it is continuing to work with its Inspector General to implement this recommendation. We will continue to monitor EXIM's progress in this area.

Recommendation: The acting Bank president and Board chairman should ensure that the Bank monitors and evaluates outcomes of fraud risk management activities, using a risk-based approach and outcome-oriented metrics, and that it subsequently adapts antifraud activities or implements new ones, as determined to be appropriate and consistent with GAO's Fraud Risk Framework. (Recommendation 7)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In November 2019, EXIM stated that it is continuing work to implement this recommendation. We will continue to monitor EXIM's progress in this area.

Recommendation: The Secretary of Defense should assess CFIUS resource requirements within the Office of Manufacturing and Industrial Base Policy (MIBP) and DOD component reviewers in light of increasing workload, and prioritize personnel and funding resources accordingly to review, mitigate, and monitor transactions that are of concern to the department. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation and in August 2020, stated it had augmented the personnel in the Office of the Deputy Assistant Secretary of Defense for Industrial Policy (formally the Office of Manufacturing and Industrial Base Policy) to include 15 federal civilians and 60 contractors to support the current CFIUS caseload. Industrial Policy officials stated that DOD CFIUS component reviewers have also augmented their personnel resources, and that approximately 15 of their contractor employees will support DOD CFIUS stakeholders. However, documentation of the efforts to prioritize personnel and funding resources within DOD CFIUS component reviewers was not available at the time of our follow-up.

Recommendation: The Secretary of Defense, in coordination with the Deputy Assistant Secretary of Defense for MIBP and Office of the Under Secretary of Defense, Personnel and Readiness, should incorporate the results of its efforts to identify, assess, and prioritize national security concerns related to foreign investment in emerging technologies and in proximity to certain critical military locations, into DOD Instruction 2000.25 and communicate the results to DOD component reviewers. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation and stated in July 2019 that it believes the passage of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) will help the department to address concerns related to foreign investment in emerging technologies and in proximity to critical military locations. In August 2020, officials from the Office of the Deputy Assistant Secretary of Defense for Industrial Policy stated that some of the regulations implementing FIRRMA are currently being written, and that the department is also still in the process of updating DOD Instruction 2000.25, which they anticipate completing in April 2021.

Recommendation: Following the completion of its emerging technology study, the Deputy Assistant Secretary of Defense for MIBP should assess what additional authorities may be necessary to address risks related to foreign investment in critical and emerging technologies, and seek legislative action to address risks posed by these investments as appropriate. (Recommendation 3)

Agency: Department of Defense: Office of the Under Secretary of Defense for Acquisition, Technology and Logistics: Office of Manufacturing and Industrial Base Policy: Deputy Assistant Secretary of Manufacturing and Industrial Base Policy
Status: Open

Comments: DOD agreed with this recommendation and stated in July 2019 that it believes the passage of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) should provide the department with the necessary authorities to address concerns related to foreign investment in emerging technologies. However, in August 2020, officials from the Office of the Deputy Assistant Secretary of Defense for Industrial Policy stated that the regulation implementing FIRRMA requrements related to emerging technology is still in the process of being written by the Department of Commerce, and that until these regulations are issued the Department of Defense cannot assess their ability to address concerns related to foreign investment in critical and emerging technologies.

Recommendation: The Deputy Assistant Secretary of Defense for MIBP should update DOD Instruction 2000.25, to include additional guidance and clarification regarding DOD component responsibilities during the CFIUS process and DOD processes for identifying non-notified transactions. (Recommendation 6)

Agency: Department of Defense: Office of the Under Secretary of Defense for Acquisition, Technology and Logistics: Office of Manufacturing and Industrial Base Policy: Deputy Assistant Secretary of Manufacturing and Industrial Base Policy
Status: Open

Comments: DOD agreed with this recommendation and stated in July 2019 that it was working with other CFIUS member agencies to make the formal non-notified process DOD established in 2016 a more robust, interagency process. In August 2020, DOD stated it is still in the process of revising DOD Instruction 2000.25 to include additional information on identifying non-notified transactions, but does not anticipate that the revisions will be completed until April 2021.

Recommendation: The Deputy Assistant Secretary of Defense for MIBP should update and implement requirements identified in DOD Instruction 2000.25 regarding management and oversight of mitigation agreements, such as taking into account the resources needed to effectively monitor agreements, improving communication methods between MIBP and the DOD components, and clarifying component responsibilities in developing and monitoring mitigation agreements. (Recommendation 7)

Agency: Department of Defense: Office of the Under Secretary of Defense for Acquisition, Technology and Logistics: Office of Manufacturing and Industrial Base Policy: Deputy Assistant Secretary of Manufacturing and Industrial Base Policy
Status: Open

Comments: DOD agreed with this recommendation and stated in July 2019 that it is in the process of revising DOD Instruction 2000.25 regarding the management and oversight of mitigation agreements, and have more than doubled their resources for mitigation monitoring. As of August 2020, officials from the Office of Industrial Policy stated that that revisions to DOD Instruction 2000.25 will not be completed until April 2021.

Recommendation: Congress should consider redefining what can be considered an allowable expense to be charged from the administrative account. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of February 2020, two current bills in Congress address this matter. First, the Return Expenses Paid and Yielded Act would amend the Arms Export Control Act to remove an exclusion from the definition of administrative expenses related to military pay and unfunded civilian retirement and other benefits, and would require DOD to review and report to Congress on options for further expanding the use of FMS administrative fees. Second, the Annual Duplication Report Act of 2019 would require DOD to assess and report on (1) any expenses incurred by the U.S. government in operating the FMS program that are not paid for by the administrative fee, (2) their estimated annual cost, (3) the costs and benefits of funding such expenses, and (4) any legislative changes needed to allow the FMS administrative fee to pay for such expenses.

Recommendation: The Director of DSCA should take steps to ensure that comprehensive reviews of the administrative fee rate are completed at least every 5 years. (Recommendation 1)

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

Comments: In its agency response to this report, DSCA concurred with this recommendation. As of December 2018, DSCA had planned to update its policy to clarify its process for completing comprehensive reviews of the administrative fee rate to ensure that adequate planning for the next rate review allows it to be completed on time. However, in updating its policy in April 2019, DSCA did not include any clarifications to ensure comprehensive reviews would be completed at least every 5 years or be adequately planned. As of August 2020, DSCA officials indicated they planned to take further action to address this recommendation by December 2020. We will continue to monitor DSCA's implementation of this recommendation.

Recommendation: The Director of DSCA should direct the Defense Contract Management Agency (DCMA) and the Defense Finance and Accounting Service to work together to ensure timely correction of the fiscal years 2016 and 2017 DCMA contract administration services (CAS) reimbursement issues. (Recommendation 3)

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

Comments: In its agency response to this report, DSCA concurred with this recommendation. In October 2018, DSCA sent a memo to DCMA and DFAS directing them to resolve the reimbursement issues and to develop a corrective action plan. As of August 2020, DSCA officials estimated this corrective action plan would be implemented by December 2020. . We will continue to monitor implementation of this recommendation.

