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 Under Secretary for Health should, in collaboration with relevant VBA and NCA officials, improve its process to accurately identify all on-campus veteran deaths by suicide by ensuring that it uses updated information and corroborates information with VA facility officials. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should expand the policy requirement for a root cause analysis to include all cases of on-campus veteran death by suicide, regardless of whether the veterans involved were enrolled in VHA health care services at the time of their death. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Under Secretary for Health should direct the Office of Mental Health and Suicide Prevention to expand its analyses of on-campus veteran deaths by suicide to include all relevant information VA collects for these incidents, such as data from root causes analyses and information collected through the Behavioral Health Autopsy Program. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

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

Agency: Department of Energy
Status: Open

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

Recommendation: The Commissioner of Internal Revenue should update the FAQs issued in 2019 to include a statement that the FAQs may serve as a source of general information but cannot be relied upon by taxpayers as authoritative since they are not binding on IRS. (Recommendation 1)

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

Comments: IRS disagreed with this recommendation. In an August 2020 letter, IRS stated that the 2019 currency FAQs are illustrative of how longstanding tax principles apply to property transaction and IRS does not take positions contrary to public FAQs. However, if IRS intends the public FAQs on virtual currency to be binding on IRS it could address our recommendation by publishing the FAQs in the Internal Revenue Bulletin. Doing so would render a disclaimer statement unnecessary and would satisfy the intent of the recommendation. We will continue to follow up with IRS on this recommendation and will provide an update if IRS takes action.

Recommendation: The Commissioner of Internal Revenue should take steps to increase third-party reporting on taxable transactions involving virtual currency, which could include clarifying IRS's interpretation of existing third-party reporting requirements under the Internal Revenue Code and Treasury Regulations, or pursuing statutory or regulatory changes. (Recommendation 2)

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

Comments: IRS agreed with this recommendation. In August 2020, IRS informed us that IRS's Office of Chief Counsel and the Department of the Treasury are developing guidance that will address third-party reporting on certain taxable transactions involving virtual currency. IRS expects that this guidance will also propose rules to avoid duplicate reporting under other information reporting regimes that may apply to transactions involving virtual currency. We will continue to monitor IRS's efforts to increase third-party reporting on taxable transactions involving virtual currency.

Recommendation: The Commissioner of Internal Revenue should clarify the application of reporting requirements under FATCA to virtual currency. (Recommendation 3)

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

Comments: IRS disagreed with this recommendation. In an August 2020 letter, IRS said it intends to focus on developing guidance regarding information reporting on certain virtual currency transactions involving U.S. businesses instead of clarifying the application of reporting requirements under FATCA to virtual currency. IRS stated that additional guidance on FATCA requirements may be appropriate in the future as the workings of foreign virtual currency exchanges become more transparent over time. We found that many virtual currency stakeholders were uncertain about how, if at all, FATCA requirements apply to virtual currency and would benefit from clarifications to the guidance. We will continue to follow up with IRS on this recommendation and will provide an update if IRS takes action.

Recommendation: The Director of FinCEN, in coordination with IRS as appropriate, should make a statement about the application of foreign account reporting requirements under the Bank Secrecy Act to virtual currency readily available to the public. (Recommendation 4)

Agency: Department of the Treasury: Financial Crimes Enforcement Network
Status: Open

Comments: FinCEN agreed with this recommendation. When we can confirm that FinCEN has taken action we will provide updated information.

Recommendation: The DEA Administrator should develop and implement additional ways to use algorithms in analyzing ARCOS and other data to more proactively identify problematic drug transaction patterns. (Recommendation 1)

Agency: Department of Justice: Drug Enforcement Administration
Status: Open
Priority recommendation

Comments: DOJ agreed with this recommendation and DEA stated it will continue to examine a variety of technologies to analyze ARCOS and other data and implement additional ways to use algorithms to more proactively identify problematic drug transaction patterns.

Recommendation: The DEA Administrator, in coordination with the department-wide efforts on data strategy, should establish and document a data governance structure to ensure DEA is maximizing its management of industry-reported drug transaction data. (Recommendation 2)

Agency: Department of Justice: Drug Enforcement Administration
Status: Open
Priority recommendation

Comments: DOJ agreed with this recommendation. As of September 2019, DEA officials stated that its Office of Information Systems' Chief Data Officer just recently started to work with DOJ and other components to develop a data strategy in response to the recently released department wide strategy, and has begun efforts to develop a governance structure. In November, 2019 DEA indicated it will continue to mature its data governance structure. The intent of this recommendation is for DEA to establish a formalized data governance structure to manage its collection and use of data used to support the Diversion Control Division's mission.

Recommendation: The DEA Administrator should establish outcome-oriented goals and associated measurable performance targets related to opioid diversion activities, using data it collects, to assess how the data it obtains and uses supports its diversion control activities. (Recommendation 3)

Agency: Department of Justice: Drug Enforcement Administration
Status: Open
Priority recommendation

Comments: DOJ neither agreed nor disagreed with this recommendation but DEA stated in November 2019, that it recognizes that measurable performance targets related to opioid diversion activities can serve as leading practices at different organizational levels including the program, project, or activity level. Our recommendation is intended to ensure that DEA can demonstrate the usefulness of the data it collects and uses to support its opioid diversion control activities.

Recommendation: The DEA Administrator, in consultation with industry stakeholders, should identify solutions to address the limitations of the ARCOS Enhanced Lookup Buyer Statistic Tool, to ensure registrants have the most useful information possible to assist them in identifying and reporting suspicious orders to DEA. (Recommendation 4)

Agency: Department of Justice: Drug Enforcement Administration
Status: Open
Priority recommendation

Comments: DOJ agreed with this recommendation and in November 2019, stated it has consulted with industry stakeholders and identified solutions to address the limitations of the tool.

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

Agency: Department of Agriculture
Status: Open

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

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

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

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

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

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

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

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

Agency: Department of Agriculture
Status: Open

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

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

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

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

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

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

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

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

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

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

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

Agency: Department of Veterans Affairs
Status: Open

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

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

Agency: Department of Veterans Affairs
Status: Open

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

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

Agency: Department of State
Status: Open
Priority recommendation

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

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

Agency: Department of State
Status: Open

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

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

Agency: Department of State
Status: Open

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

Recommendation: The Secretary of the Treasury, as Chairperson of the Boards of Trustees, should work with the other trustees to take steps—in consultation with the chief actuaries of SSA and CMS—to improve the management of the report development schedule in order to provide the Trustees reports to Congress by the statutory deadline. These steps could include regularly updating the schedule using actual progress and archiving the final iteration of the schedules. (Recommendation 1)

Agency: Department of the Treasury
Status: Open

Comments: Treasury agreed with the recommendation and said they would work with the other trustees to take steps to improve the management of the report development schedule.

Recommendation: The Secretary of the Treasury, as Chairperson of the Boards of Trustees, should work with the other trustees to establish a policy to inform Congressional committees of jurisdiction when the trustees determine that the reports are expected to miss the issuance deadline. This outreach should include 1) the factors that are contributing to delays, and 2) the reports' expected issuance dates. (Recommendation 2)

Agency: Department of the Treasury
Status: Open

Comments: Treasury agreed with this recommendation. The agency said it would explore the potential for a policy to inform Congressional committees of jurisdiction when the trustees determine that the reports are expected to miss the April 1 deadline.

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

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

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

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

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

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

Recommendation: The Secretary of the Navy should direct NAVSEA to incorporate current cost and program data and an updated cost risk analysis in its planned update of the Columbia class lead submarine cost estimate. (Recommendation 1)

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

Comments: DOD concurred with this recommendation, stating that the Columbia Class Program cost estimate will be updated in 2019 to support the lead ship authorization Decision Acquisition Board in 2020. As of September 2020, we have yet to receive an update on the status of this recommendation.

Recommendation: The Secretary of the Navy should direct NAVSEA to develop a realistic and well-documented estimate of savings from use of the authorities associated with the Fund and incorporate the savings associated with the lead submarine into the Columbia lead submarine cost estimate. (Recommendation 2)

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

Comments: DOD agreed with this recommendation, stating that the updated Columbia Class Program cost estimate would incorporate estimated savings from use of the authorities associated with the fund and savings associated with the Columbia lead submarine cost estimate. In August 2020, Navy officials indicated that NAVSEA updated the Columbia lead submarine cost estimate to include updates to the estimate of savings from the use of the authorities associated with the Fund.

Recommendation: The Secretary of the Navy should direct the Columbia class program office to update the lead submarine cost estimate and cost risk analysis prior to requesting funds for lead submarine construction. (Recommendation 3)

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

Comments: DOD concurred with this recommendation, stating that the lead submarine cost estimate and cost risk analysis will be updated to support the lead ship authorization Decision Acquisition Board in 2020. In August 2020, Navy officials indicated that NAVSEA updated the Columbia lead submarine cost estimate. However, this estimate was completed after funding was requested for lead submarine construction. While the Office of Cost Assessment and Program Evaluation plans to conduct an assessment of this estimate in the summer of 2020, the assessment will also be too late to inform the Navy's funding request.

Recommendation: Congress should consider amending the Internal Revenue Code, Bank Secrecy Act of 1970, and other statutes, as needed, to address overlap in foreign financial asset reporting requirements for the purposes of tax compliance and detection, and prevention of financial crimes, such as by aligning the types of assets to be reported and asset reporting thresholds, and ensuring appropriate access to the reported information.

Agency: Congress
Status: Open

Comments: No legislative action enacted as of January 2020. Congress has not amended the Internal Revenue Code, Bank Secrecy Act of 1970 and other statutes as needed to address overlap in foreign financial asset reporting requirements, as GAO suggested in April 2019. GAO continues to believe that if Congress were to modify these various statutes, the reporting burden created by navigating multiple reporting requirements will be reduced. Modifying these statutes will also allow for the use foreign financial asset information collected under the Foreign Account Tax Compliance Act to prevent and detect financial crimes.

Recommendation: The Commissioner of Internal Revenue should develop a plan to mitigate risks with compliance activities due to the lack of accurate and complete Taxpayer Identification Numbers of U.S. account holders collected from FFIs. (Recommendation 1)

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

Comments: The Internal Revenue Service (IRS) has taken several steps to improve collection of accurate and complete taxpayer identification numbers (TINs) from foreign financial institutions (FFIs). For example, in December 2019, IRS officials said they began identifying 2017 records submitted by FFIs without valid TIN fields or corresponding dates of birth for account holders. IRS also launched a campaign to identify FFIs that did not file a Form 8966 with IRS. While these steps can improve the quality of account data submitted by FFIs, IRS still faces ongoing risks that receiving inaccurate or incomplete TINs pose to efforts to identify and combat taxpayer and FFI noncompliance. Additionally, IRS has not yet developed a plan that elaborates on these risks and identifies steps to mitigate them, as we recommended in April 2019. Without such a strategy, IRS may fail to identify opportunities to adjust compliance programs to better enforce FFI reporting of valid TINs and identify U.S. persons who are not complying with FATCA reporting requirements.

Recommendation: The Commissioner of Internal Revenue should ensure that appropriate business units conducting compliance enforcement and research have access to consistent and complete data collected from individuals' electronic and paper filings of Form 8938 and elements of parent individual tax returns. As part of this effort, the Commissioner should ensure that IRS provides clear guidance to the business units for accessing such data in IRS's Compliance Data Warehouse. (Recommendation 2)

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

Comments: The Internal Revenue Service (IRS) has taken several steps to address this recommendation. According to IRS Information Technology division officials, as of December 2019, they deliver paper and electronically filed Form 8938 data to IRS's Research, Applied Analytics, and Statistics organization on a monthly basis, and makes such data available in the Compliance Data Warehouse (CDW) for use by agency officials. According to Large Business and International (LB&I) Division officials, IRS's enforcement functions also have access to this data. One outcome of this access, according to LB&I officials, is the use of FATCA data in the development of compliance examination leads. However, IRS has not yet developed clear guidance for business units to access relevant data from Forms 8938 and elements of parent individual tax returns in CDW, as we recommended. Without such guidance, CDW users may be less likely to effectively leverage CDW data for examination purposes.

