Recommendation: The Assistant Secretary for the Office for Civil Rights should revise its CRDC business rule to require that every school district reporting zeros, regardless of district size or numbers of students with disabilities, affirm the zeros are correct during the CRDC data submission process. (Recommendation 1)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and school districts that report very low numbers of incidents and set data-driven thresholds to detect such incidents. (Recommendation 2)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and schools districts that report very high number of incidents and set data-driven thresholds to detect such incidents. (Recommendation 3)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should apply the CRDC business rule targeting illogical data at the school level to all schools, regardless of the number of incidents reported. (Recommendation 4)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should identify the factors that cause underreporting and misreporting of restraint and seclusion and take steps to help school districts overcome these issues. (Recommendation 5)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should further refine and clarify federal restraint and seclusion definitions and take steps to ensure that this information is conveyed to school districts. This could include providing common classroom scenarios that highlight the differences between a restraint and an escort, and a time out and a seclusion. (Recommendation 6)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Agency: Congress
Status: Open

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

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

Agency: Department of Transportation
Status: Open

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

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

Agency: Department of Transportation
Status: Open

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

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

Agency: Department of Transportation
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Commissioner of Internal Revenue should ensure that the Deputy Commissioner for Services and Enforcement develops and documents improved controls for the validity, completeness, and accuracy of data on FBAR exams and enforcement actions. (Recommendation 2)

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

Comments: In a letter dated October 15, 2018, IRS's Deputy Commissioner for Services and Enforcement stated that IRS is in the process of designing a new FBAR database solution using the FISMA-compliant Entellitrak case management system. The solution will include data fields and systemic controls to ensure the accurate recording and reporting of FBAR case information essential to the whistleblower program. As of December 2019, IRS officials said they are on track to complete this action by June 2020. When we can confirm that IRS has completed this action, we will provide updated information.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Secretaries of the Army, the Navy, and the Air Force; the Commandant of the Marine Corps; and the Commanding General of SOCOM, clarify its guidance on perstempo thresholds as long as the statutory thresholds are waived by either establishing specific and measurable department-wide perstempo thresholds in DOD policy or ensuring that the Army, the Air Force, and the Marine Corps establish and follow their own service-specific guidance on thresholds. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: The Department concurred with this recommendation. In July 2019, the Office of the Undersecretary of Defense for Personnel and Readiness (OUSD/P&R) issued a memo that, among other things, directed the Office of the Assistant Secretary of Defense for Manpower and Reserve Affairs to (1) direct the Military Departments to comply with reporting of the military personnel data and reporting requirements necessary to support the measurement and reporting of the perstempo of the military forces as laid out in DoDI 1336.07; and (2) develop threshold policies for perstempo events. In addition, it stated that the OUSD/P&R will chair a working group to refine optempo and perstempo policy proposals for inclusion into a formal policy document(s). In November 2019, the OUSD/P&R issued another memo that provided broad perstempo policy and emphasized adherence to modified guidance codified in DODI 1336.07, which as of July 2020 is undergoing DOD directives review for issuance. The OUSD/P&R memo further directed the military departments to provide service-level perstempo guidance, to include thresholds and compliance measures, for their components. We will continue to monitor these actions and update the status of our recommendation as appropriate.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in conjunction with the Secretaries of the Army, the Navy, and the Air Force; the Commandant of the Marine Corps; and the Commanding General of SOCOM, take steps to emphasize the collection of complete and reliable perstempo data so that DOD, the services, and SOCOM can monitor perstempo. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: The Department concurred with this recommendation. In July 2019, the Office of the Undersecretary of Defense for Personnel and Readiness (OUSD/P&R) issued a memo that, among other things, directed the Office of the Assistant Secretary of Defense (Readiness) to develop policies for the accurate measurement and reporting of unit operational deployment data. In addition, the Defense Manpower Data Center (DMDC) will (1) conduct department-wide coordination to develop the necessary technical capabilities for DOD to collect, monitor, and evaluate optempo and perstempo data; (2) develop procedures for perstempo and operational deployment data validation to ensure quality checks are conducted regularly and feedback mechanisms to the military departments for error detection and correction are in place, if necessary; and (3) ensure coordination efforts for optempo and perstempo data collection efforts do not duplicate or interfere with current systems collecting such information. In November 2019, the OUSD/P&R issued another memo that provided broad perstempo policy and emphasized adherence to modified guidance codified in DODI 1336.07, which as of July 2020 is undergoing DOD directives review for issuance. This memo and draft instruction provide direction on the reporting of perstempo events and emphasize the collection of complete and reliable perstempo data. Additionally, to enhance data processing and rectify data quality issues, DOD has drafted Uniformed Services Human Resources Information System Procedures, which is also undergoing DoD directives review for official issuance, and DMDC has worked with the services to make specific data improvements. We will continue to monitor for the issuance of the draft DODI and System Procedures and update the status of our recommendation as appropriate.