Recommendation: The Director of DSCA should take steps to ensure that comprehensive reviews of the CAS fee rate are completed at least every 5 years. (Recommendation 4)

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

Comments: In its agency response to this report, DSCA partially concurred with this recommendation, noting that although performing a comprehensive review of the CAS fee rate every 5 years is a preferred practice, the agency did not plan to do so for its upcoming fee review due to various factors. In January 2020, DSCA lowered the CAS fee rate based on a rate review completed in 2019, six years after the prior rate review. In addition, in April 2019, DSCA updated related policy but included no clarifications to ensure future comprehensive reviews would be completed at least every 5 years or be adequately planned. As of August 2020, DSCA officials indicated they planned to take further action to address this recommendation by December 2020. We will continue to monitor DSCA's implementation of this recommendation.

Recommendation: The Secretary of the Treasury, as the chair of CFIUS, and working with member agencies, should coordinate member agencies' efforts to better understand the staffing levels needed to address the current and projected CFIUS workload associated with core committee functions. (Recommendation 1)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: In commenting on the report in February 2018, Treasury concurred with the recommendation. In December 2018, Treasury noted that the Foreign Investment Risk Review Modernization Act of 2018 requires each CFIUS member agency to submit detailed spending plans annually for seven years to appropriate congressional committees, including estimated expenditures and staffing levels, and requires annual testimony for seven years from the CFIUS staff chairperson regarding anticipated resource needs. As of November 2019, GAO continues to monitor this recommendation.

Recommendation: The Commissioner of CBP should take steps to evaluate the effectiveness of CBP's IPR enforcement efforts, such as by improving its metrics to track the overall effectiveness of its IPR enforcement efforts, evaluating selected activities to enhance IPR enforcement, and developing a process to assess and share information on port-led initiatives to enhance IPR enforcement (Recommendation 1)

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

Comments: CBP concurred with this recommendation. In September 2018, CBP stated that it had established an IPR working group that meets every 4-6 weeks to implement its Fiscal Year 2018 IPR Strategic Plan and develop priorities and metrics. CBP stated that, in these meetings, headquarters and field personnel share information on the results and effectiveness of local and national port initiatives and develop policies for improving IPR enforcement. Additionally, CBP provided evidence that it has begun efforts to improve its tracking of metrics and evaluation of selected activities to enhance IPR enforcement. For example, CBP provided data for 5 of the 16 measurement indicators included in its IPR Strategic Plan. Additionally, the IPR Strategic Plan includes at least 5 action items to assess or evaluate aspects of CBP's IPR enforcement. As of February 2020, CBP officials indicated they are continuing to work on these efforts. We will continue to monitor their implementation.

Recommendation: The Commissioner of CBP, in consultation with ICE, should assess what, if any, additional information would be beneficial to share with the private sector and, as appropriate, take action to enhance information sharing, where possible, such as by proposing regulatory revisions or requesting additional legal authorities from Congress. (Recommendation 2)

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

Comments: CBP concurred with this recommendation. CBP stated that, in May 2018, it briefed the Senate Finance Committee on six policy goals to improve IPR, import safety, and e-commerce enforcement that require additional legislative authority to implement. In December 2018, CBP stated that it had identified the need to establish an information sharing structure for e-commerce as a first step in implementing its E-Commerce Strategy. CBP officials stated that they would work with offices throughout CBP and with key stakeholders in the trade community and the Commercial Customs Advisory Committee (COAC) to build an information sharing structure and identify the necessary statutory and regulatory changes to implement it. CBP said that, when statutory changes have been identified, it will work through the interagency process to make any necessary Congressional recommendations. In January 2020, the Department of Homeland Security published a report that identified actions to combat trafficking of counterfeit and pirated goods in conjunction with the private sector. These actions included steps to share additional information with the private sector. For example, the report said that when CBP identifies suspected counterfeit merchandise that is destined for a U.S. fulfillment center or warehouse, it will notify the e-commerce platform or other third-party intermediary operating the facility. This will allow the operator of the fulfillment center or warehouse to remove or destroy any identical items from the same seller in coordination with rights holders. The report also recommends the formation of the Anti-Counterfeiting Consortium to Identify Online Nefarious Actors and a framework for sharing information with sellers, shippers, and other third-party intermediaries. If implemented, these steps could help to enhance information sharing with the private sector. GAO continues to monitor the implementation of these actions.

Recommendation: The Secretary of Agriculture should ensure that USDA includes all key monitoring provisions specified by applicable guidance as part of agreements with inter-American organizations. (Recommendation 2)

Agency: Department of Agriculture
Status: Open

Comments: USDA concurred with our recommendation and said that they will implement it, but has not provided any update on their efforts to implement the recommendation as of August 2019.

Recommendation: The Secretary of Agriculture should ensure that USDA officials have full documentation of required monitoring activities in agreements with inter-American organizations. (Recommendation 3)

Agency: Department of Agriculture
Status: Open

Comments: USDA concurred with our recommendation and said that they will implement it, but has not provided any update on their efforts to implement the recommendation as of August 2019.

Recommendation: The Secretary of State should direct the Bureau of International Narcotics and Law Enforcement Affairs to identify and address factors that affect the reliability of its democracy assistance data, such as miscoded or missing data. (Recommendation 1)

Agency: Department of State
Status: Open
Priority recommendation

Comments: Department of State concurred with this recommendation and said it would take steps to implement it. As of January 2020, State reported that its Bureau of the Comptroller and Global Financial Services and Bureau of Administration is expected to complete analysis in 2020 with an associated action plan to address the issues encountered by State's Bureau of International Narcotics and Law Enforcement Affairs (INL) and other bureaus understanding the importance of timely, accurate, complete, and quality data being reported to Federal Procurement Data System- Next Generation and USASpending.gov. State also provided GAO with an overview of its newly established processes in its accounting system to improve data reliability, including ensuring that current and future transactions would maintain coding integrity. State has taken a number of steps to identify and address factors that affect the reliability of its democracy assistance data, such as miscoded data. However, State needs to provide information on steps taken to identify and address other factors, in particular missing data, which affect the reliability of its democracy assistance data. When we confirm what further actions State has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of State should direct the Director of the Office of U.S. Foreign Assistance Resources to implement a process to improve the reliability, accessibility, and standardization of democracy assistance data across the geographic regions of the Bureaus of European and Eurasian Affairs and South and Central Asian Affairs, such as utilizing a centralized database for award data. (Recommendation 2)

Agency: Department of State
Status: Open

Comments: Department of State concurred with this recommendation and said it would take steps to implement it. In January 2020, State reported taking actions to implement the recommendation and we have requested documentation of these actions. In March 2019, Department of State reported that democracy assistance data for all bureaus, including the Bureaus of European and Eurasian Affair (EUR) and South and Central Asian Affairs (SCA), are being tracked and its quality is being improved through the Department's Foreign Assistance Data Review (FADR) process, an ongoing process chartered in September 2014 to understand and document the Department's challenges with capturing all foreign assistance activities from budget planning and allocation through obligation and disbursement in multiple State-owned budget, financial, and program management systems. State reported that through the FADR process, the Office of U.S. Foreign Assistance Resources (F) has been working with the Bureau of the Comptroller and Global Financial Services (CGFS), the Bureau of Administration (A), and bureaus that administer Foreign Assistance to better capture transaction data for all types of foreign assistance-including democracy, human rights, and governance data. State also reported that 13 U.S. Embassy Public Affairs Sections in EUR that receive assistance funding to carry out democracy programs and all 11 posts in SCA are recording their assistance funding awards in the centralized State Assistance Management System (SAMS), which is one of the Department's financial management systems that is used for reporting foreign assistance transactions to ForeignAssistance.gov.