Recommendation: The Commissioner of Internal Revenue should employ a comprehensive plan for managing efforts to leverage FATCA data in agency compliance efforts. The plan should document and track activities over time to
• ensure individuals and FFIs comply with FATCA reporting requirements;
• assess and mitigate data quality risks from FFIs;
• improve the quality, management, and accessibility of FATCA data for compliance, research, and other purposes; and
• establish, monitor, and evaluate compliance efforts involving FATCA data intended to improve voluntary compliance and address noncompliance with FATCA reporting requirements. (Recommendation 3)

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

Comments: In September 2019, IRS's Deputy Commissioner for Services and Enforcement said that IRS disagreed with our April 2019 recommendation. The Deputy Commissioner said that resources that would be dedicated to update a comprehensive plan unique to FATCA-such as the FATCA Compliance Roadmap-are better spent on enforcement activities. The Deputy Commissioner also said that IRS's strategy for FATCA compliance will instead be part of IRS's Large Business & International (LB&I) Division's overall portfolio management strategy. Implementing enforcement activities could increase taxpayers' and foreign financial institutions' (FFIs) compliance with FATCA reporting requirements. While IRS does not have to revise and reemploy its FATCA Compliance Roadmap, it can employ a comprehensive plan as part of LB&I's portfolio management strategy to evaluate FATCA enforcement activities already in place, and determine the extent to which these activities improve voluntary compliance and address noncompliance with FATCA reporting requirements. Without such a plan, IRS risks not maximizing efforts to manage and address the myriad of challenges it faces in effectively ensuring taxpayer compliance.

Recommendation: The Commissioner of Internal Revenue should assess factors contributing to unnecessary Form 8938 reporting and take steps, as appropriate, to address the issue. Depending on the results of the assessment, potential options may include:
• identifying and implementing steps to further clarify IRS Form 8938 instructions and related guidance on IRS's website on determining what foreign financial assets to report, and how to calculate and report asset values subject to reporting thresholds; and
• conducting additional outreach to educate taxpayers on required reporting thresholds, including notifying taxpayers that may have unnecessarily filed an IRS Form 8938 to reduce such filings. (Recommendation 4)

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

Comments: As of February 2020, IRS officials said the agency is in the process of obtaining 2017 and 2018 tax data to analyze the number of unnecessary filings of Form 8938. Completing this data analysis and identifying the full range of factors contributing to unnecessary Form 8938 reporting will allow IRS to better address such factors. These efforts, in turn, will reduce the risk that taxpayers file-and IRS processes-forms that taxpayers were not required to submit to IRS.

Recommendation: The Secretary of the Treasury should lead efforts, in coordination with the Secretary of State and Commissioner of Social Security, to establish a formal means to collaboratively address ongoing issues—including issues accessing financial services and employment and obtaining SSNs—that U.S. persons living abroad encounter from implementation of FATCA reporting requirements. (Recommendation 5)

Agency: Department of the Treasury
Status: Open

Comments: The Department of the Treasury (Treasury) has taken some steps to implement GAO's April 2019 recommendation. Specifically, Treasury proposed changes to the Internal Revenue Service (IRS) relief procedures to abate assessments for certain expatriating taxpayers and is working with IRS and the Department of State (State) to publicize the procedures. In addition, Treasury led efforts with IRS, State, and the Social Security Administration (SSA) to develop frequently asked questions that combine relevant guidance for individuals to obtain a Social Security number, renounce U.S. citizenship, and comply with U.S. tax obligations. However, as of December 2019, Treasury lacked a collaborative interagency mechanism to address ongoing issues U.S. persons living abroad continue to encounter from implementation of Foreign Account Tax Compliance Act (FATCA) reporting requirements. In November 2019, Treasury said it was not the appropriate agency to lead these coordination efforts. However, GAO continues to believe that because Treasury is ultimately responsible for effectively administering FATCA, it is in a better position than State or SSA to establish an effective collaborative mechanism. Doing so will help agencies address the ongoing issues Americans living abroad experience from FATCA.

Recommendation: The Secretary of State, in coordination with the Secretary of the Treasury and Commissioner of Social Security, should establish a formal means to collaboratively address ongoing issues—including issues accessing financial services and employment and obtaining SSNs—that U.S. persons living abroad encounter from implementation of FATCA reporting requirements. (Recommendation 6)

Agency: Department of State
Status: Open

Comments: The Department of State (State) has taken several steps to implement GAO's April 2019 recommendation. In September 2019, State worked with the Department of the Treasury (Treasury), the Internal Revenue Service (IRS), and Social Security Administration (SSA) to develop and post online frequently asked questions on how to obtain a Social Security number, renounce U.S. citizenship, and comply with U.S. tax obligations. Additionally, State officials participated in an October 2019 webinar hosted by IRS regarding newly approved tax relief procedures for certain former citizens who have renounced U.S. citizenship and seek to be federal tax compliant. State also established procedures with SSA for its embassies and consulates abroad to help U.S. citizens apply for a Social Security number during the passport application process without SSA permission, thus removing a significant barrier in serving U.S. citizens abroad. However, as of December 2019, State lacked a collaborative interagency mechanism with Treasury to address ongoing FATCA implementation issues related to access to foreign financial services and denial of employment and promotion opportunities overseas. Treasury is responsible for leading efforts to establish such a mechanism; however, State's participation in such a mechanism on a continuing basis will help agencies address remaining issues Americans living abroad experience from FATCA.

Recommendation: The Commissioner of Social Security, in coordination with the Secretaries of State and Treasury, should establish a formal means to collaboratively address ongoing issues—including issues accessing financial services and employment and obtaining SSNs—that U.S. persons living abroad encounter from implementation of FATCA reporting requirements. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: The Social Security Administration (SSA) has taken or plans to take steps to implement GAO's April 2019 recommendation. SSA worked with the Department of the Treasury (Treasury), the Internal Revenue Service, and the Department of State (State) to develop and post online frequently asked questions on how to obtain a Social Security number, renounce U.S. citizenship, and comply with U.S. tax obligations. Additionally, in October 2019, SSA said it plans to conduct outreach events for U.S persons living abroad who need Social Security numbers. However, as of December 2019, SSA lacked a collaborative interagency mechanism with Treasury and State to address ongoing FATCA implementation issues, such as recurring issues U.S. persons may have obtaining Social Security numbers. Treasury is responsible for leading efforts to establish such a mechanism; however, SSA's participation in such a mechanism on a continuing basis will help agencies address remaining issues Americans living abroad experience from FATCA.

Recommendation: The Director of OMB should clarify and document OMB's procedure for changing official data definition standards for DATA Act reporting, for example, by explicitly describing how change procedures developed for other government-wide initiatives apply to DATA Act definition standards in a public source of guidance or information. (Recommendation 1)

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

Comments: OMB has taken steps to restructure the federal data ecosystem, including issuing government-wide guidance covering all federal data and creating a Business Standards Council. However, given the complexity of recent changes, OMB needs to explicitly and publicly describe how those changes-developed in the context of other government-wide initiatives-apply to DATA Act data element definitions.

Recommendation: The Director of OMB should ensure that the June 2018 policy changes regarding DATA Act data definition standards are clearly identified and explained in the official repository or another authoritative public source of DATA Act standards and guidance, such as by including a revision history along with the current version of the definitions. (Recommendation 2)

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

Comments: In January 2020, OMB staff cited its Federal Spending Transparency Data Standards website and specifically notations on that site regarding the dates of revisions made to those standards as being responsive to this recommendation. However, the specific notations cited by OMB only show changes made back in 2015 and do not reflect nor explain some of the more recent revisions that led to GAO making this recommendation.

Recommendation: The Director of OMB should make available more disaggregated data on fees, fines, and penalties that it maintains in its OMB MAX database. For example, OMB could report data on fee collections by agency in Analytical Perspectives. (Recommendation 1)

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

Comments: The Office of Management and Budget (OMB) did not provide comments on our draft report and therefore neither agreed nor disagreed with this recommendation. As of October 2020, OMB had not provided evidence of any actions taken to implement this recommendation.

Recommendation: The Director of OMB should instruct agencies to regularly review the application of the user fee designation in the OMB MAX data and update the designation, as needed, to meet the criteria in OMB Circular No. A-11. (Recommendation 3)

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

Comments: OMB did not provide comments on our draft report and therefore neither agreed nor disagreed with this recommendation. As of October 2020, OMB had not provided evidence of any actions taken to implement this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in coordination with the Chairman of the Joint Chiefs of Staff, issue a more detailed implementation plan or include implementation plan details in identified formal department-wide guidance to include a description of the resources (i.e., relevant operational and financial information) required to implement the plan including dollar and personnel amounts. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. On February 25, 2020, DOD issued its revised Pre-Positioned War Reserve Materiel Strategic Implementation Plan. However, the updated plan did not include a description of the resources-- including dollar and personnel amounts--required to implement the plan. Instead, the updated plan states that no additional personnel or resources will be required to execute and manage the plan, and that those personnel executing and managing the plan are expected to do so in addition to their normal duties. In May 2020, DOD stated it intends to include additional information about the required resources in the plan's next revision. We will keep this recommendation open pending our review of the next iteration of the plan.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in coordination with the Chairman of the Joint Chiefs of Staff, take steps to fully implement joint oversight of DODs prepositioned stock programs, including providing detailed information on how to implement such an oversight approach in department guidance and reviewing other joint oversight efforts, in order to synchronize the military services' preposition stock strategies to avoid fragmentation. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. On February 25, 2020, DOD issued its revised Pre-Positioned War Reserve Materiel Strategic Implementation Plan which lays out a method for joint oversight. While GAO is encouraged and will monitor DOD's implementation efforts, it is too soon to determine the extent to which these efforts-when completed-will address DOD's fragmented management of its prepositioned stock programs. To fully address this recommendation, DOD needs to fully implement the joint oversight method outlined in the plan.

Recommendation: The Secretary of Energy should direct DOE's Office of Environmental Management to develop a program-wide strategy that outlines how DOE will direct available resources to address human health and environmental risks across and within sites. (Recommendation 1)

Agency: Department of Energy
Status: Open
Priority recommendation

Comments: As of February 2020, DOE's Office of Environmental Management has not developed a program-wide strategy that addresses this recommendation. DOE officials said they are "developing a strategic options analysis to evaluate the current approaches to cleanup and other recently identified opportunities across the complex that could reduce risk and life-cycle costs through more efficient and innovative approaches." According to DOE officials, the analysis will consider risk-based approaches across sites, with the goal of reducing human health and environmental risks and the associated environmental liability.

Recommendation: The Secretary of Energy should direct DOE's Office of Environmental Management to submit in EM's annually required Future-Years Defense Environmental Management Plan all mandated requirements, as well as information on annual growth in environmental liability estimates by site, the key factors causing that growth, and an explanation of significant differences between environmental liability estimates and life cycle cost estimates. (Recommendation 2)

Agency: Department of Energy
Status: Open

Comments: As of February 2020, DOE's Office of Environmental Management has not implemented this recommendation. DOE officials stated that DOE will coordinate with the Office of Management and Budget on the preparation of the Future-Years Defense Environmental Management Plan, or other reporting, to supplement Congressional Budget documentation. Officials also stated that EM is currently undertaking an analysis of EM's environmental liability growth.

Recommendation: The Secretary of Energy should direct DOE's Office of Environmental Management to disclose the funding EM needs to meet all of its schedule milestones called for in compliance agreements in, for example, supplemental reports or the annual Future-Years Defense Environmental Management Plan. (Recommendation 3)

Agency: Department of Energy
Status: Open

Comments: As of February 2020, DOE's Office of Environmental Management has not implemented this recommendation. DOE officials stated that DOE will coordinate with the Office of Management and Budget to include such information in the Future-Years Defense Environmental Management Plan, or another appropriate report.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Policy updates its policy and instruction on providing support to the Secret Service to define the requirements for producing semiannual reports of expenditures required by the Presidential Protection Assistance Act of 1976, as amended. These requirements should, at a minimum, include (1) the steps and time frames for completing updates to the policy and instruction, (2) time frames for reporting the expenditures, and (3) an oversight mechanism to ensure that the Department of Defense consistently submits these reports to specified congressional committees. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with the recommendation. As of July 31, 2019, DOD has not updated its policy or instruction.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Policy defines the steps, including time frames, necessary to achieve near term reporting requirements under the Presidential Protection Assistance Act of 1976, as amended, and submit the reports as required. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with the recommendation. As of July 31, 2019, DOD has not updated its policy.