Recommendation: The Secretary of Transportation should develop an evaluation plan for the Infrastructure for Rebuilding America (INFRA) program in advance of issuing the notice of funding opportunity and ensure the program's evaluation plan clearly defines how all review teams should apply criteria, assess applications, and assign ratings to ensure that all applications are consistently reviewed. (Recommendation 1)

Agency: Department of Transportation
Status: Open

Comments: In 2019, we found that DOT's evaluation plan for the INFRA 2017-2018 round of funding was not finalized prior to DOT's issuance of the notice of funding opportunity. In addition, we raised concerns with a lack of documentation outlining why members of the INFRA senior review team followed up with some applicants over others. DOT told us that, for the fiscal year 2020 INFRA awards, it plans to provide information in the Notice of Funding Opportunity and evaluation plan explaining under the circumstances under which additional information may be sought from applicants. DOT stated that it plans to complete these actions by March 2020. We will continue to monitor DOT's actions.

Recommendation: The Secretary of Transportation should ensure all program applicants be notified in writing of the outcomes of the application selection process. For unsuccessful applicants, the notification should include a brief explanation of the decision. (Recommendation 2)

Agency: Department of Transportation
Status: Open

Comments: DOT officials told us that they formally notified unsuccessful INFRA applicants of selection decisions via email and offered applicants the chance to schedule a debriefing with DOT officials. As of January 2020, we are assessing DOT's actions.

Recommendation: The Secretary of Transportation should require INFRA program teams document their decision-making rationale throughout all levels of review in the application selection process. (Recommendation 3)

Agency: Department of Transportation
Status: Open

Comments: In 2019, we again raised concerns with the lack of documentation outlining DOT's rationale for its INFRA award decisions, as well as a lack of documentation regarding why members of the senior review team followed-up with some applicants over others. DOT stated that it would work to address these issues by updating its internal guidance. We will continue to monitor DOT's actions.

Recommendation: The Secretary of the Army should direct the Chief of Engineers and the Commanding General of the U.S. Army Corps of Engineers to systematically review data on municipal and industrial water storage agreements stored within the OMBIL system and correct errors, as appropriate, to ensure that the data are accurate and complete.

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

Comments: As of September 2020, based on information provided by the Corps, the agency has reviewed approximately half of the data and hopes to review the rest of the data by the end of June 2021.

Recommendation: The Secretary of the Army should direct the Chief of Engineers and the Commanding General of the U.S. Army Corps of Engineers to collect and analyze data on the length of time it takes to complete the reallocation process.

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

Comments: As of September 2020, the Corps is studying how data are captured in the OMBIL system to ensure the agency has a sustainable approach that can be used to collect and analyze data into the future. The Corps hopes to complete its actions on this recommendation by the end of December 2021.

Recommendation: To ensure future large-scale rehabilitation projects are in line with leading project management practices, WMATA should develop a policy that requires and includes relevant procedures specifying that, prior to starting large-scale projects, WMATA should use detailed data on the conditions of assets to develop project objectives and scope.

Agency: Washington Metropolitan Area Transit Authority
Status: Open

Comments: As of July 2020, WMATA is managing three efforts focused on improving WMATA's asset inventory and condition assessment processes. Specifically, WMATA reported that it is developing Data Governance and Standards rules and working with contractors to improve WMATA's asset inventory and condition assessment processes. These efforts should all be complete by the end of 2020. GAO will continue to monitor WMATA's efforts to address this recommendation.

Recommendation: To ensure future large-scale rehabilitation projects are in line with leading project management practices, WMATA should develop a policy that requires and includes relevant procedures specifying that, prior to starting large-scale projects, WMATA should evaluate and compare alternative ways of accomplishing the project objectives, including estimates for the alternatives' costs and impacts.

Agency: Washington Metropolitan Area Transit Authority
Status: Open

Comments: As of July 2020, WMATA has implemented a new process to evaluate major projects. More specifically, WMATA's new initiative includes a process for assessing and presenting alternative strategies for selected major projects. WMATA currently has a number of cases moving through this process for the first time, and GAO will assess the outcomes of these cases as well as the extent to which this process is codified in WMATA policies later in 2020.

Recommendation: To ensure future large-scale rehabilitation projects are in line with leading project management practices, WMATA should develop a policy that requires and includes relevant procedures specifying that, prior to starting large-scale projects, WMATA should develop a comprehensive project management plan for the selected alternative--to include key elements such as detailed plans for managing the project's scope, schedule, and cost--for those projects that may not be designated major capital projects.