Recommendation: The Director of the Office of Allowances (ALS) should clearly document how the conditions at relevant posts meet the criteria for Director Points to ensure that hardship pay rates for overseas posts are consistently determined across posts and tenures of ALS Directors. (Recommendation 1)

Agency: Department of State
Status: Open

Comments: In commenting on our report, State concurred with our recommendation. As of January 2020, the Director of ALS has not granted any Director Points since the subject GAO review was completed. According to State officials, should points be necessary in the future, ALS will document why the conditions at relevant posts require the use of Director Points connected with hardship pay rates. We will continue to follow-up on this.

Recommendation: The Undersecretary of Management should assess the cost-effectiveness of State's policies and procedures for stopping and starting hardship pay for employees who temporarily leave their assigned overseas posts. (Recommendation 2)

Agency: Department of State
Status: Open
Priority recommendation

Comments: State concurred with this recommendation, and reported that the department is taking a two-pronged approach to reviewing the issue. First, the Department is conducting a comprehensive review of all costs associated with the processing of hardship and other associated allowance and differential cables through reviews of post-level and central expenditures. This review is expected to be complete by October 2020. Second, the Department is costing out alternative methods of addressing allowance and differential costs that reduce the manual effort on the Department but address the need to support costs incurred by Foreign Service Officers overseas. Meetings with Foreign Service Officer staff to understand variances in the current model were held in the summer of 2019. Highlights from those sessions are being incorporated into a proposal to coincide with the review of costs from the first phase. The final proposal is expected to be complete by the end of 2020.

Recommendation: The Department's Comptroller should analyze available diplomatic cable data from overseas posts to identify posts at risk of improper payments for hardship pay, identify any improper payments, and take steps to recover and prevent them. (Recommendation 3)

Agency: Department of State
Status: Open
Priority recommendation

Comments: State concurred with this recommendation. According to State, it continues to identify and seek repayment of improper payments and communicate the importance of timely actions to the regional bureaus and posts to ensure improper payments do not occur. In addition, the Bureau of the Comptroller and Global Financial Services (CGFS) supports the roll out of the Overseas Personnel System, which will centralize the collection of arrival and departure data for the calculation of improper payment notification and risk analysis. To fully implement the recommendation, the Bureau of Human Resources (HR) must complete worldwide deployment of the Overseas Personnel System, and both HR and CGFS would need to complete integration work to enable arrival and departure data to flow in an automated fashion between the two systems. CGFS would then need to provide documentation that the system allows it to more easily identify and prevent improper payments. Preliminary development of the integration will begin in the summer of 2020 while the OPS roll-out continues.

Recommendation: The Acting Director of DSCA should take steps to ensure the collection of data measuring the timeliness of the delivery of equipment and services to recipient countries. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: Based on the evidence DSCA has provided to date, this recommendation remains open. In March and September 2019, DSCA provided responses, including a copy of the October 2018 Memorandum eliminating 13-27, which was the requirement to provide the first item or service within 180 days of signing the LOA. DSCA also indicated that it had established an initiative to identify milestones. In order to close this recommendation, DSCA needs to provide evidence that this initiative resulted in the identification and implementation of metrics and targets to measure the cycle time of FMS sales from LOA implementation to delivery, and the collection of the appropriate data necessary to use the metrics to manage performance. In the absence of such measures, DSCA's elimination of the 180-day requirement is not consistent with GAO's recommendation to ensure the collection of data measuring the timeliness of the delivery and services to recipient countries. GAO is reviewing responses provided in late 2019 to see whether they satisfy the recommendation.

Recommendation: The Acting Director of DSCA should analyze data on all performance metrics to better identify deficiencies. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: In March 2019 DSCA indicated that it has not yet identified the most appropriate milestones to efficiently and effectively track FMS sales. In addition, pursuant to Recommendation #1, DSCA has eliminated the only performance metric for measuring the timeliness of the delivery of goods and services upon executing an LOA. This recommendation remains open until DSCA identifies the metrics, and collects and analyzes the data to measure performance, including the timeliness of the process. GAO is reviewing the responses provided in late 2019 to determine whether they satisfy the recommendation.

Recommendation: The Acting Director of DSCA should develop a workforce plan. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: In March 2019, DSCA officials informed GAO that DSCA will include a workforce plan in a Human Capital Strategy Plan. In June 2019, GAO was informed that the Human Capital Strategy had been completed, and requested a copy. In September 2019, DSCA informed us that the workforce plan should be completed by December 2020. GAO may be able to close this recommendation after receiving and reviewing the Strategy if it includes the promised workforce plan.

Recommendation: The Acting Director of DSCA should develop workload measures for its FMS workforce. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: In March 2019, DSCA informed GAO that it is currently establishing workload models. In order to close Recommendation 4, DSCA should provide, or make available for review, the workload models for the Country Portfolio Director and Country Financial Director positions, as well as the workload models for Title 10 equipping and end-use monitoring positions. In September 2019, DSCA provided information on the status of the efforts to develop workload measures. DSCA should also provide an explanation of why DSCA has determined that these functions lend themselves to a workload model, while other functions do not. GAO is reviewing the response provided in late 2019 to determine whether DSCA has satisfied the recommendation.

Recommendation: To provide reasonable assurance that USRAP applicant fraud prevention and detection controls are adequate and effectively implemented, the Secretaries of Homeland Security and State should conduct regular joint assessments of applicant fraud risk across USRAP.

Agency: Department of Homeland Security
Status: Open

Comments: We reported that the Department of State and DHS's U.S. Citizenship and Immigration Services (USCIS) have not jointly assessed applicant fraud risks across the U.S. Refugee Admissions Program (USRAP), consistent with federal internal control standards and leading practices for fraud risk management. Specifically, we reported that although State and USCIS perform a number of fraud risk management activities and have responded to individual instances of applicant fraud in the program, these efforts do not position State and USCIS to assess fraud risks program-wide for USRAP or know if their controls are appropriately targeted to the areas of highest risk in the program. Therefore, we recommended that the Secretaries of Homeland Security and State conduct regular joint assessments of applicant fraud risk across USRAP. USCIS concurred with our recommendation. In response, State reported that it will work together with USCIS to conduct joint risk assessments by jointly developing a risk assessment framework. According to DHS and State documentation, the departments finalized a joint framework in January 2018. In February 2019, DHS and State provided us with the interim progress report on their efforts to conduct an assessment of applicant fraud risk across USRAP. In June 2019, USCIS reported that DHS and State have completed the planned analysis and the draft report is being prepared for leadership review and clearance. DHS estimated that the report will be completed by September 30, 2020. To fully address the recommendation, State and USCIS should jointly conduct regular fraud risk assessments across USRAP.