Recommendation: The Assistant Secretary for Financial Institutions should annually collect and evaluate HFAs' risk assessments, which include HFAs' risk levels. (Recommendation 1)

Agency: Department of the Treasury
Status: Open

Comments: According to Treasury, as of March 2019, the agency had requested that each Housing Finance Agency evaluate its controls and update its Risk and Control Matrix to ensure that it reflects the risk assessment level of each control that has been assessed and to provide this information to Treasury. Treasury stated that it would evaluate the risk assessments to verify that the appropriate risk level had been assessed and that proper segregation of duties exists. As of August 2020, Treasury had not demonstrated that it had annually collected or evaluated HFA's risk assessments.

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense for Acquisition and Sustainment to identify the reasons behind the high rate of miscoding for orders awarded under multiple award contracts and use this information to identify and take action to improve the reliability of the competition data entered into FPDS-NG. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: In November 2018, and in response to our draft report, DOD stated that it would analyze the Federal Procurement Data System- Next Generation data in an effort to identify why the miscoding of orders under multiple award contracts occurs, and use this information to advise the contracting community of actions to improve the reliability of the competition data. In July 2019, DOD officials stated they did not have an update regarding planned actions to address the recommendation. As of September 2020, DOD officials did not respond to our multiple requests for updates to this recommendation.

Recommendation: The Secretary of Health and Human Services should direct the Associate Deputy Assistant Secretary for Acquisition to identify the reasons behind the high rate of miscoding for orders awarded under multiple award contracts and use this information to identify and take action to improve the reliability of the competition data entered into FPDS-NG. (Recommendation 2)

Agency: Department of Health and Human Services
Status: Open

Comments: In February 2019, HHS stated it was performing analysis and research to understand the reasons for the miscoding of orders. Once this analysis and research is completed, HHS reported it plans to work to address the root causes of the previously identified miscodings, so as to prevent future errors. In July 2019, HHS officials stated they did not have an update regarding planned actions to address the recommendation. As of September 2020, HHS officials did not respond to our multiple requests for updates to this recommendation.

Recommendation: The Director of OMB should take steps to update OMB guidance to specify other types of quality information that agencies with programs noncompliant for 3 or more consecutive years should include in their notifications to Congress, such as significant matters related to risks, issues, root causes, measurable milestones, designated senior officials, accountability mechanisms, and corrective actions or strategies planned or taken by agencies to achieve compliance. (Recommendation 1)

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

Comments: The Office of Management and Budget (OMB) neither agreed or disagreed with the recommendation but stated that it had no comments. In January 2020, OMB informed us that it had no status updates to provide at this time. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The Director of OMB should enhance the guidelines for agencies to establish the controls required by FRDAA, by clarifying the difference between FRDAA and ERM requirements, and through collaboration with agencies to determine what additional information agencies need to implement the controls. (Recommendation 1)

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

Comments: In March 2020, the Payment Integrity Information Act of 2019 (PIIA) was enacted to improve efforts to identify and reduce government-wide improper payments, including payments that are the result of fraud. PIIA repealed and replaced FRDAA. However, OMB and the other agencies subject to PIIA essentially must satisfy the same requirements established under FRDAA, including adhering to OMB's related guidelines. OMB has not updated its published guidelines for FRDAA as we recommended. If OMB takes additional actions to supplement guidelines under PIIA, we will review the guidelines to determine whether it addresses our recommendation.

Recommendation: The Director of OMB should enhance FRDAA reporting guidelines by directing agencies to report complete and detailed information on each of the reporting elements specified by FRDAA, which should include information related to financial and nonfinancial fraud. (Recommendation 2)

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

Comments: In March 2020, the Payment Integrity Information Act of 2019 (PIIA) was enacted to improve efforts to identify and reduce government-wide improper payments, including payments that are the result of fraud. PIIA repealed and replaced FRDAA, but maintained similar reporting requirements for federal agencies regarding fraud risks and also extended the time line for reporting by a year. OMB did not update its previous reporting guidance for FRDAA as we recommended. If OMB takes additional actions to supplement reporting guidelines under PIIA, we will review the guidelines to determine whether it addresses our recommendation.

Recommendation: The Secretary of the Army should require monitoring of its processes used for recording all required real property information--to include evaluating on an ongoing basis whether or to what extent these activities are being carried out--and remediating any identified deficiencies. (Recommendation 1)

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

Comments: The Army concurred with this recommendation. As of February 2020, DOD officials told us that the Army has required monitoring of its processes used for recording all real property information. Specifically, the Army developed a 5-year plan to address the recommendations to improve data quality and accountability in conjunction with the ongoing DOD financial statement audit. The plan reportedly requires measuring results through directed physical inspections and record updates, using a single, standardized Accountable Property System of Record (APSR) for all assets. DOD officials also told us that the Army developed an automated validation and second-person verification to comply with the requirements and business rules of the DOD Real Property Information Model (RPIM), and that it continue to use OSD's validation and verification tool when providing annual data inputs to OSD's Real Property Assets Database, with any feedback to be addressed at senior Army levels. However, DOD officials did not provide any documentation that these requirements have been established. Once we receive that documentation, we will review it to assess the extent to which it meets the intent of our recommendation.

Recommendation: The Secretary of the Navy should require monitoring of Navy and Marine Corps processes used for recording all required real property information--to include evaluating on an ongoing basis whether or to what extent these activities are being carried out--and remediating any identified deficiencies. (Recommendation 2)

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

Comments: The Navy concurred with this recommendation. As of February 2020, DOD officials stated that the Navy required monitoring of its processes used for recording real property information. Specifically, the Navy established a requirement for a 100% inventory check to ensure existence and completeness of its real property information. As part of DOD larger effort to improve its financial management through the Financial Improvement and Audit Readiness (FIAR) guidance, DOD officials also told us that the Navy plans to implement the existence and completeness results provided by an independent Public Accounting Firm. Further, it will continue to use OSD's validation and verification tool when providing annual data inputs to OSD's Real Property Assets Database, with any feedback to be addressed at senior Navy levels. However, DOD officials did not provide any documentation that these requirements had been put in place. Once we receive that documentation, we will review it to assess the extent to which it meets the intent of our recommendation.

Recommendation: The Secretary of the Air Force should require monitoring of its processes used for recording all required real property information--to include evaluating on an ongoing basis whether or to what extent these activities are being carried out--and remediating any identified deficiencies. (Recommendation 3)

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

Comments: The Air Force concurred with this recommendation. As of February 2020, DOD officials told us that the Air Force has required monitoring of its processes for recording all required real property information. For example, the Air Force plans to establish a Data Quality Program (DQP) within the Air Force Civil Engineer Center Information Technology Functional Management Office to incorporate requirements for improving accuracy of its asset information in its Accountable Property System of Record (APSR). The Air Force also plans to revise its instruction AFI 32-9005 to define responsibility for the accuracy of data at the lowest level. Further, it plans to require use of OSD's validation and verification tool to identify and correct inaccuracies when providing annual data inputs to OSD's Real Property Assets Database, with any feedback to be addressed at senior Air Force levels. However, DOD officials did not provide any documentation that these requirements had yet been put in place. We await documentation of these requirements and will review them, once received, to assess the extent to which they meet the intent of our recommendation.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense for Acquisition and Sustainment, in collaboration with the military services, defines and documents which data elements within the RPAD submissions are most significant for decision-making. (Recommendation 4)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation to define and document which data elements within its Real Property Assets Database (RPAD) submissions are most significant for decision-making. As of February 2020, DOD officials told us they will conduct a review of all data elements in its Real Property Assets Database, including compiling list of all data elements actively being used by data consumers. DOD also plans to divide required data elements into blocks to begin strenuous monitoring for accuracy. DOD's estimated completion date for these actions is September 2023. We will continue to monitor the completion of DOD's planned actions.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense for Acquisition and Sustainment, in collaboration with the military services, coordinates on corrective action plans to remediate discrepancies in significant data elements in its real property data system that are identified by OSD's verification and validation tool. (Recommendation 5)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with this recommendation to coordinate on corrective action plans to remediate discrepancies in significant data elements in its real property data system that are identified by OSD's verification and validation tool. As of February 2020, DOD officials told us they plan to establish a senior leader Functional Governance Board to monitor accuracy compliance. DOD also plans to establish quarterly progress reports to be posted on the Data Analytics Integration Support (DAIS) application for constant monitoring by all users. DOD's estimated completion date for these actions is September 2022. We will continue to monitor the completion of DOD's planned actions.

Recommendation: The Secretary of Defense should ensure that the Undersecretary of Defense for Acquisition and Sustainment, in collaboration with the military services, develops a strategy that identifies and addresses risks to data quality and information accessibility. At a minimum, this strategy should establish time frames and performance metrics for addressing risks related to (1) unfilled real property positions, (2) a lack of a department-wide approach to improving its data, and (3) implementation of OSD's expanded data platform. (Recommendation 6)

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD partially concurred with this recommendation and stated that it plans to collaborate with the military services on separate service strategies that reflect each military service's operating environment. As of February 2020, DOD officials told us they plan to stabilize their Data Analytics Integration Support (DAIS) platform to improve data inventory by ensuring successful network connectivity for all military service users. DOD will update policy guidance to formalize the use of the DAIS platform for inventory submission by the military services. DOD also will develop and formalize in policy benchmarks and metrics to monitor data accuracy. DOD's estimated completion date for these actions is September 2023. We will continue to monitor the completion of DOD's planned actions.

Recommendation: The Administrator of CMS should provide states with more information on how to fulfill the requirement for independent encounter data audits, including information on the required audit scope and methodology, and what should be described in the resulting report. (Recommendation 1)

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

Comments: HHS agreed with our recommendation, noting that CMS would provide states with additional information on how to fulfill the requirement for independent encounter data audits. HHS also noted in January 2019 that CMS was developing voluntary guidance that will include information on best practices for validating encounter data. To implement this recommendation, the Administrator of CMS should inform states of the required audit scope and methodology as well as the resulting report. As of January 2020, HHS officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: The Administrator of CMS should provide states information on the required content of the annual assessment of encounter data reporting. (Recommendation 2)

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

Comments: HHS agreed with our recommendation, noting that CMS would provide states further information on the required content of the annual assessment. In January 2019, HHS noted that CMS continues to develop guidance to states on how to fulfill the annual assessment requirement. As of January 2020, HHS officials have not informed us of any additional actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: The Administrator of CMS should provide states with information on the circumstances under which CMS would defer or disallow matching funds in response to noncompliant encounter data submissions. (Recommendation 3)

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

Comments: HHS neither agreed nor disagreed with our recommendation and noted steps it has already taken to remind states of their obligation to submit timely, quality encounter data, and prioritize data quality. In January 2019, HHS identified a possible step CMS could take in the event it finds deficiencies in states' encounter data reporting that cannot be resolved through informal monitoring and discussions with state Medicaid agencies. In particular, HHS noted that CMS would issue guidance on the parameters by which the agency would impose financial penalties on states for noncompliant encounter data submissions, if necessary. In February 2020, CMS officials told us that they continue to monitor state encounter data submissions and would issue guidance to states if they identify deficiencies in the data that cannot be resolved through informal monitoring and disccussions with state Medicaid agencies. To implement this recommendation, the Administrator of CMS should provide states with this information. We will update the status of this recommendation when we receive additional information.