Agency: Washington Metropolitan Area Transit Authority
Status: Open

Comments: As of July 2020, WMATA is updating its Infrastructure Project Implementation Manual, which would cover projects such as new construction and rehabilitation of facilities and systems. WMATA is planning to issue the update for the Project Implementation Manual by end of September 2020. GAO will continue to monitor WMATA's progress in addressing this recommendation.

Recommendation: The Secretary of Education should assess and improve, as necessary, the quality of data and methods used to forecast borrower incomes, and revise the forecasting method to account for inflation in estimates.

Agency: Department of Education
Status: Open
Priority recommendation

Comments: The Department of Education agreed to assess and improve its borrower income data, and adjust incomes for inflation. In model documentation prepared in advance of the agency's fiscal year 2017 financial statements, Education acknowledged problems in the estimated borrower income data it used to estimate income-driven repayment (IDR) plan costs, and said it was working to obtain access to actual borrower income data for use in its cost estimates. Education implemented part of this recommendation by adjusting borrower incomes for inflation, which caused a downward re-estimate of IDR plan costs totaling $17.1 billion. GAO will monitor Education's progress in implementing the other part of the recommendation.

Recommendation: The Secretary of Education should complete efforts to incorporate repayment plan switching into the agency's redesigned student loan model, and conduct testing to help ensure that the model produces estimates that reasonably reflect trends in Income-Driven Repayment plan participation.

Agency: Department of Education
Status: Open

Comments: The Department of Education (Education) agreed to incorporate repayment plan switching into its redesigned student loan model, reiterating that efforts to incorporate this capability into a new microsimulation model had begun despite challenges inherent in predicting borrower behavior. However, Education's current student loan model still does not allow for estimating the effects of repayment plan switching. In the interim, Education updated its repayment plan selection assumption to more accurately reflect recent trends in income-driven repayment plan participation. GAO will monitor the progress of Education's efforts to implement the planned model redesign with the capability to incorporate plan switching behavior.

Recommendation: To make it more likely that HHS will achieve its goals to reduce quality measure misalignment and associated provider burden, the Secretary of HHS should direct CMS and the Office of the National Coordinator for Health Information Technology to prioritize their development of electronic quality measures and associated standardized data elements on the specific quality measures needed for the core measure sets that CMS and private payers have agreed to use.

Agency: Department of Health and Human Services
Status: Open

Comments: In January 2019, HHS told us that CMS completed an analysis to determine which measures-from the core measure sets that CMS and private payers have agreed to use-are feasible to develop as electronic clinical quality measures. Further, in April 2019, CMS officials told us they will consider developing new electronic clinical quality measures where appropriate and feasible to fill future measure needs or gaps identified by the Core Quality Measures Collaborative (CQMC). However, we determined that the actions did not fully address the recommendation because they do not include efforts to work with ONC to prioritize their development of electronic clinical quality measures for the CQMC core measure sets. We will update the status of this recommendation when we receive additional information.

Recommendation: To make it more likely that HHS will achieve its goals to reduce quality measure misalignment and associated provider burden, the Secretary of HHS should direct CMS to comprehensively plan, including setting timelines, for how to target its development of new, more meaningful quality measures on those that will promote greater alignment, especially measures to strengthen the core measure sets that CMS and private payers have agreed to use.

Agency: Department of Health and Human Services
Status: Open

Comments: In April 2019, HHS told us that CMS had conducted an assessment of the impact of selected measures used in its quality programs and has linked key component of that assessment to some meaningful measure areas that CMS has identified as priorities. However, this document did not include elements of a comprehensive plan--such as setting timelines-for how to target its development of new, more meaningful quality measures that will promote greater alignment. We will update the status of this recommendation when we receive additional information.

Recommendation: In order to strengthen investment decisions, place the chosen investments on a sound acquisition footing, provide a better means of tracking investment progress, and improve the management and transparency of the U.S. missile defense approach in Europe, the Secretary of Defense should direct MDA's new Director to include in its resource baseline cost estimates all life cycle costs, specifically the operations and support costs, from the military services in order to provide decision makers with the full costs of ballistic missile defense systems.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD partially concurred with our 2013 recommendation that decisionmakers should have insight into the full lifecycle costs of MDA's weapon systems outlined in the Ballistic Missile Defense System Accountability Report (BAR), including the military services' operations and sustainment (O&S) costs. This is especially important, as after more than a decade MDA has yet to transfer weapon systems in production and sustainment to the military services, as originally intended. Consequently, MDA is becoming responsible for an increasing amount of the costs associated with these weapon systems. DOD and Congress have expressed concerns over this situation and are exploring a path forward; however, in the mean time, determining the O&S costs can help decisionmakers fully understand the financial responsibility for these weapon systems, be it with the military services or MDA. MDA cited beginning to report aspects of this information in the BAR and also establishing joint cost estimates (JCE) for O&S with the military services for some weapon systems, both of which could potentially serve as a means of providing decisionmakers with insight into the full lifecycle costs. We have an ongoing assessment that will evaluate both of MDA's cited efforts and the extent to which these are providing decisionmakers with a comprehensive understanding of the depth and breadth of each weapon system's full lifecycle costs.