Recommendation: To provide reasonable assurance that USRAP applicant fraud prevention and detection controls are adequate and effectively implemented, the Secretaries of Homeland Security and State should conduct regular joint assessments of applicant fraud risk across USRAP.

Agency: Department of State
Status: Open

Comments: We reported that the Department of State and DHS's U.S. Citizenship and Immigration Services (USCIS) have not jointly assessed applicant fraud risks across the U.S. Refugee Admissions Program (USRAP), consistent with federal internal control standards and leading practices for fraud risk management. Specifically, we reported that although State and USCIS perform a number of fraud risk management activities and have responded to individual instances of applicant fraud in the program, these efforts do not position State and USCIS to assess fraud risks program-wide for USRAP or know if their controls are appropriately targeted to the areas of highest risk in the program. Therefore, we recommended that the Secretaries of Homeland Security and State conduct regular joint assessments of applicant fraud risk across USRAP. USCIS concurred with our recommendation. In response, State reported that it will work together with USCIS to conduct joint risk assessments by jointly developing a risk assessment framework. According to DHS and State documentation, the departments finalized a joint framework in January 2018. In February 2019, DHS and State provided us with the interim progress report on their efforts to conduct an assessment of applicant fraud risk across USRAP. In June 2019, USCIS reported that DHS and State have completed the planned analysis and the draft report is being prepared for leadership review and clearance. DHS estimated that the report will be completed by September 30, 2020. To fully address the recommendation, State and USCIS should jointly conduct regular fraud risk assessments across USRAP.

Recommendation: To ensure the transparency and accountability of USDA's selection of countries to receive in-kind food aid, the Secretary of Agriculture should develop guidance to require documentation of the reasons for providing funding to countries that were not on the priority list.

Agency: Department of Agriculture
Status: Open

Comments: The agency agreed with our recommendation. As of February 2020, USDA has not developed guidance to require documentation of the reasons for providing funding to countries that were not on the priority list. In November 2019, USDA officials notified GAO that the responsible USDA office had reorganized, which has caused a delay in their response.

Recommendation: To help ensure that, consistent with the Bellmon amendment, the provision of U.S. in-kind food aid does not result in a substantial disincentive to, or interference with, domestic production or marketing in countries receiving in-kind food aid, the Secretary of Agriculture should monitor markets during implementation of McGovern-Dole projects to identify any potential negative effects, such as unusual changes in prices.

Agency: Department of Agriculture
Status: Open

Comments: The agency agreed with our recommendation. USDA reported that proposed McGovern-Dole commodities are selected in coordination with the host governments in order to ensure they will not disrupt local production, markets, or food prices. However, as of February 2020, USDA has not taken action to monitor markets during implementation of McGovern-Dole projects to identify whether any potential negative effects have occurred, such as disruptions of local production or unusual changes in food prices. In November 2019, USDA officials notified GAO that the responsible USDA office had reorganized, which has caused a delay in their response.

Recommendation: To help ensure that, consistent with the Bellmon amendment, the provision of U.S. in-kind food aid does not result in a substantial disincentive to, or interference with, domestic production or marketing in countries receiving in-kind food aid, the Secretary of Agriculture should evaluate markets after the completion of McGovern-Dole and Food for Progress projects to determine whether markets were negatively affected during project implementation or after project completion.

Agency: Department of Agriculture
Status: Open

Comments: The agency agreed with our recommendation, and has reported actions to address the recommendation. GAO has requested documentation from USDA to confirm the actions taken. As of February 2020, USDA has not provided documentation confirming actions taken. In November 2019, USDA officials notified GAO that the responsible USDA office had reorganized, which has caused a delay in their response.

Recommendation: To strengthen CBP's trade enforcement efforts, the Commissioner of CBP should direct the Office of Trade to include performance targets, when applicable, in addition to performance measures in its Priority Trade Issue strategic and annual plans.

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

Comments: As of August 2019, the seven FY 2019 Priority Trade Issue (PTI) annual plans prepared by CBP's Office of Trade all included performance measures with performance targets, but some plans did not include baselines to measure it's trade enforcement efforts against. The Office of Trade reported that it was in the process of finalizing its FY2020 annual plans, which should be available in December 2019. In addition, the Office of Trade reported that it no longer develops a single strategic plan covering all of its PTIs and only prepares the PTI annual plans.

Recommendation: To strengthen CBP's trade enforcement efforts, the Commissioner of CBP should direct the Office of Trade and the Office of Field Operations to develop a long-term hiring plan that articulates how CBP will reach its staffing targets for trade positions set in the Homeland Security Act and the agency's resource optimization model.

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

Comments: As of June 2019, CBP stated that both the Office of Trade (OT) and Office of Field Operations (OFO) continue to take steps to address hiring gaps which include evaluating approaches to hiring and evaluating and selecting candidates for its various trade positions. For example, OT had developed a recruitment strategy for hiring regulatory auditors. OT reported that it has brought regulatory auditors onboard as a result of its strategy but experienced attrition and challenges in attaining its staffing target for this position. OT and OFO did not provide recruitment strategies for the other trade positions. OFO's Human Capital Division, along with assistance from OT and other CBP components, reported finalizing a long-term hiring plan to meet and maintain the congressional floor for certain trade and revenue positions, including those for import specialists, by the end of fiscal year 2020.

Recommendation: To better assess OBO's performance, the Secretary of State should finalize the mechanisms OBO will use to centrally manage project management data (to include project cost and schedule information), currently termed the Ideal Operational State, and document through appropriate policies, procedures, or guidance.

Agency: Department of State
Status: Open

Comments: As of January 2020, OBO reported the development of an Integrated Master Schedule template that will serve as a single source for project schedule information for all new capital projects, from inception to occupancy. OBO also reported a bureau-wide effort to develop a holistic Data Management Strategy, including project management data among additional categories of data such as portfolio, program, property, and human capital. GAO continues to monitor State's efforts to implement this recommendation.

Recommendation: To enhance USAID's financial oversight of implementing partners' spending to implement and support Title II development and emergency projects, the USAID Administrator should take steps to ensure that it collects complete and consistent monitoring data from implementing partners for Title II development and emergency projects on the use of 202(e) funding for cash transfers, food vouchers, and local and regional procurement as well as data on the use of Title II funding for internal transportation, storage, and handling (ITSH) costs, in accordance with established requirements.