Recommendation: The Director of OMB, working with CFOC, should (1) collect data metrics regularly on the Career Roadmap Builder online tool and Grants Training 101 to determine how widely the resources are being used, and (2) obtain periodic feedback from federal agencies on the usefulness of these tools and any needed improvements. (Recommendation 2)

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

Comments: OMB staff provided us with oral comments stating that the agency partially concurred with our recommendations. For our second recommendation, OMB agreed that user feedback data regarding the Career Roadmap Builder and Grants Training 101 is useful. However, OMB stated that while it will continue to collect data on the number of users, it believes that federal agencies should be responsible for collecting specific, detailed user data if they are using those resources. We continue to believe that OMB and CFOC would benefit from collecting specific, detailed user data on these tools, which they devoted time and multiple resources to developing. Collecting detailed data metrics that go beyond the number of users can help OMB and CFOC to better evaluate the effectiveness of these grants training tools. Additionally, OMB stated the agency is committed to working with CFOC to review the Grants Training 101 module to determine how useful it is and if any improvements or adjustments are needed. In May 2019, OMB staff said that no action had been taken to date in response to this recommendation. In January 2020, OMB responded in writing to this recommendation stating that it was continuing to collect data on usage for both training tools on the CFO.gov site. OMB specified, however, that the usage data was for the number of visitors on the two sites and on users by agency. OMB went on to say that each agency is responsible for the professional development of its own workforce, and that Federal agencies can, at their discretion, collect user data if the Roadmap and Grant Training 101 are part of their official training program. In addition, OMB stated it had made the Grants Training 101 available publicly for federal and non-federal personnel on CFO.Gov, and that collecting specific user data is not considered by them to be beneficial to demonstrate the usefulness of the materials. Based on this response, we will continue to inquire as to the availability and use of metrics and effectiveness measures for the Career Roadmap and the Grants Training 101 modules.

Recommendation: The Secretary of HHS should establish a process to monitor and evaluate HHS's grants training at the central office level. This process should include (1) a method for identifying all employees working on grants across the agency, and (2) oversight procedures to evaluate the sufficiency of sub-agencies' grants training efforts including the incorporation of leading practices related to assessing competencies, training approaches, accountability, and training results. (Recommendation 3)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS concurred with our findings and recommendation. In its comment letter, HHS stated that its Office of Grants Policy, Oversight, and Evaluation, within the Office of Grants and Acquisition Policy and Accountability, Division of Grants, in conjunction with the HHS ReInvent Grants Initiative would be developing and implementing a department-wide financial assistance training and certification program to improve the functional effectiveness of the financial assistance management workforce in the areas of internal controls and risk mitigation. The program is designed to support the professional development of the HHS grants management workforce through both instructor-led and online courses. HHS' ReInvent Grants Management (RGM) staff and GAO held a conference call on November 30th, 2018 to discuss how RGM intended to address the recommendation in GAO-18-491 by developing a generalized framework for the Grants Management Training and Certification (GMTC) program for HHS. An HHS official reported that at its December 2019 quarterly meeting, the HHS Division of Workforce Development (DWD) reported they had in the past quarter: briefed the HHS Executive Committee on Grants Administration Policy (ECGAP) on the DWD mission and goals for training the grants workforce; developed briefing documents and presentations based on a RGM developed framework to develop competencies and outline curriculum of the GMTC program; continued to review and refine the program framework to incorporate DWD mission and goals; drafted the initial policy to further inform the structure and procedures of the GMTC program (e.g. certification levels, required coursework, career development requirements), which should be issued by HHS Office of Grants within Federal Fiscal Year 2020; and collaborated with the HHS Grants Closeout Business Process Reengineering Team to discuss current grants closeout status and how DWD can support grant staff and grant recipient closeout training efforts. Given the ongoing nature of HHS efforts, GAO will continue to monitor progress on a quarterly basis.

Recommendation: As MHS governing bodies conduct their recurring reviews of quality measures selected for MHS's Core Dashboard and Purchased Care Dashboards, the Assistant Secretary of Defense for Health Affairs should direct those bodies to prioritize, as appropriate, the selection of measures that apply to both direct and purchased care at the provider level and that expand the range of quality measure types and medical conditions that are assessed. (Recommendation 1)

Agency: Department of Defense: Office of the Assistant Secretary of Defense (Health Affairs)
Status: Open

Comments: As of January 2020, DOD officials described proposed actions to address key elements of our recommendation. Specifically, DOD officials described compiling a comprehensive library of existing inpatient and outpatient quality measures for both direct and purchased care; categorizing those measures by type and medical condition; and identifying 8 measures that are common across direct and purchased care. DOD stated it is considering expanding those 8 common measures to 12 measures. The new measures would cover three cancer screening measures and an additional inpatient satisfaction measure. However, DOD officials noted these 12 measures are not reported at the provider level for purchased care given current contract reporting requirements and would require contract modifications. DOD officials also said they are participating in an interagency partnership to use a common set of quality measures across federal programs, including under the Department of Veterans Affairs. Once those quality measures are determined, DOD may expand the range of quality measures common across direct and purchased care to be consistent with other federal programs. We will keep this recommendation open until DOD provides additional information on actions taken to select and expand quality measures across direct and purchased care.

Recommendation: The Assistant Secretary of Defense for Health Affairs should establish, as appropriate, performance standards related to the Purchased Care Dashboard measures that are consistent with the MHS's performance standards for direct care; ensure they are applied to individual purchased care providers; and take steps, such as amending its managed care support contracts, if necessary, to require corrective actions to be taken when providers do not meet those standards. (Recommendation 2)

Agency: Department of Defense: Office of the Assistant Secretary of Defense (Health Affairs)
Status: Open

Comments: As of January 2020, DOD officials said that once a common set of quality measures is adopted to the extent possible across direct and purchased care (as discussed in Recommendation 1), DOD plans to establish consistent performance standards applied to individual providers and plans to develop processes to issue corrective actions for individual direct and purchased care providers who do not consistently meet established standards. We will update this recommendation as DOD provides progress updates on the implementation of these plans.

Recommendation: The Assistant Secretary of DOL's Employment and Training Administration should provide states with information about its determination that the use of state formal warning policies is no longer permissible under federal law. (Recommendation 1)

Agency: Department of Labor
Status: Open
Priority recommendation

Comments: DOL agreed with this recommendation. The agency stated that it would take action to provide states with information about its determination that the use of state formal warning policies is no longer permissible under federal law. As of December 2019, DOL reported that it is developing new guidance that states can no longer use formal warnings. We will consider closing this recommendation when the agency completes this effort.

Recommendation: The Assistant Secretary of DOL's Employment and Training Administration should monitor states' efforts to discontinue the use of formal warning policies. (Recommendation 2)

Agency: Department of Labor
Status: Open

Comments: DOL agreed with this recommendation and stated that it would monitor states' efforts to discontinue the use of formal warning policies. In December 2019, DOL reported that it has been developing new guidance that more explicitly informs states that formal warning policies are not permissible. We will consider closing this recommendation when the agency completes this effort and monitors states' compliance with the guidance.

Recommendation: The Assistant Secretary of DOL's Employment and Training Administration should clarify information on work search verification requirements in its revised Benefit Accuracy Measurement procedures. The revised procedures should include an explanation of what DOL considers to be sufficient verification of claimants' work search activities. (Recommendation 3)

Agency: Department of Labor
Status: Open
Priority recommendation

Comments: DOL agreed with this recommendation and stated that it would clarify information on work search verification requirements in its revised Benefit Accuracy Measurement procedures. In December 2019, DOL reported that it is developing new guidance with instructions to clarify work search verification requirements. To fully implement this recommendation, DOL should finalize and publish these instructions on verifying claimants' work search activities and provide the clear directions to states.

Recommendation: The Assistant Secretary of DOL's Employment and Training Administration should monitor states' compliance with the clarified work search verification requirements. (Recommendation 4)

Agency: Department of Labor
Status: Open

Comments: DOL agreed with this recommendation and stated that it would monitor states' compliance with clarified work search verification requirements. In December 2019, DOL reported that it is working with the Office of Management and Budget on its draft work search guidance that will more explicitly inform states that formal warning policies are not permissible. We will close this recommendation when DOL publishes these instructions, providing states with clear directions, and monitors their compliance with the guidance.

Recommendation: The Secretary of the Interior should notify all participating entities to ensure they are aware of the Interim Federal Action Plan and their role in it. (Recommendation 2)

Agency: Department of the Interior
Status: Open

Comments: The 2020 OMB Crosscut Budget states that the implementation of the Delta Plan has been conducted by the Delta Plan Interagency Implementation Committee, which was created in 2013, and includes participation and leadership from federal agencies at the regional and DC headquarters levels. It also states that the Council is primarily responsible for coordinating federal activities in the Delta. This language clarifies the role of federal agencies in relation to the Council and the Delta Plan, as we recommended. However, in December 2019, Bureau of Reclamation officials stated that they were not aware of any communication of federal agencies' role. We will continue to monitor this recommendation.

Recommendation: The Chair of CEQ should notify all participating entities to ensure they are aware of the Interim Federal Action Plan and their role in it. (Recommendation 4)

Agency: Executive Office of the President: Council on Environmental Quality
Status: Open

Comments: The 2020 OMB Crosscut Budget states that the implementation of the Delta Plan has been conducted by the Delta Plan Interagency Implementation Committee, which was created in 2013, and includes participation and leadership from federal agencies at the regional and DC headquarters levels. It also states that the Council is primarily responsible for coordinating federal activities in the Delta. This language clarifies the role of federal agencies in relation to the Council and the Delta Plan, as we recommended. However as of January 2020, CEQ officials had not provided an update on this recommendation, although Bureau of Reclamation officials stated that they were not aware of any communication of federal agencies' role. We will continue to monitor this recommendation.

Recommendation: The Secretary of the Interior should coordinate with appropriate state entities to obtain and report the information available to meet the requirements under section 105 of the Calfed Bay-Delta Authorization Act (CALFED Act). (Recommendation 5)

Agency: Department of the Interior
Status: Open

Comments: In October 2019, Interior reported that the California Delta Stewardship Council (a state agency) had met twice and asked Reclamation to develop a template on financial detail for the Science Tracker, the Council's web-based tracking system. The Council compiles and reports on funding information and progress for federal and state agencies. The template will be used by a subgroup of agencies to collect their 2019 expenditures and this will be put into the Science Tracker in preparation for a February 15, 2020 reporting date. The subgroup is working on establishing common accounting and reporting protocols, supporting web-based tracking, and coordinating a review of science in the Delta.

Recommendation: The Director of OMB should coordinate with appropriate state entities to obtain and report the information available to meet the requirements under section 106 of the CALFED Act. (Recommendation 6)

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

Comments: As of January 2020, OMB staff did not provide an update. When we confirm what actions the agency has taken, we will provide updated information.

Recommendation: The Director of OMB should direct staff to update OMB's written guidance for federal and state agencies on submitting data for the budget crosscut reports OMB is required to submit under section 106 of the CALFED Act. (Recommendation 7)

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

Comments: As of January 2020, OMB staff had not provided an update on this recommendation. When we confirm what actions the agency has taken, we will provide updated information.

Recommendation: The Secretary of Defense ensures that the Offices of the Under Secretary of Defense for Personnel and Readiness and Under Secretary of Defense for Acquisition and Sustainment in coordination with the Secretaries of the Army, Navy, and Air Force take interim steps to help ensure that standardized aviation mishap data elements are collected by the safety centers. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to a corrective action plan that DOD updated in July 2020, the department has taken some steps to implement this recommendation. According to the plan, DOD is developing standards for mishap data through the Safety and Information Management Working Group and is making progress towards finalizing mishap data element standards. DOD's internal tracking indicates that the draft business process model has been completed, but standardizing the DOD data elements is a work in-progress. DOD's estimated completion date for this effort is June 2021. Completing these actions would allow the military services' safety centers to collect relevant training-related data as part of the update of aviation mishap data elements, as GAO recommended in August 2018.

Recommendation: The Secretary of Defense ensures that the Offices of the Under Secretary of Defense for Personnel and Readiness and Under Secretary of Defense for Acquisition and Sustainment in coordination with the Secretaries of the Army, Navy, and Air Force update department-wide and service instructions and policies to clarify the responsibility of the Office of the Secretary of Defense for conducting analysis and its access to the military services' information on human factors that contributed to aviation mishaps. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to a corrective action plan that DOD updated in July 2020, the department has taken some steps to implement this recommendation. According to the plan, DOD is revising DOD Instruction 6055.07, which will clarify the department's policy that it is the responsibility of the Office of the Secretary of Defense for conducting analysis and its access to the military services' information on human factors that contributed to aviation mishaps. DOD's estimated completion date for this effort is July 2021. Completing this action would clarify the Office of the Secretary of Defense's role for conducting analyses and access to the military services' safety centers' data on aviation mishaps, as GAO recommended in August 2018.