Recommendation: In order to strengthen investment decisions, place the chosen investments on a sound acquisition footing, provide a better means of tracking investment progress, and improve the management and transparency of the U.S. missile defense approach in Europe, the Secretary of Defense should direct MDA's new Director to stabilize the acquisition baselines, so that meaningful comparisons can be made over time that support oversight of those acquisitions.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with our 2013 recommendation regarding the need for MDA to stabilize its acquisition baselines, but also noted MDA's need to adjust its baselines to remain responsive to evolving requirements and threats; both of which are beyond MDA's control. Further, DOD highlighted the MDA Director's authority to make adjustments to the agency's programmatic baselines, within departmental guidelines. Our recommendation, however, is not designed to limit the Director's authority to adjust baselines or to prevent adjusting the baselines, as appropriate. Rather, our recommendation is designed to address traceability issues we have found with MDA's baselines, which are within its control. Specifically, for MDA to be able to effectively report longer-term progress of its acquisitions and provide the necessary transparency to Congress, it is critical that the agency stabilize its baselines so that once set, any revisions can be tracked over time. We have an ongoing assessment to update MDA's progress.

Recommendation: To improve the Bureau's use of its master schedule to manage the 2020 decennial census, the Secretary of Commerce should require the Director of the U.S. Census Bureau to include estimates of the resources, such as labor, materials, and overhead costs, in the 2020 integrated schedule for each activity as the schedule is built, and prepare to carry out other steps as necessary to conduct systematic schedule risk analyses on the 2020 schedule.

Agency: Department of Commerce
Status: Open
Priority recommendation

Comments: Commerce neither agreed nor disagreed with this recommendation. Regarding GAO's 2013 assessment of the Bureau's schedule (GAO-14-59), Bureau officials stated that they hoped to begin identifying the resources needed for each activity in their schedules by early 2014. Bureau officials announced they had completed the 2020 Census schedule in July 2016, and have since periodically described their intent to link resources to activities within their schedules. However, as of May 2018, when the Bureau had not taken these steps. Senior Bureau officials stated that it would require additional staffing in order to plan for and implement this recommendation. In July 2018 (GAO-18-589) we reported again on the status of the Bureau's scheduling, stating that when the Bureau has resource loaded its schedule, it will be able to use the schedule more effectively as a management tool. The Bureau took steps toward assigning resources to its master activity schedule for the 2020 Census, but effectively ran out of time to do so. Assigning resources to large complex schedules is easier to do early in schedule development process, as we recommended the Bureau do in 2009 for its 2020 Census schedule. This recommendation will remain open pending the Bureau taking steps in developing its 2030 schedule with appropriate resources linked to it.

Recommendation: Given the potential for improving compliance now and in the future, Congress may wish to provide IRS with the authority to use math error checks to identify and correct returns with ineligible (1) IRA "catch-up" contributions, and (2) contributions to traditional IRAs from taxpayers over age 70-1/2.

Agency: Congress
Status: Open

Comments: As of March 2020, Congress has expanded IRS's math error authority in certain circumstances, but not as broadly as GAO suggested in February 2010. Section 208 of division Q of the Consolidated Appropriations Act, 2016 (Public Law 114-113 enacted in December 2015) gave IRS the authority to use math error authority if (1) a taxpayer claimed the Earned Income Tax Credit, Child Tax Credit, or the American Opportunity Tax Credit (AOTC) during the period in which a taxpayer is not permitted to claim such credit as a consequence of either having made a prior fraudulent or reckless claim; or (2) a taxpayer omitted information required to be reported because the taxpayer made prior improper claims of the Child Tax Credit or the AOTC. While expanding math error authority is consistent with what GAO suggested in February 2010, GAO maintains that a broader authorization of math error authority with appropriate controls would enable IRS to correct obvious noncompliance, would be less intrusive and burdensome to taxpayers than audits, and would potentially help taxpayers who underclaim tax benefits to which they are entitled. If Congress decides to extend broader math error authority to IRS, controls may be needed to ensure that this authority is used properly such as requiring IRS to report on its use of math error authority. The Administration also requested that Congress expand IRS's math error authority as part of the Service's Congressional Budget Justification and Annual Performance Report and Plan for fiscal year 2019. Specifically, the Administration requested authority to correct a taxpayer's return in the following circumstances: 1) the information provided by the taxpayer does not match the information contained in government databases; 2) the taxpayer has exceeded the lifetime limit for claiming a deduction or credit; or 3) the taxpayer has failed to include with his or her return certain documentation that is required by statute. As of April 2019, the Congress had not provided IRS with such authority.