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

Comments: In December 2017, USAID informed us that new Title II development awards would require partners to adhere to a requirement that it added in July 2017 to the Food for Peace development award template, which requires programs to provide quarterly performance reports on actual cash transfers, food vouchers, and local and regional procurement activities. USAID also noted that it had developed a new WFP emergency award template with reporting requirements for monitoring data on cash transfers, food vouchers, and local and regional procurement activities. In February 2018, USAID provided support that it has developed training and standardized oversight staff roles and responsibilities to help ensure that complete and consistent monitoring data is collected for Title II development and emergency projects. However, USAID still needs to provide evidence that it collects complete and consistent monitoring data from implementing partners for Title II projects, in accordance with established requirements. As of September 2020, we continue to monitor USAID's ongoing actions taken in response to this recommendation.

Recommendation: To improve the reliability and usefulness of program evaluations for agency program and budget decisions, the Chief Executive Officer of MCC, the Administrator of USAID, the Secretary of Agriculture, the Secretary of Defense, the Secretary of State, and the Secretary of Health and Human Services (in cooperation with State's Office of the U.S. Global AIDS Coordinator and Health Diplomacy) should each develop a plan for improving the quality of evaluations for the programs included in our review, focusing on areas where our analysis has shown the largest areas for potential improvement.

Agency: Department of Agriculture
Status: Open

Comments: In response to the Foreign Aid Transparency and Accountability Act (FATAA), the USDA Foreign Agricultural Service (FAS) - Food Assistance Division (FAD) updated its Monitoring and Evaluation policy in February 2019. In addition, in May 2019, USDA provided GAO with a draft evaluation quality checklist (EQC) that the FAS - FAD will use to review draft evaluations. The checklist includes specific questions about the evaluation's design, methodology, findings, and conclusions, among other items. USDA FAS-FAD indicated that the criteria used in the checklist were developed in alignment with our report, the quality checklist developed for an assessment of USAID evaluations, and its own internal criteria. As of July 2019, the EQC was in internal clearance. In November 2019, USDA stated that it was piloting a draft of the EQC, however, a re-organization within USDA had affected the timetable for implementing it. USDA stated that it would wait to finalize the EQC until it was able to potentially adjust it to reflect any new duties or priorities under the agency re-organization. We will continue to follow-up with USDA FAS-FAD to determine whether the checklist has been finalized and implemented.

Recommendation: To better ensure that the evaluation findings reach their intended audiences and are available to facilitate incorporating lessons learned into future program design or budget decisions, the Chief Executive Officer of MCC should adjust MCC evaluation practices to make evaluation reports available within the timeframe required by MCC guidance.

Agency: Millennium Challenge Corporation
Status: Open

Comments: MCC concurred with the recommendation but noted that its then-forthcoming revised policy on monitoring and evaluation would state that "MCC expects to make each interim and final evaluation report publicly available as soon as practical after receiving the draft report." This revised guidance did not set a specific time frame for the reviews. In a letter provided to GAO in May 2017, MCC stated that it had initiated a re-design of its evaluation monitoring information system to provide MCC with detailed timelines of each component of the evaluation review and publication process. MCC provided additional information regarding actions taken in follow-up to our recommendations in April 2018. In December 2018, MCC provided GAO with a list of evaluation reports that had been released in calendar years 2017 and 2018. Of the 18 reports that were released in 2017 and 2018, 9 were released in six or fewer months after the date of the report and 9 were released more than six months after the date of the report. These review times represented only a modest improvement over what we found at the time of our report. In our report, we found that 6 of the 16 reports we examined were released within six months of MCC receiving the report, and 10 were released more than six months after MCC received the report. We requested an updated list of evaluation reports from MCC in January 2020 and will continue to review the timelines for release of reports.

Recommendation: To better ensure that the evaluation findings reach their intended audiences and are available to facilitate incorporating lessons learned into future program design or budget decisions, the Secretary of Agriculture should implement guidance and procedures for making FAS evaluations available online and searchable on a single website that can be accessed by the general public.

Agency: Department of Agriculture
Status: Open

Comments: In February 2019, the USDA Foreign Agricultural Service (FAS) - Food Assistance Division (FAD)'s updated Monitoring and Evaluation policy required that all final versions of USDA evaluation reports be made publicly available on the FAS website and that evaluators provide a copy of the evaluation reports that is free of personally identifiable and proprietary information. As of May 2019, USDA has published seven non-sensitive evaluations on the publicly available Development Experience Clearinghouse (DEC) website. As of July 2019, FAS was drafting internal standard operating procedures (SOPs) for making future and past evaluations publicly available on the DEC. In November 2019, USDA stated that it was piloting a draft of the SOPs, however, a re-organization within USDA had affected the timetable for implementing them. USDA stated that it would wait to finalize the SOPs until it was able to potentially adjust them to reflect any new duties or priorities under the agency re-organization. We will continue to follow-up with USDA FAS-FAD to determine whether the SOPs have been finalized and implemented.

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

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

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

Recommendation: To ensure that all relevant U.S. agencies have information on the effect of changes in U.S. policy related to Cuba, the Secretary of State, in consultation with the Department of Commerce, Department of the Treasury, U.S. Department of Agriculture, and other relevant agencies, should take steps to identify and begin to collect the information that would allow them to monitor changes in economic engagement, including with the Cuban private sector.

Agency: Department of State
Status: Open

Comments: State concurred with this recommendation. In April 2017, State reported that it was taking steps to identify and collect information that would enable it to monitor the Cuban economy and changes in the economic environment, including with the Cuban private sector. For example, State noted that Embassy Havana had developed a plan for in-country travel and reporting by identifying key sectors and provinces that could provide additional insights on the Cuban economy. As of July 2017, State reported that the U.S. government had paused most bilateral engagement with the Cuban government while the incoming presidential administration conducted an interagency policy review. However, State noted that during this time the U.S. embassy in Havana produced several analytic cables discussing developments in the Cuban economy. With the release of the administration's National Security Presidential Memorandum "Strengthening the Policy of the United States Toward Cuba" in June 2017, State reported that it would work to implement this policy and would monitor developments in U.S. engagement with the private sector and Cuban economic trends. As of November 2017, State said that it was consulting with interagency partners on developments impacting the Cuban private sector and that it was working with other U.S. agencies to determine how to most effectively redirect resources away from the Cuban government and towards the private sector as called for in the administration's Cuba policy. However, State also noted that operations at Embassy Havana had been significantly affected by Hurricane Irma and the health attacks against U.S. diplomats in Cuba. According to State, the Secretary of State's September 2017 order for all non-emergency U.S. personnel to depart Cuba had limited the ability of Embassy Havana to report on developments there, but that the department would continue to monitor and report on Cuba's private sector to the greatest extent possible and as resources permitted. As of November 2019, State had shared with GAO reporting it had conducted related to Cuba's economy. GAO is in the process of reviewing this documentation and will be making a final decision about whether State has taken sufficient steps to implement GAO's recommendation.

Recommendation: To improve the transparency and clarity of the Trafficking in Persons Report and improve its usefulness as a diplomatic tool to encourage countries to address trafficking, the Secretary of State should improve explanations in narratives for Tier 1 rankings, including using consistent language, as feasible, in the Trafficking in Persons Report.