Recommendation: The Secretary of Defense ensures that the DOD Chief Management Officer in coordination with the offices of the Under Secretary of Defense for Personnel and Readiness and Under Secretary of Defense for Acquisition and Sustainment and the Secretaries of the Army, Navy, and Air Force identify relevant training-related data to collect as part of any update of the aviation mishap data elements and incorporate these data into future analyses. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. According to a corrective action plan that DOD updated in July 2020, the department has taken some steps to implement this recommendation. According to the plan, DOD is developing standards for mishap data through the Safety and Information Management Working Group and is making progress towards finalizing mishap data element standards. DOD's internal tracking indicates that the draft business process model has been completed, but standardizing the DOD data elements is a work in-progress. DOD's estimated completion date for this effort is June 2021. Completing these actions would allow the military services' safety centers to collect relevant training-related data as part of the update of aviation mishap data elements, as GAO recommended in August 2018.

Recommendation: The Under Secretary of Health should ensure all RME inspections are being conducted and reported as required and that the inspection results VHA has are complete. (Recommendation 1)

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

Comments: VA agreed with this recommendation and indicated it would establish an oversight process for reviewing and monitoring findings from inspections. VA has described some of the oversight actions it has put in place and noted that actions would be completed in 2020. We will update the status of this recommendation when additional information is received.

Recommendation: The Under Secretary of Health should examine the Sterile Processing Services workforce needs and take action based on this assessment, as appropriate. (Recommendation 3)

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

Comments: VA agreed with this recommendation and indicated it would review workforce needs and take necessary actions. VA has described some of the actions taken and noted that actions would be completed in 2019. We will update the status of this recommendation when additional information is received.

Recommendation: The Secretary of Defense should ensure that the Navy provides additional information in the annual President's budget exhibits associated with CVN 65 dismantlement and disposal to facilitate improved transparency and accountability. Additions should, at a minimum, include the CVN 65 funding estimate across the Future Years Defense Program, activities planned or performed for applicable fiscal years, tracking of total cost and high level changes in cost and schedule from the prior year with explanations for changes, and if applicable, contract type, awardee, award value, and award and completion date estimates. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense agreed with this recommendation, stating that the Navy would develop and submit additional cost, schedule, and contract information to supplement existing budget exhibits and continue this reporting through completion of the CVN 65 dismantlement and disposal. Congress subsequently addressed our recommendation to the department as part of the Fiscal Year 2019 National Defense Authorization Act enacted on August 13, 2018. Specifically, the act requires the Secretary of the Navy to include information on each dismantlement and disposal of a nuclear-powered aircraft carrier occurring or planned to occur during the period of the future years defense program submitted to Congress with that budget. For each ship, this includes (1) a summary of activities and significant developments in connection with the dismantlement and disposal; (2) a detailed description of cost and schedule performance against the baseline for the dismantlement and disposal, including a description of and explanation for any variance from such baseline; and (3) a description of the funding amounts requested, or expected to be requested, for the dismantlement and disposal for prior, current, and future fiscal years. In August 2020, a Naval Reactors official stated that the draft environmental impact statement (EIS) for the carrier disposal will be published in the summer of 2021. The final EIS is planned for fall 2022 with an accompanying record of decision announcing the Navy's intended course of action for CVN 65 dismantlement and disposal. The official also confirmed that the Navy anticipates developing a schedule of work and requesting funding for CVN 65 dismantlement and disposal plans in 2023 if the commercial dismantlement option is selected. If the Navy elects to have the dismantlement performed by the government, these activities will occur at a later date. We will continue to monitor the Navy's activities in order to document any action taken to implement this recommendation.

Recommendation: The Secretary of Defense should require the Navy to obtain an independent cost estimate, performed by DOD's Office of Cost Analysis and Program Evaluation or the Naval Center for Cost Analysis, for both the naval shipyard and full commercial options before choosing a dismantlement and disposal approach for CVN 65. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense agreed with this recommendation and stated that the Navy would obtain independent cost estimates through the Office of Cost Analysis and Program Evaluation (CAPE) for both the naval shipyard and full commercial CVN 65 dismantlement and disposal options before a final decision is made on which option the Navy will pursue. In August 2020, a Naval Reactors official stated that the draft environmental impact statement (EIS) for the carrier disposal will be published in the summer of 2021. The final EIS is planned for fall 2022 with an accompanying record of decision announcing the Navy's intended course of action for CVN 65 dismantlement and disposal. The official also said the Navy is working directly with the Center for Naval Analyses, Puget Sound Naval Shipyard, and CAPE to gather and review independent cost estimates for commercial dismantlement and updated naval shipyard cost estimates. The commercial and naval shipyard estimates will be reviewed and assessed by CAPE prior to the Navy making a decision on which option to pursue. CAPE's written report assessing the commercial and naval shipyard estimates is expected to combine with the ongoing EIS to directly inform the Navy's decision for CVN 65. We will continue to monitor the status of independent cost estimate activities for CVN 65 until the estimates have been completed.

Recommendation: The Secretary of Defense should require the Navy to complete a risk management plan prior to beginning the CVN 65 dismantlement and disposal. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense agreed with this recommendation and stated that the Navy would prepare a risk management plan for the CVN 65 dismantlement and disposal before the award of a contract or the provision of funds. In August 2020, a Naval Reactors official stated that the draft environmental impact statement (EIS) for the carrier disposal will be published in the summer of 2021. The final EIS is planned for fall 2022 with an accompanying record of decision announcing the Navy's intended course of action for CVN 65 dismantlement and disposal. The official also confirmed that if the Navy selects the commercial dismantlement option for CVN 65, the Navy anticipates identifying potential risks and mitigations in February 2021 for CVN 65 dismantling to support independent cost estimate development, with risk management plan approval to follow in July 2022. If the Navy elects to have the dismantlement performed by the government, these activities will occur at a later date. We will continue to monitor the Navy's efforts to complete a risk management plan as the department works toward a decision for the CVN 65 dismantlement and disposal.

Recommendation: The Secretary of Defense should require the Navy to approve a cost and schedule baseline prior to beginning the CVN 65 dismantlement and disposal. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense agreed with this recommendation and stated that the Navy would prepare and approve a cost and schedule baseline for the CVN 65 dismantlement and disposal before the award of any contract or the provision of funds for the effort. Congress subsequently addressed our recommendation to the department on August 13, 2018, as part of the Fiscal Year 2019 National Defense Authorization Act. Specifically, the act requires the Secretary of the Navy to provide a report to the congressional defense committees that provides a cost and schedule baseline for the dismantlement and disposal of nuclear powered aircraft carriers approved by Navy leadership. In August 2020, a Naval Reactors official stated that the draft environmental impact statement (EIS) for the carrier disposal will be published in the summer of 2021. The final EIS is planned for fall 2022 with an accompanying record of decision announcing the Navy's intended course of action for CVN 65 dismantlement and disposal. The official also confirmed that the Navy anticipates developing a cost and schedule baseline for CVN 65 dismantlement and disposal in 2022 if the commercial dismantlement option is selected. If the Navy elects to have the dismantlement performed by the government, these activities will occur at a later date. We will continue to monitor the Navy's activities in order to document any action taken to implement this recommendation.

Recommendation: FTA should determine which on-demand services qualify as "public transportation" based on the statutory definition and disseminate information to clarify whether and how to report data from such services into the National Transit Database (NTD). (Recommendation 2)

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

Comments: DOT concurred with this recommendation. As of September 2018, FTA planned to implement it by updating its NTD manual to include a new data collection field for on-demand services provided by Transportation Network Companies (TNC) in order to track these separately from other types of on-demand services. FTA will post a proposed update to clarify whether and how to report TNC-provided services into the NTD. FTA plans to post the proposed revisions along with specifications for which on-demand services qualify as "Public transportation" to the NTD policy in the Federal Register for comment. As of May 2020, FTA anticipated completing these actions by November 30, 2020.

Recommendation: The Secretary of the Treasury should include in Treasury's fiscal year 2018 AFR information about all civil monetary penalties within its jurisdiction, including the inflation adjustment of the civil monetary penalties. (Recommendation 5)

Agency: Department of the Treasury
Status: Open

Comments: In November 2018, Treasury issued its fiscal year 2018 agency financial report and included information about all civil monetary penalties within its jurisdiction. However, it did not adjust two civil monetary penalty amounts for inflation and indicated that it planned to complete the regulations to adjust these two amounts for inflation by the end of 2018. In November 2019, Treasury issued its fiscal year 2019 agency financial report and included information about all civil monetary penalties within its jurisdiction. However, it did not adjust one of the two civil monetary penalty amounts for inflation in our finding. As of June 2020, Treasury has not taken the necessary corrective actions to completely address this recommendation.

Recommendation: The Director, working with the Study, should ensure that as the Study finalizes its reporting format, it fully incorporates leading practices of performance reporting. (Recommendation 1)

Agency: Environmental Protection Agency
Status: Open

Comments: In June 2020, the Long Island Sound Study (Study) stated that it has incorporated two leading practices into the reporting format for its progress reports. In addition, the Study website shows the progress toward ecosystem targets compared to the recovery plan, and for a preceding period of time when data are available. According to the Study, EPA hired a contractor to develop a report addressing our recommendations. The Study is using the contractor report to finalize its reporting format and plans to develop an online reporting and tracking system that fully incorporates leading practices of performance reporting. We will review the format of the online tracking system when it becomes available and provide updated information as appropriate.

Recommendation: The Director, working with the Study, should develop cost estimates that include analyses of uncertainties for each of the targets in the 2015 plan. (Recommendation 2)

Agency: Environmental Protection Agency
Status: Open

Comments: In June 2020, the Study reported that it had hired a contractor to develop a report including the range of costs, including uncertainty bounds, needed to attain each of the targets in the 2015 plan. The contractor has completed its study. Cost estimates for each ecosystem target were developed by adding up the existing cost ranges for each of the implementation actions in the 2015 plan. The report is posted and accessible to the public on the Long Island Sound Study website (https://longislandsoundstudy.net/2019/11/addressing-gaos-recommendations-liss-performance-reporting-and-cost-estimating/). The report contains recommendations for the Study to continue estimating costs in future reports. We are following up with EPA to determine whether the Study will do this.

Recommendation: The Director, working with the Study, should estimate the range of potential costs for all implementation actions and include the estimates in future supplements to the 2015 plan. (Recommendation 3)

Agency: Environmental Protection Agency
Status: Open

Comments: In June 2020, the Study said that as part of the Plan 2020-2024 implementation action update, it will include a range of costs for implementation actions. We will review the supplemental documents when they are available and provide updated information as appropriate.

Recommendation: The Director of HUD's Lead Office should ensure that the office more fully documents its processes for scoring and awarding lead grants and its rationale for award decisions. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open

Comments: As of November 2019, HUD's Lead Office had taken steps to implement this recommendation. For example, they updated the 2018 Application Review Guide with some criteria that could be used to score grant applications. However, the 2019 Application Review Guide did not contain similar criteria. To fully implement this recommendation, the agency will need to follow through and adopt criteria to score grant applications on a consistent basis.

Recommendation: The Director of HUD's Lead Office should ensure that the office periodically evaluates its processes for scoring and awarding lead grants. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: As of November 2019, HUD's Lead Office began to take steps to implement this recommendation. For example, in the upcoming weeks and months, the Lead Office staff plan to meet to review the most recent round of grant applications and determine whether any changes need to be made to the scoring criteria for future years. To fully implement this recommendation, HUD's Lead Office staff will need to provide evidence the office is periodically evaluating and changing processes to score and award grants, as appropriate.

Recommendation: The Director of HUD's Lead Office and the Assistant Secretary for the Office of Public and Indian Housing (PIH) should collaborate to establish a plan to mitigate and address risks within HUD's lead paint compliance monitoring processes. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: As of November 2019, HUD officials told us the agency had taken steps to implement the recommendation, including requiring PHAs to submit appropriate documentation regarding public housing units' compliance with lead paint regulations and updating an internal checklist for on-site compliance reviews that HUD staff conduct. We will continue to monitor HUD's progress in response to our recommendation.