Agency: Department of State
Status: Open

Comments: In comments on the draft report, State concurred with this recommendation and said that it seeks to make the Trafficking in Persons Report as useful as possible to a broad array of stakeholders and will continue its commitment to ensure each narrative better serves this purpose. GAO analyzed State's 2017, 2018, and 2019 Trafficking in Persons Report and found improvements in the explanations in narratives for Tier 1 countries. However, narratives for some Tier 1 countries did not clearly explain their placement, including language that seemed contradictory to certain standards and criteria and ambiguous language that meant we were unable to determine how State had determined whether certain standards and criteria were met. As of December 2019, GAO is continuing to monitor State's efforts to fully implement the recommendation. GAO will review State's upcoming 2020 Trafficking in Persons Report.

Recommendation: To implement DOD guidance requiring the military departments to prepare readiness and Operation and Maintenance (O&M) budget impact assessments during drawdown planning, the Secretary of Defense should direct the Secretaries of the military departments to develop guidance that assigns responsibility for the preparation of impact assessments and includes direction on how such assessments should be conducted as part of drawdown planning.

Agency: Department of Defense
Status: Open

Comments: In commenting on the draft report, DOD concurred with the recommendation. As of August 2018, we are in the process of following up with the department to determine the current status.

Recommendation: To implement DOD guidance requiring the military departments to prepare readiness and O&M budget impact assessments during drawdown planning, the Secretary of Defense should direct the Director, DSCA, to develop an internal control mechanism to determine whether the military departments have completed the required impact assessments before moving forward with drawdown planning and execution.

Agency: Department of Defense
Status: Open

Comments: In commenting on the draft report, DOD concurred with the recommendation. As of August 2018, we are in the process of following up with the department to determine the current status.

Recommendation: To improve the effectiveness of the SEC's conflict minerals disclosure rule, the Secretary of Commerce should submit to the appropriate congressional committees a plan outlining steps that Commerce will take, with associated time frames, to (1) assess the accuracy of the independent private sector audits (IPSA) and other due diligence processes described under section 13(p) of the Securities Exchange Act of 1934; (2) develop recommendations for the process used to carry out such audits, including ways to improve the accuracy of the audits and establish standards of best practices for such audits; and (3) acquire the necessary knowledge, skills, and abilities to carry out these responsibilities.

Agency: Department of Commerce
Status: Open
Priority recommendation

Comments: Commerce agreed with this recommendation. In response to this recommendation, Commerce indicated in an October 25, 2016 letter to GAO that it has developed a three-step approach which parallels the three distinct elements of the recommendation. To fully implement this recommendation, Commerce needs to submit the said three-step plan, including associated timeframes for their completion, to the appropriate congressional committees. Section 1502 of the Dodd-Frank Act defines "appropriate committees" to mean the Committee on Appropriations, the Committee on Foreign Affairs, the Committee on Ways and Means, and the Committee on Financial Services of the House of Representatives; and the Committee on Appropriations, the Committee on Foreign Relations, the Committee on Finance, and the Committee on Banking, Housing, and Urban Affairs of the Senate. In a January 2018 email, a Commerce official indicated to GAO that the agency had reviewed the 19 IPSA audits filed by companies in 2016, and the agency plans to complete a review of the 16 IPSA audits filed in 2017 by the end of FY 2018. However, the official noted that the "Department will not undertake the development of recommendations and best practices while the SEC is revising its rule." Commerce cited SEC staff's recent updated guidance and ongoing reviews of the conflict minerals rule, among other things, as their primary reason. However, the SEC staff's updated guidance also clarified that the guidance "does not express any legal conclusion on the rule" and is "subject to any further action that may be taken by the Commission." Therefore, the rule is still in effect, according to SEC staff. We requested a status update in October 2019 and Commerce responded: "In National Association of Manufacturers v. United States SEC, 2017 U.S. Dist. LEXIS 135732 (2017), the District Court for the District of Columbia declared an element of the relevant SEC rule unconstitutional, necessitating that the SEC determine how that decision affects overall implementation of the Conflict Minerals rule. Until the SEC completes its deliberative process, makes such determination, and implements any necessary revisions to the rule, the Department does not intend to undertake additional work under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act with regard to the assessment of the accuracy of the audits and other due diligence processes or recommendations regarding the audits. After which point, the Department will assess how the SEC determination and any revisions to the rule affect the Department's plans for implementing GAO's recommendation."

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

Agency: Department of State
Status: Open
Priority recommendation

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

Recommendation: To improve risk management in the collection of AD/CV duties and to identify new or changing risks, CBP should regularly conduct a comprehensive risk analysis that assesses both the likelihood and the significance of risk factors related to AD/CV duty collection. For example, CBP could construct statistical models that explore the associations between potential risk factors and both the probability of nonpayment and the size of nonpayment when it occurs.

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

Comments: As of December 2019, CBP was taking steps to conduct the type of risk analysis GAO recommended in July 2016. In November 2019 we reported that according to CBP , the agency had developed and successfully tested two models using risk factors including, but not limited to, the type of good, country of origin of the good, and whether the importer is from a foreign country. One test demonstrated that, using data from fiscal years 2007-2015, CBP could have predicted over 95 percent of the importers with delinquent antidumping and countervailing (AD/CV) duty bills in fiscal years 2016 and 2017. CBP requested $17 million in fiscal year 2020 funds to make updates to its information systems necessary to facilitate the implementation of statistical models. CBP is also working on long-term enhancements to the models that it says will leverage additional modeling techniques, such as social network and spatial analysis. Regularly conducting a comprehensive risk analysis of factors related to AD/CV duty non-collection could enhance CBP's capacity to collect additional revenue by enabling CBP to increase bonding amounts for continuous entry and single-transaction bonds for importers with a greater risk of nonpayment. In a December 2019 Commercial Customs Operations Advisory Committee report, CBP said that it planned to begin rolling out a risk-based bonding framework in March 2020. The new framework relies on a bond formula that is in part based on risk factors identified by the statistical models .

Recommendation: To improve risk management in the collection of AD/CV duties, CBP should, consistent with U.S. law and international obligations, take steps to use its data and risk assessment strategically to mitigate AD/CV duty nonpayment, such as by using predictive risk analysis to identify entries that pose heightened risk and taking appropriate action to mitigate the risk.