Recommendation: The Director of HUD's Lead Office and the Assistant Secretary for PIH should collaborate to develop and document procedures to ensure that HUD staff take consistent and timely steps to address issues of public housing agency noncompliance with lead paint regulations. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: As of November 2019, HUD officials told us procedures were in draft form and under internal review and were not expected to be finalized until spring 2020.

Recommendation: The Secretary of HUD should request authority from Congress to amend the inspection standard to identify lead paint hazards in the Housing Choice Voucher program as indicated by analysis of health effects for children, the impact on landlord participation in the program, and other relevant factors. (Recommendation 6)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In response to this recommendation, HUD's fiscal year 2021 budget justification requested funds to test an alternative lead paint testing method in HUD's Housing Choice Voucher program. To fully implement our recommendation, HUD needs to continue to take steps to analyze potential effects of alternative lead paint testing methods, and use the results to inform its decisions about requesting new authority from Congress.

Recommendation: The Director of the Lead Office should develop performance goals and measures to cover the full range of HUD's lead efforts, including its efforts to ensure that housing units in its rental assistance programs are lead-safe. (Recommendation 7)

Agency: Department of Housing and Urban Development
Status: Open

Comments: As of November 2019, HUD officials told us they still were exploring whether current data systems could be used to count the number of lead-safe housing units in HUD's rental assistance programs. We will continue to monitor HUD's effort to implement this recommendation.

Recommendation: The Director of the Lead Office, in conjunction with PD&R, should finalize plans and develop a time frame for evaluating the effectiveness of the Lead Safe Housing and Lead Disclosure Rules, including an evaluation of the long-term cost effectiveness of the lead remediation methods required by the Lead Safe Housing Rule. (Recommendation 8)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In November 2019, HUD officials told us they planned to use data from the forthcoming update to the American Healthy Homes Survey to better estimate the prevalence of lead paint hazards in federally assisted housing which would provide an indication of the effectiveness of the lead paint rules. However, officials told us the findings from the updated survey likely would not be available until summer 2020.

Recommendation: The Director of the Lead Office should complete statutory reporting requirements, including but not limited to its efforts to make housing lead-safe through its lead grant programs and rental-assistance programs, and make the report publicly available. (Recommendation 9)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In November 2019, HUD officials told us they planned to issue a report to Congress on the agency's lead efforts in early 2020.

Recommendation: The Under Secretary of Defense for Research and Engineering should ensure that the Director, MDA revises MDA policies to require that all integrated capabilities--capabilities that require integration of two or more elements--be included in a Technical Capability Declaration. (Recommendation 1)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: DOD partially concurred with this recommendation. While DOD agreed with the intent of this recommendation, DOD stated that the MDA Director will determine which major integrated capabilities should be delivered via the Technical Capability Declaration (TCD) process. MDA also noted that it is updating MDA Directive 5000.17 (estimated release in 4Q FY2020), which is intended to address this recommendation. GAO will assess the revisions when they are available. We continue to believe that in order for the agency to meet the full intent of our recommendation, it should establish in policy, a clear, definitive standard for which capabilities require a TCD delivery.

Recommendation: The Under Secretary of Defense for Research and Engineering should ensure that the Director, MDA clarifies, in written policy, the exact requirements, process, and key milestones necessary to issue a Technical Capability Declaration, including a requirement that the Assessment Requirements Review be held in such a time frame that it can provide meaningful input to MDA's test plans. (Recommendation 2)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: DOD concurred with this recommendation and contends that its new Policy Memorandum 90 meets the intent of our recommendation. However, this new Policy Memorandum leaves open the possibility of continued inconsistent application of the Technical Capability Declaration (TCD) process. In order for the agency to meet the full intent of our recommendation, MDA should establish in policy, a clear, definitive standard for which capabilities require a TCD for delivery that should be tracked over several years to ensure that the policy is followed. MDA officials noted that revisions to MDA Directive 5000.17 expected at the end of Fiscal Year 2020 will address the recommendation. We will assess the new parameters set out in the revised policy directive, when it is available. We will also continue to track how MDA implements any new policies on TCDs and whether the information is transparent.

Recommendation: The Under Secretary of Defense for Research and Engineering should ensure that the Director, MDA includes information on current undefinitized contract actions in the BMDS Accountability Report, including the not-to-exceed price, the definitization schedule, the amount of funds obligated for the undefinitized period, and any changes since the contract action was entered into. (Recommendation 3)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: DOD concurred with this recommendation and has taken steps to implement it. While we noted in our report that the BMDS Accountability Report for 2018, approved by the MDA Director on March 9, 2018 reflected that the agency had taken steps to implement this recommendation, we plan to leave this recommendation open to ensure that the BMDS Accountability Report accurately contains all undefinitized contract actions that the agency enters into through the fiscal year and whether the reporting contains the information necessary to satisfy our recommendation.

Recommendation: The Under Secretary of Defense for Research and Engineering should ensure that the Director, MDA, ensures that models used for operational tests are validated and accredited for such assessments. To help achieve this, MDA should provide the BMDS Operational Test Agency all evidence previously agreed to and needed to accredit models before ground testing events, as specified in the BMDS OTA accreditation plan. (Recommendation 4)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: DOD concurred with this recommendation and stated that MDA is actively working with the BMDS Operational Test Agency (BMDS OTA) to resolve any issues associated with, and the reporting of, modeling limitations. However, according to BMDS OTA officials, while the number of accredited models has risen in recent years, some remain unaccredited. We, therefore, believe it is premature to closeout this recommendation but we will continue to track MDA's progress on taking the necessary steps to implement this recommendation.

Recommendation: The Under Secretary of Defense for Research and Engineering should ensure that the Director, MDA includes in capability delivery packages, such as the Technical Capability Declaration memos and Operational Capability Baseline change packages, the following: a. The verification, validation, and accreditation status of the models used in operational ground tests; and b. Modeling and simulation limitations that affect operational ground test results. (Recommendation 5)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: DOD concurred with this recommendation and stated that MDA has made significant progress over the last year in these efforts. MDA will provide the Technical Capability Declaration (TCD) and Operational Capability Baseline (OCB) packages for us to assess. Until we are able to do so, we believe it is premature to closeout this recommendation. We will continue to monitor MDA's progress in taking the necessary steps.

Recommendation: The Under Secretary of Defense for Research and Engineering should ensure that the Director, MDA and the Secretaries of the Armed Services responsible for operating BMDS elements develop written agreements as soon as feasible for modeling and simulations technical and funding requirements for any BMDS elements that are service-operated but represented in BMDS performance assessments. (Recommendation 6)

Agency: Department of Defense: Office of the Under Secretary of Defense for Research and Engineering
Status: Open

Comments: DOD concurred with this recommendation and are taking steps to implement this recommendation. We will continue to monitor the efforts necessary including finalizing and executing written agreements between MDA and any BMDS elements that are Service-operated but represented in BMDS performance assessments.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment revises its guidance on privatized military housing to include a requirement that the military departments incorporate measures of future sustainment into their assessments of privatized housing projects. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report. In its response, the department stated that it was working with the military departments to determine appropriate measures of future sustainment and would revise its guidance to require the military departments to incorporate measures of future sustainment into their assessments of privatized housing projects. In May 2019, an official from the Office of the Assistant Secretary of Defense for Sustainment stated that DOD anticipates being able to issue this guidance sometime in calendar year 2019.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment takes steps to resume issuing required reports to Congress on the financial condition of privatized housing in a timely manner. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report and stated that it was working to further streamline the reporting format and data collection process to ensure more timely reporting to Congress. Subsequently, in September 2018 DOD issued its report to Congress on the financial condition of privatized housing covering fiscal years 2015 and 2016, and in May 2019 DOD issued the report covering fiscal year 2017. An official from the Office of the Assistant Secretary of Defense for Sustainment noted in May 2019 that the next report will cover updated reporting requirements from the National Defense Authorization Act for Fiscal Year 2019. The official said that DOD was in the process of reviewing its schedule to determine when it will be able to submit the report covering fiscal year 2018, with the expectation that the submission will be made in December 2019 or no later than March 2020. The official added that collection, reconciliation, and coordination of the information in the report remains the biggest challenge to timely submittal, as well as other privatized housing-related work requirements. Because it is unclear whether future reports reflecting the updated reporting requirements will be submitted in a timely manner, we will continue to monitor DOD's response to this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment reports financial information on future sustainment of each privatized housing project in its reports to Congress. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report and stated that it would ensure that financial information on future sustainment of each privatized housing project would be included in the report to Congress on privatized housing covering fiscal year 2017. However, the report covering fiscal year 2017 was issued in May 2019 and did not include financial information on the future sustainment of each privatized housing project. We will continue to monitor any actions DOD takes to implement this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment provides guidance directing the military departments to assess the significance of the specific risks to individual privatized housing projects resulting from the reductions in the basic allowance for housing and identify courses of action to respond to any risks based on their significance. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report. In its response, the department stated that it would issue guidance to the military departments to annually report on their assessment of the specific risk of changes in the basic allowance for housing to individual privatized housing projects and identify any courses of action to respond to the risks based on their significance. In May 2019, an official from the Office of the Assistant Secretary of Defense for Sustainment stated that DOD anticipates being able to issue this guidance sometime in calendar year 2019.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment finalizes guidance in a timely manner that clearly defines the circumstances in which the military departments should provide notification of project changes and which types of project changes require prior notification or prior approval. (Recommendation 7)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report. In its response, the department stated that DOD has coordinated draft guidance with the military departments which it expected to issue in fiscal year 2018. However, in May 2019, an official from the Office of the Assistant Secretary of Defense for Sustainment stated that the guidance has been delayed due to other pressing requirements and DOD now anticipates being able to issue this guidance sometime in calendar year 2019.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Energy, Installations, and Environment revises its guidance on privatized military housing to require the military departments to define their risk tolerances regarding the future sustainability of their privatized housing projects. (Recommendation 8)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its response to our report. In its response, the department stated that it would revise its privatized housing guidance to require the military departments to define their risk tolerances regarding future sustainability of privatized housing projects. In May 2019, an official from the Office of the Assistant Secretary of Defense for Sustainment stated that DOD anticipates being able to issue this guidance sometime in calendar year 2019.

Recommendation: Congress should consider legislation modifying the Internal Revenue Code to allow routine account transfers within the same foreign workplace retirement plan or between two foreign workplace retirement plans in the same country to be free from U.S. tax in countries covered by an existing income tax treaty that provides for favorable U.S. tax treatment of foreign workplace retirement plan contributions.

Agency: Congress
Status: Open

Comments: We will monitor congressional action related to this matter.

Recommendation: The Secretary of Labor should issue guidance on the obligations under the Employee Retirement Income Security Act of 1974 of sponsors of ongoing plans to prevent, search for, and pay costs associated with locating missing participants. (Recommendation 1)

Agency: Department of Labor
Status: Open

Comments: Labor agreed with this recommendation. In June 2019, the Department reported that it engaged with a range of stakeholders on issues surrounding missing and unresponsive participants, including representatives of plans, employers, financial services groups, consumer groups, and state unclaimed property funds. Their goal is to help plans locate and pay retirement benefits to missing participants and beneficiaries; they will evaluate constructive guidance to issue. There is no specific timeline for next steps regarding subregulatory guidance or regulatory proposals. GAO will monitor the agency's progress in implementing this recommendation.

Recommendation: The IRS Commissioner should review taxation issues relating to distributions involving incorrect participant addresses and uncashed benefit checks and clarify for the public the Internal Revenue Code's requirements in these circumstances. (Recommendation 2)

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

Comments: IRS agreed to review taxation issues relating to distributions involving incorrect participant addresses and uncashed benefit checks and to clarify for the public the Internal Revenue Code's requirements in these circumstances. We will consider closing this recommendation when the agency provides evidence that it completed these efforts.

Recommendation: The IRS Commissioner should consider revising the letter forwarding program in a cost-effective manner to again provide information on behalf of plan sponsors on unclaimed retirement accounts to participants. (Recommendation 3)

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

Comments: IRS disagreed with this recommendation, noting that the IRS address of record for a participant would likely be of no greater value than addresses available through alternatives such as commercial locator services. However, our report does not cite the accuracy of IRS addresses, but rather other benefits that make a program revision worth considering, specifically the likelihood that individuals will open IRS correspondence, and the trust DOL places in the service as way for plan fiduciaries to meet their obligations. IRS also stated that the limited number of IRS staff and resources impact the feasibility of reinstating this program for plan participants. We continue to believe that expanding the letter forwarding program would be beneficial, and we encourage IRS to consider cost-effective ways to do so.

Recommendation: The IRS Commissioner should clarify how U.S. individuals are to report their foreign retirement accounts. The clarification could include addressing how these accounts should be designated and how the taxpayer should report contributions, earnings, and distributions made from the account. (Recommendation 4)

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

Comments: IRS agreed with this recommendation. We encourage IRS to take the necessary steps to dispel any confusion U.S. individuals may have over how to properly classify and report their foreign retirement accounts on a U.S. tax return-such clarification should help ensure that these taxpayers can meet their tax reporting obligations.

Recommendation: The IRS Commissioner should systematically analyze data reported through Form 8938 filings on foreign retirement accounts owned by U.S. individuals with the goal of developing an evidence-based understanding of how these accounts change over time and what level of risk these accounts pose for tax evasion. To assist with this analysis, IRS should consider revising Form 8938 to more clearly distinguish between retirement accounts and other types of accounts or assets being reported by taxpayers under current reporting requirements. (Recommendation 5)

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

Comments: IRS disagreed with this recommendation but not on its merits, citing a lack of resources to implement it. Specifically, IRS noted that although the modification to the Form 8938 suggested in this recommendation may seem minor, systemically collecting and analyzing the data would require resources beyond those currently available to IRS. However, our report notes that IRS indicated that they already collect foreign account filing data through the Form 8938 and that the current reporting requirements help the agency to "keep a line of sight" on U.S. individuals' foreign pension arrangements. IRS told us that without such data being reported, U.S. individuals with foreign retirement accounts may seek to avoid proper reporting on their tax returns when distributions are made. However, without agreeing to take steps to analyze these data reported by taxpayers, the question remains why the agency continues to collect such information-which we show in the report to present a substantial reporting burden on taxpayers-if the agency has no plan to analyze the data in order to make an informed decision about the risk for tax evasion that such accounts present. It is also unclear how IRS would maintain a line of sight on foreign retirement accounts belonging to U.S. individuals without analyzing the data reported by taxpayers on such accounts. We recognize that resources are limited. When staff and resources become available, IRS should modify the form and conduct a systematic analysis of these data-data that current law requires taxpayers to report-in order to assess the risk of tax evasion that foreign retirement accounts pose. Such an analysis can provide a basis to reach an evidence-based understanding of how these accounts change over time and what level of risk they pose for tax evasion, and U.S. individuals owning foreign retirement accounts will continue to face these substantial reporting burdens without the knowledge that the data they are required to provide will be put to good use by the federal government.

Recommendation: The IRS Commissioner should take steps to improve the likelihood that the Notice of Potential Private Pension Benefit Information corresponds to actual retirement benefits in the future, for example, by working with the Social Security Administration as necessary. (Recommendation 6)

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

Comments: IRS agreed with this recommendation. The agency indicated it would work to improve the likelihood that the Notice of Potential Private Pension Benefit Information corresponds to actual retirement benefits in the future, and agreed to take steps to ensure that the data reported on Form 8955-SSA are accurate and to advise plan sponsors of any changes to reporting these data.

Recommendation: The Social Security Administration Commissioner should take steps to improve the likelihood that the Notice of Potential Private Pension Benefit Information corresponds to actual retirement benefits in the future, for example, by working with IRS as necessary. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: SSA agreed with this recommendation. In November 2019, SSA stated that the agency is meeting with the IRS regularly to discuss Form 8955-SSA, which provides the basis for the information shown in the "Potential Private Retirement Benefit Information" notice. The IRS agreed to incorporate SSA's suggestion to update Form 8955-SSA to explain that the filer should include the individual pension plan participant's full social security number (SSN) on the form. SSA reported that it is working with the IRS to clarify coding instructions for Form 8955-SSA and institute a new edit to its paper processing to ensure accuracy. They are also considering potential data exchanges with filers. We will monitor the agency's progress in completing these tasks.

Recommendation: The Assistant Secretary for the Office of Public and Indian Housing (PIH) should complete workforce planning for the MTW demonstration to help ensure that PIH has sufficient staff with appropriate skills and competencies to manage an expanded demonstration, including reviewing reports and carrying out compliance reviews in a timely manner. (Recommendation 1)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that PIH was continuing its workforce planning efforts, including assessing the knowledge, skills, and abilities needed to implement the MTW expansion.

Recommendation: The Assistant Secretary for PIH should more fully document the process for annually assessing compliance with the five demonstration requirements. (Recommendation 2)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they had drafted written protocols for assessing compliance with the five demonstration requirements that would be finalized by May 2019.

Recommendation: The Assistant Secretary for PIH should develop and implement a process to track how MTW demonstration funds are being used for other allowable activities, including local, nontraditional activities. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that they were still determining the most cost effective way to track MTW demonstration funds being used for local, nontraditional activities.

Recommendation: The Assistant Secretary for PIH should identify and implement changes to PIC to capture household data for households served through local, nontraditional activities. (Recommendation 4)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that HUD planned to add fields for capturing data on households served through local, nontraditional activities to the next generation of PIC for expansion MTW agencies, which would be implemented in the summer of 2020. Officials said HUD is currently in the process of determining how the next generation of PIC will be rolled out for existing MTW agencies.

Recommendation: The Assistant Secretary for PIH should develop and implement a process to monitor MTW agencies' reserves. (Recommendation 5)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that they planned to monitor existing MTW agencies' Housing Choice Voucher reserves by revising their annual reporting requirements to require them to report their plans for and use of reserves.

Recommendation: The Assistant Secretary for PIH should clarify HUD's rent-reform definition for the MTW demonstration as part of a framework for monitoring the effect of rent-reform, work-requirement, and time-limit policies on tenants. (Recommendation 6)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that PIH would clarify the definition of rent reform for existing MTW agencies in a document responding to frequently asked questions on the annual reporting requirements and for expansion agencies in the operations notice that it was finalizing for the expansion of the MTW program.

Recommendation: The Assistant Secretary for PIH should set parameters for HUD's definition of self-sufficiency for the demonstration, either by providing one definition or a range of options from which agencies could choose, as part of a framework for monitoring the effect of rent-reform, work-requirement, and time-limit policies on tenants. (Recommendation 7)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they planned to provide a range of suggested options for defining self-sufficiency in a document responding to frequently asked questions about the annual reporting requirements for MTW agencies.

Recommendation: The Assistant Secretary for PIH should revise HUD's guidance to MTW agencies to make it clear which elements are required in impact analyses, annual reevaluations, and hardship policies and the information required for each element as part of a framework for monitoring the effect of rent-reform, work-requirement, and time-limit policies on tenants. (Recommendation 8)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they planned to make it clear which elements are required in impact analyses, annual reevaluations, and hardship policies in the operations notice HUD was finalizing for the expansion of the MTW program. Further, HUD officials stated that the 2016 Appropriations Act that extended the standard agreement for the existing 39 MTW agencies limits HUD's ability to revise its guidance for these agencies to make it clear which elements are required in impact analyses, annual reevaluations, and hardship policies and the information required for each element. However, they stated that guidance related to the hardship policy and annual reevaluations has been updated to include more specific parameters for what an agency must submit to HUD. As we stated in our report, this guidance is set forth outside the standard agreement, which HUD already has revised without changes to the standard agreement. Therefore, we continue to believe that HUD could revise its guidance for the existing agencies to clarify which elements are required for these documents and the information each element should include.

Recommendation: The Assistant Secretary for PIH should develop written guidance for existing MTW agencies that requires a hardship policy for public housing time limits and encourages an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies for public housing and voucher programs as part of a framework for monitoring the effect of these policies on tenants. (Recommendation 9)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that they had updated their most recent annual reporting requirements for MTW agencies to require a hardship policy for public housing time limits and that they were working on finalizing guidance to existing MTW agencies encouraging an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies for public housing and voucher programs.

Recommendation: The Assistant Secretary for PIH should require an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies new MTW agencies adopt for their public housing and voucher programs as part of a framework for monitoring the effect of these policies on tenants. (Recommendation 10)

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2020, HUD officials stated that the operations notice they were finalizing for the expansion of the MTW program would require an impact analysis, annual reevaluation, and hardship policy for work-requirement and time-limit policies new MTW agencies adopt for their public housing and voucher programs.

Recommendation: The Assistant Secretary for PIH should develop and implement a plan for analyzing the information that agencies report on the effect of rent-reform, work-requirement, and time-limit policies on tenants as part of a framework for monitoring the effect of these policies on tenants. (Recommendation 11)

Agency: Department of Housing and Urban Development
Status: Open
Priority recommendation

Comments: In February 2020, HUD officials stated that they planned to develop separate analysis plans for existing and expansion MTW agencies due to differences in the types of performance information HUD can require them to report under their MTW agreements.

Recommendation: The Secretary of HHS should direct ACF to provide additional guidance and technical assistance to states to address known challenges and enhance their understanding of CAPTA requirements, including the requirements for health care providers to notify CPS of substance-affected infants and the development of a plan of safe care for these infants.

Agency: Department of Health and Human Services
Status: Open

Comments: HHS did not agree with this recommendation. The agency stated that it clarified guidance in the areas we raised. HHS also believes it is necessary to allow states the flexibility to meet the requirements in the context of their state CPS program. However, we found that states reported issues with the guidance and it did not address a key ongoing challenge regarding CAPTA requirements. HHS indicated that it will continue to provide technical assistance to states and fund demonstration sites to establish or enhance collaboration across community agencies and courts. Although continuing to provide technical assistance to states should be beneficial, our findings demonstrate that additional guidance is also needed. We continue to believe our recommendation is warranted. As of February 2020, the agency continues to disagree.

Recommendation: The Administrator of CMS should provide guidance and clarify requirements regarding the monitoring and reporting of deficiencies that states using home and community-based services (HCBS) waivers are required to report on their annual reports. (Recommendation 1)

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

Comments: CMS concurred with this recommendation and indicated the agency would provide guidance and clarify requirements regarding the monitoring and reporting of deficiencies in states' annual reports. According to CMS's fiscal year 2021 Budget Justification the agency expects to issue sub-regulatory guidance pertaining to health and welfare of Medicaid beneficiaries in residential facilities by the close of 2020.To fully implement this recommendation, the sub-regulatory guidance should clarify requirements for states' monitoring and reporting of deficiencies in HCBS annual reports. GAO will continue to monitor CMS actions in response to this recommendation.

Recommendation: The Administrator of CMS should establish standard Medicaid reporting requirements for all states to annually report key information on critical incidents, considering, at a minimum, the type of critical incidents involving Medicaid beneficiaries, and the type of residential facilities, including assisted living facilities, where critical incidents occurred. (Recommendation 2)

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

Comments: HHS neither agreed nor disagreed with this recommendation. According to CMS' fiscal year 2021 Budget Justification, the agency expects to issue sub-regulatory guidance pertaining to health and welfare of Medicaid beneficiaries in residential facilities by the close of 2020. To fully implement this recommendation, the sub-regulatory guidance should establish standard Medicaid reporting requirements for all states to report critical incidents annually. GAO will continue to monitor CMS actions in response to this recommendation.

Recommendation: The Administrator of CMS should ensure that all states submit annual reports for HCBS waivers on time as required. (Recommendation 3)

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

Comments: CMS concurred with this recommendation and stated that it will review and update its communications with states to reaffirm reporting requirements and ensure that all HCBS annual reports are submitted on time. According to CMS' fiscal year 2021 Budget Justification, the agency expects to issue sub-regulatory guidance pertaining to the health and welfare of Medicaid beneficiaries in residential facilities by the close of 2020. To fully implement this recommendation, the sub-regulatory guidance should ensure that all states submit annual reports on time. GAO will continue to monitor CMS actions in response to this recommendation.