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

Comments: As of December 2019, CBP was taking steps to develop a risk-based AD/CV bonding framework to use in conjunction with the development of an AD/CV risk assessment model. CBP is developing a supplemental AD/CV duty continuous entry bond that incorporates nonpayment risk factors identified in its statistical models and has worked with Commercial Customs Operations Advisory Committee (COAC) to test the proposed risk based bonding formula by applying it to historical data. CBP has estimated that the collection rate under the risk-based bonding framework using the proposed formula would have been significantly higher than the collection rate under its existing bond policies during fiscal years 2007-2017, both in number and value of the bills collected; however, COAC members said the proposed bond formula would have resulted in overinsurance, which could increase cost to importers. The use of supplemental continuous entry bonds may require regulatory changes and modifications to CBP's database. CBP has also conducted an analysis of the use of single-transaction bonds using historical data, and found that this procedure would have allowed CBP to collect significantly more revenue in fiscal years 2007-2018. CBP is working with COAC members to test a risk-based application of single-transaction bonds to historical AD/CV duty entries to assess whether the bond would have reduced the amount of uncollected duties. In a December 2019 Commercial Customs Operations Advisory Committee report, CBP said that it plans to rolls out its risk-based bonding framework in March 2020.

Recommendation: To make the best use of federal resources directed toward combating FGM/C in the United States, the Attorney General and the Secretaries of Education, Health and Human Services, Homeland Security, and State should each develop a written plan that describes the agency's approach for conducting education and outreach to key stakeholders in the United States regarding FGM/C.

Agency: Department of Education
Status: Open

Comments: The Department of Education (Education) concurred with this recommendation. In February 2020, Education told us that it had awarded three grants that, while not focused on FGM/C, may be used for student safety and health at the U.S. state and local levels. After it evaluates grantees' need for information and resources related to FGM/C, Education will determine its next steps. In addition, Education reported that it continues to participate on the federal interagency workgroup devoted to FGM/C and has dedicated program staff to respond to issues related to FGM/C. Education expects to finalize its written plan by August 2020.

Recommendation: To make the best use of federal resources directed toward combating FGM/C in the United States, the Attorney General and the Secretaries of Education, Health and Human Services, Homeland Security, and State should each communicate the plan with other relevant federal agencies and stakeholder groups, as appropriate.

Agency: Department of Education
Status: Open

Comments: The Department of Education (Education) concurred with this recommendation, and noted in a February 2020 update that it is in the process of determining next steps for certain FGM/C awareness activities that may be included in the written plan it will develop. Education expects that it will finalize its written plan by August 2020, at which point it should also communicate that plan with other federal agencies and stakeholder groups to address our recommendation.

Recommendation: To help ensure vulnerable unaccompanied children receive child advocate services, the Secretary of the Department of Health and Human Services should direct ORR to develop a monitoring process that includes: (1) regularly reviewing referrals to the program contractor, including identifying which care providers in locations with a child advocate program do not make referrals; and (2) reviewing information on the children the program contractor determines it is unable to serve.

Agency: Department of Health and Human Services
Status: Open

Comments: In June 2016, the Office of Refugee Resettlement (ORR) reported that it was working with the child advocate contractor to develop standard operating procedures (SOP) to assign child advocates for children. In February 2020, ORR reported that the finalized SOPs are being implemented. Agency officials stated that they are reviewing program referrals through monthly reporting and calls with the contractor. ORR officials also said they allow the contractor to determine which unaccompanied children are provided a child advocate and there are insufficient resources to assign advocates to all children that are referred. In August 2020, ORR reported that the agency is in the process of developing a new case management system that will enhance its monitoring of the child advocate program, including the ability to analyze child advocate referral data. This system is expected to be fully operational in late 2021.

Recommendation: To strengthen compliance with the Leahy laws and implementation of State's human rights vetting process and to help ensure that U.S. funded assistance is not provided to Egyptian security forces that have committed gross violations of human rights, as State works to implement a revised version of the International Vetting and Security Tracking system (INVEST) system that is expected to help facilitate equipment vetting, the Secretary of State should develop time frames for establishing corresponding policies and procedures to implement a vetting process to help enable the U.S. government to provide a more reasonable level of assurance that equipment is not transferred to foreign security forces, including those in Egypt, when there is credible information that a unit has committed a gross violation of human rights.

Agency: Department of State
Status: Open
Priority recommendation

Comments: State agreed with this recommendation. State acknowledged challenges identifying recipients of equipment across the range of assistance activities, but noted that it would continue to update its systems and procedures to facilitate human rights vetting for recipients of equipment. In April 2017, State reported that it had provided finalized guidance on vetting Egyptian recipients of Foreign Military Financing-funded equipment to Embassy Cairo and that these procedures had been incorporated into a revised version of Embassy Cairo's guide for conducting human rights vetting. At the time, State noted that Embassy Cairo had begun to implement these procedures. However, State subsequently reported that implementation of these procedures lapsed in 2018 due to staff turnover at Embassy Cairo. As of January 2020, State said that it intends to have new standard operating procedures in place for equipment vetting in Egypt later in 2020. In addition, State has not adopted procedures, similar to those in development for Egypt, to be used more broadly in other countries that also receive equipment through the Foreign Military Financing account or through other U.S. assistance programs. As of June 2017, State had added new features to INVEST, its human rights vetting system, to help facilitate vetting of equipment recipients, and published new vetting guidance requiring screening of equipment transfers. However, State has not established global requirements for posts to use the new equipment vetting system features to screen equipment transfers. As of February 2020, State reported that it had developed draft standard operating procedures for conducting equipment vetting globally; however, these procedures are being reviewed internally within the Department and are expected to be finalized later in 2020. We will continue to monitor agency efforts to implement this recommendation.

Recommendation: While recognizing that cargo preference serves policy goals established by Congress with respect to the U.S. merchant marine, including maintenance of a fleet capable of serving as a naval and military auxiliary in time of war or national emergency, Congress should consider clarifying cargo preference legislation regarding the definition of "geographic area" to ensure that agencies can fully utilize the flexibility Congress granted to them when it lowered the CPFA requirement.

Agency: Congress
Status: Open

Comments: GAO did not receive comments on the Matter for Congressional Consideration. As of July 2020, GAO found no evidence of legislation having been introduced to clarify the definition of "geographic area" with regard to cargo preference laws.

Recommendation: To enhance State's efforts to protect SWT participants from abuse and the SWT program from misuse, the Secretary of State should direct the Bureau of Education and Cultural Affairs to establish a mechanism to ensure that sponsors provide complete and consistent lists of fees that participants must pay.

Agency: Department of State
Status: Open

Comments: In response to our recommendation that the State Department (State) establish a mechanism to ensure that sponsor provide complete and consistent lists of fees that exchange visitors on the Summer Work Travel program must pay, State acknowledged it collected such fee information in 2016. As July 18, 2018, we are awaiting State's review and analysis of this information to ensure the price lists are consistent and comprehensive, as well as published guidance it is sending to sponsors on how fee and cost information must be listed on their websites so that there will be consistency among sponsors. State indicated its fee study will take place in 2019 to cover the period of 2018. As of August 2020, State indicated that it planned to complete the fee study following final Summer Work Travel rule, pending OMB approval.

Recommendation: To enhance State's efforts to protect SWT participants from abuse and the SWT program from misuse, the Secretary of State should direct the Bureau of Education and Cultural Affairs to establish a mechanism to ensure that information about these participant fees is made publicly available.

Agency: Department of State
Status: Open

Comments: In response to our recommendation that the State Department (State) establish a mechanism to ensure that information about Summer Work Travel participant fees is made publicly available, State noted that it had published a notice for proposed rulemaking on January 12, 2017. When finalized, this would require each sponsor to include in its recruiting material, and post on its main Web site (e.g., with a visible link to such a page on the sponsors homepage), examples of the typical monthly budgets of exchange visitors placed in various regions of the United States to illustrate wages (based on the required weekly minimum of 32-hours of work at a typical host placement) balanced against itemized fees and estimated costs. Until State finalizes this rule, they cannot enforce this requirement. State anticipated releasing the final rule in the middle of 2019, pending OMB approval. As of August 2020 State has not issued a final rule; and OMB approval is still pending.

Recommendation: To enhance State's efforts to protect SWT participants from abuse and the SWT program from misuse, the Secretary of State should direct the Bureau of Education and Cultural Affairs to establish detailed criteria that will allow State to assess the sufficiency and appropriateness of opportunities for cultural activities outside the workplace that sponsors provide to SWT participants.

Agency: Department of State
Status: Open

Comments: In response to our recommendation that the State Department (State) establish detailed criteria that will allow it to assess the sufficiency and appropriateness of opportunities for cultural activities outside the workplace that sponsors provide to Summer Work Travel participants, State published a notice for proposed rulemaking on January 12, 2017. When finalized, this would require sponsors and their host entities to create cultural opportunities at least once per month. The proposed rule also notes that State will issue guidance outlining best practices for cross-cultural programming. As of August 2020 this is not finalized.

Recommendation: To reduce uncertainty about the expected cost and schedule of the U.S. ITER Project and its potential impact on the U.S. fusion program, once the ITER Organization completes its reassessment of the international project schedule, the Secretary of Energy should direct the Associate Director of the Office of Fusion Energy Sciences to use that schedule, if reliable, to propose a final, stable funding plan for the U.S. ITER Project, approve a performance baseline with finalized cost and schedule estimates, and communicate this information to Congress.

Agency: Department of Energy
Status: Open
Priority recommendation

Comments: DOE approved a performance baseline for the first plasma portion of the U.S. ITER Project in January 2017 and communicated that performance baseline to Congress. However, as of June 2020, DOE has not set a performance baseline for the post-first plasma portion of the project. DOE officials told us the Administration was reviewing U.S. participation in ITER. They said that if, at the end of the review, the Administration decided to continue U.S. participation in ITER, then DOE would set a performance baseline for the post-first plasma portion of the U.S. ITER Project.

Recommendation: To reduce uncertainty about the expected cost and schedule of the U.S. ITER Project and its potential impact on the U.S. fusion program, the Secretary of Energy should direct the Associate Director of the Office of Fusion Energy Sciences to direct the U.S. ITER Project Office to revise and update the project's cost estimate to meet all characteristics of high-quality, reliable cost estimates. Specifically, the U.S. ITER Project Office should revise the project's cost estimate to ensure it is credible by including a comprehensive sensitivity analysis that includes all significant cost elements and conducting an independent cost estimate.

Agency: Department of Energy
Status: Open

Comments: DOE revised and updated the cost estimate for the first plasma portion of the U.S. ITER Project in November 2016. Officials reported that, as part of that update, the U.S. ITER Project Office completed a comprehensive sensitivity analysis and that the Office of Science's Office of Project Assessment had conducted a review of the revised cost estimate. However, as of June 2020, DOE had yet to revise and update the cost estimate for the post-first plasma portion of the U.S. ITER Project. DOE officials told us they planned to do so when they set a performance baseline for that portion of the project, which they expected to do if, at the end of an ongoing review, the Administration decided to continue U.S. participation in ITER.

Recommendation: To better ensure that CBP's Office of Field Operations' (OFO) staffing processes are transparent and to help ensure CBP can demonstrate that these resource decisions have effectively addressed CBP's mission needs, the Commissioner of CBP should document the methodology and process OFO uses to allocate staff to land ports of entry on the southwest border, including the rationales and factors considered in making these decisions.

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

Comments: In May 2017, CBP's Office of Field Operations began working with a contractor to develop a comprehensive CBP position allocation methodology and tool. According to CBP officials, the purpose of this tool was to ensure a data driven, transparent process for allocating CBP resources--including staff--to land ports of entry on the southwest border. CBP officials stated that the contractor completed the tool in January 2018, CBP tested the tool in fiscal year 2018, and CBP planned to implement the tool in fiscal year 2019. However, CBP officials told us in September 2020 that a subsequent reorganization of the Office of Field Operations rendered the tool unusable without further modification. As a result, they used a manual method to allocate staff in fiscal year 2020 and plan to do the same in fiscal year 2021. As of September 2020, CBP officials planned to document the methodology and process they are now using to allocate staff to land ports of entry, including rationales and factors considered, by November 2020. This recommendation remains open.

Recommendation: To more effectively manage NDF's resources, increase program accountability, and ensure that NDF has the information necessary to improve program performance, the Secretary of State should direct ISN and NDF to periodically and systematically conduct and document program evaluations of NDF.

Agency: Department of State
Status: Open

Comments: The Department of State concurred with the recommendation. As of September 2020, State had provided some evidence that State was going to conduct an organizational evaluation of the Nonproliferation and Disarmament Fund as called for under the Department's evaluation policy. GAO is now in the process of reviewing the evidence that State has provided.

Recommendation: In order to contain costs and reduce duplication of administrative support services overseas, Congress may wish to consider requiring agencies to participate in ICASS services unless they provide a business case to show that they can obtain these services outside of ICASS without increasing overall costs to the U.S. government or that their mission cannot be achieved within ICASS.

Agency: Congress
Status: Open

Comments: As of December 2019, no legislative action has been identified. Congress has not required agencies to participate in ICASS absent a business case that shows that they can obtain services outside ICASS without additional cost to the U.S. government, as GAO suggested in January 2012. GAO identified no congressional action on this matter in fiscal year 2019. In January 2014, the joint explanatory statement regarding the Consolidated Appropriations Act, 2014, included a direction that the Secretary of State develop, in coordination with the ICASS Service Center and participating agencies, an efficient process by which an agency participating in the ICASS program provides a cost analysis and justification for the agency's decision to opt out of any ICASS services. However, this direction does not require agencies to participate in ICASS absent such a justification. Action on this matter is important because continued duplication of administrative services limits ICASS's ability to achieve economies of scale and deliver services more efficiently.

Recommendation: To better understand the extent to which deployed DOD civilian employees have access to needed medical care, as appropriate, the Secretary of Defense should direct the Combatant Commander of U.S. Central Command to clarify the level of care that deployed DOD civilian employees can expect in theater, including their eligibility for routine care.

Agency: Department of Defense
Status: Open

Comments: DOD has not implemented this recommendation. In July 2019, DOD officials responsible for policy concerning deployed civilians clarified that DOD policy states deployed civilians are eligible for medical care at the same level and scope as military personnel. However, as of November 2019 they were unable to confirm whether policy in U.S. Central Command reflects this requirement. .