Recommendation: The Director of National Intelligence, in his capacity as Security Executive Agent, and in coordination with the other Security, Suitability, and Credentialing Performance Accountability Council Principals--the Deputy Director for Management of Office of Management and Budget (OMB) in his capacity as Chair of the PAC, the Director of OPM, and the Under Secretary of Defense for Intelligence--should establish a milestone for the completion of government-wide performance measures for the quality of investigations. (Recommendation 1)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI stated that it non-concurred with many of the report's recommendations, but did not state with which recommendations it did not concur. In August 2019, ODNI officials pointed to the Quality Assessment Reporting Tool as the mechanism to measure the quality of background investigations. However, officials also stated that they had not finalized collection of all required data to establish performance measures and, while QART contains a significant data sample size, the data call issued in January 2019 will provide additional information for comparative analysis to develop performance measures for the entire Executive Branch. Officials agreed that since DOD does not use QART, there needed to be ongoing discussions with them to ensure quality standards are met. We will continue to follow-up on the status of this recommendation.

Recommendation: The Director of National Intelligence, in his capacity as Security Executive Agent, and in coordination with the other Security, Suitability, and Credentialing Performance Accountability Council Principals--the Deputy Director for Management of OMB in his capacity as Chair of the PAC, the Director of OPM, and the Under Secretary of Defense for Intelligence--should conduct an evidence-based review of the investigation and adjudication timeliness objectives for completing the fastest 90 percent of initial secret and initial top secret security clearances.(Recommendation 2)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI stated that it non-concurred with many of the report's recommendations, but did not state with which recommendations it did not concur. ODNI officials stated in August 2019 that Trusted Workforce 2.0 is specifically developing timeliness goals which are achievable and based on empirical evidence. We will continue to follow-up on the status of this recommendation.

Recommendation: The Director of National Intelligence, in his capacity as Security Executive Agent, and in coordination with the other Security, Suitability, and Credentialing Performance Accountability Council Principals--the Deputy Director for Management of OMB in his capacity as Chair of the PAC, the Director of OPM, and the Under Secretary of Defense for Intelligence--should develop a government-wide plan, including goals and interim milestones, to meet those timeliness objectives for initial personnel security clearance investigations and adjudications. (Recommendation 3)

Agency: Office of the Director of National Intelligence
Status: Open

Comments: ODNI stated that it non-concurred with many of the report's recommendations, but did not state with which recommendations it did not concur. In its August 2019 response on the status of this recommendation, ODNI officials stated that the transfer of background investigations from NBIB to DOD will provide an opportunity for the Executive Agents to reassess and address investigative timeliness issues and strengthen management of sensitive information. Moreover, they stated that Trusted Workforce 2.0 will give them the ability to significantly reduce the timelines required to deliver a Secret and Top Secret clearance. We will continue to follow-up on the status of this recommendation.

Recommendation: The Administrator of CMS, in partnership with the states, should take additional steps to expedite the use of T-MSIS data for program oversight. Such steps should include, but are not limited to, efforts to (1) obtain complete information from all states on unreported T-MSISdata elements and their plans to report applicable data elements; (2) identify and share information across states on known T-MSIS datalimitations to improve data comparability; and (3) implement mechanisms, such as the Learning Collaborative, by whichstates can collaborate on an ongoing basis to improve thecompleteness, comparability, and utility of T-MSIS data.(Recommendation 1)

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

Comments: HHS concurred with this recommendation. As of February 2020, CMS has taken steps to improve T-MSIS data quality, but further efforts are needed to expedite the data's use in oversight. With regard to obtaining complete information from all states, CMS released additional guidance in March 2019, on state compliance with T-MSIS requirements. This guidance includes the need to resolve data issues associated with 12 top priority items and missing data elements, both of which are key for using T-MSIS data. Further, CMS identified an additional 11 top priority items, noting it also expected states to resolve data issues with these items. CMS reports that it has helped resolve data issues related to these 23 top priority items by sending states summary data on compliance with associated reporting requirements. CMS has notified states of their compliance status and asked non-compliant states to submit corrective action plans. However, CMS reports that the level of states' T-MSIS data completeness varies and agency state liaisons and technical assistants continue to work individually with states to identify, prioritize, and resolve key missing data elements. With regard to identifying and sharing information, CMS has made some T-MSIS data available for use through five T-MSIS analytical files, which include data on Medicaid and CHIP enrollment, demographics, service utilization, and payments. Further, CMS has created resources to support researchers in their use of these analytical files, including information on the completeness and accuracy of certain data elements. With regard to implementing mechanisms for collaboration across states, additional CMS action is needed. In particular, CMS's efforts to create a mechanism for states to disseminate information about T-MSIS data and its comparability across states remain limited and the agency has not launched its proposed Learning Collaborative to facilitate ongoing feedback and collaboration. While progress has been made, additional actions, such as establishing mechanisms for ongoing feedback and collaboration across states, are needed to consider this recommendation implemented.

Recommendation: The Administrator of CMS should articulate a specific plan and associated time frames for using T-MSIS data for oversight. (Recommendation 2)

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

Comments: HHS concurred with this recommendation. As of February 2020, CMS has taken steps to articulate guidance to states, but has not outlined a specific plan and associated time frames for using T-MSIS data for oversight. Until CMS takes these actions, the recommendation remains open.

Recommendation: The Director of OMB should continue to provide ongoing technical assistance that significantly contributes to agencies making their own determinations about their DATA Act reporting requirements and monitor agency submissions. (Recommendation 1)

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

Comments: OMB stated in January 2020 that it believes that the assistance it has previously provided to help agencies make their own reporting determinations fulfills the recommendation's intent. However, because we continue to identify instances where agencies had not submitted these data, we continue to believe that OMB needs to follow up with agencies that are not submitting quarterly data to find out why they are not reporting. It also needs to update its list of agencies required to report.

Recommendation: The Director of OMB should clarify and align existing guidance regarding the appropriate definitions agencies should use to collect and report on Primary Place of Performance and establish monitoring mechanisms to foster consistent application and compliance. (Recommendation 2)

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

Comments: OMB has issued or contributed to guidance documents that are intended to help agencies collect and report on "Primary Place of Performance." We believe that providing specific examples of how agencies should approach challenging situations when reporting on this data element for grants would provide further clarity.

Recommendation: The Secretary of the Treasury should reasonably assure that ongoing monitoring controls to help ensure the completeness and accuracy of agency submissions are designed, implemented, and operating as designed. (Recommendation 4)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: In September 2019, Treasury officials stated that they are working to formalize a process for monitoring agency submissions. This process will include (1) emailing agencies prior to submission deadlines to remind them of the approaching submission deadlines; (2) following up with agencies that do not submit required data by the submission deadline and offering technical assistance as needed; and (3) forwarding a list of non-compliant agencies to OMB. GAO will continue to monitor Treasury's efforts to establish monitoring controls to help ensure the completeness and accuracy of the data.

Recommendation: The Secretary of the Treasury should disclose known data quality issues and limitations on the new USAspending.gov. (Recommendation 5)

Agency: Department of the Treasury
Status: Open
Priority recommendation

Comments: As of January 2020, Treasury has made progress by disclosing limitations related to unreported spending, among other things. Treasury is planning a major update to the USAspending.gov website to include more information about known data quality issues. Treasury plans to make this update to the website in the coming months and has an internal target date of June 2020 for completion. When completed, this action will help users make more informed decisions about how to interpret and use the data provided on the website.

Recommendation: The Secretary of Agriculture should ensure that the CIO of USDA establishes an agency-wide policy and process for the CIO's certification of major IT investments' adequate use of incremental development, in accordance with OMB's guidance on the implementation of FITARA, and confirm that it includes: a description of the CIO's role in the certification process; a description of how CIO certification will be documented; and a definition of incremental development and time frames for delivering functionality, consistent with OMB guidance. (Recommendation 9)

Agency: Department of Agriculture
Status: Open

Comments: In September 2019, a Department of Agriculture official stated that the department was working to establish a policy to include the information noted in our recommendation and planned to finalize a policy by the end of December 2019. We will continue to monitor the department's progress on these efforts.

Recommendation: The Secretary of Veterans Affairs (VA) should ensure that the CIO of VA updates the agency's policy and process for the CIO's certification of major IT investments' adequate use of incremental development, in accordance with OMB's guidance on the implementation of FITARA, and confirm that it includes a description of the CIO's role in the certification process and a description of how CIO certification will be documented. (Recommendation 10)

Agency: Department of Veterans Affairs
Status: Open

Comments: The Department of Veterans Affairs (VA) has taken action, and stated that it would draft a policy to address our recommendation. In November 2019, a VA official stated that the department is working to address our recommendation but did not identify timeframes for when all activities would be completed. We will continue to evaluate the department's progress in implementing this recommendation.

Recommendation: The Administrator of the Environmental Protection Agency (EPA) should ensure that the CIO of EPA establishes an agency-wide policy and process for the CIO's certification of major IT investments' adequate use of incremental development, in accordance with OMB's guidance on the implementation of FITARA, and confirm that it includes: a description of the CIO's role in the certification process; a description of how CIO certification will be documented; and a definition of incremental development and time frames for delivering functionality, consistent with OMB guidance. (Recommendation 11)

Agency: Environmental Protection Agency
Status: Open

Comments: The Environmental Protection Agency (EPA) concurred with our recommendation and stated that it planned to develop a policy to implement this recommendation and other FITARA issues. Specifically, EPA officials reported in July 2019 that the agency was continuing to work to address the recommendation but did not provided a time frame for when a policy would be finalized. We will continue to monitor EPA's progress on these efforts.

Recommendation: The Administrator of the National Aeronautics and Space Administration (NASA) should ensure that the CIO of NASA establishes an agency-wide policy and process for the CIO's certification of major IT investments' adequate use of incremental development, in accordance with OMB's guidance on the implementation of FITARA, and confirm that it includes: a description of the CIO's role in the certification process; a description of how CIO certification will be documented; and a definition of incremental development and time frames for delivering functionality, consistent with OMB guidance. (Recommendation 13)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: The National Aeronautics and Space Administration (NASA) concurred with our recommendation and reported that the agency was in the process of addressing it. Specifically, NASA officials reported in June 2020 that its guidance is currently being updated to include the information noted in our recommendation and will be finalized by September 2020. We will continue to monitor NASA's progress on these efforts.

Recommendation: The Director of the Office of Personnel Management (OPM) should ensure that the CIO of OPM updates the agency's policy and process for the CIO's certification of major IT investments' adequate use of incremental development, in accordance with OMB's guidance on the implementation of FITARA, and confirm that it includes a description of the CIO's role in the certification process and a description of how CIO certification will be documented. (Recommendation 16)

Agency: Office of Personnel Management
Status: Open

Comments: The Office of Personnel Management (OPM) concurred with our recommendation and stated that it would update its policies and processes to include the elements we recommended. Specifically, OPM officials reported in November 2019 that guidance on CIO certification was being developed but the agency had not yet determined a time frame for finalizing the policy. We will continue to monitor OPM's progress on these efforts.

Recommendation: The Commandant of the Coast Guard should either develop new performance goals to address mission activity gaps, or explain in the Coast Guard's Annual Performance Report (APR) why certain aspects of mission performance are measured while others are not. (Recommendation 1)

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

Comments: In October 2017, the Coast Guard concurred with our recommendation and stated that it would add new measures in future Annual Performance Reports (APRs) and explain what is measured and what is not, as appropriate. In May 2020, the Coast Guard provided GAO with its updated fiscal year 2019 APR. After reviewing the fiscal year 2019 APR, we found that the Coast Guard made revisions to the goals for the Ports, Waterways, and Coastal Security (PWCS) and Marine Environmental Protection-prevention activities (MEP) missions and added a goal for the Search and Rescue mission. However, the APR did not include additional goals or an explanation why certain aspects of mission performance are measured while others are not for the other performance goals we previously identified as not fully addressing all related mission activities. In its July 2020 update to this recommendation, the Coast Guard reported that the metrics published in the APR are measures of Coast Guard performance and not performance goals. The Coast Guard also noted that it continually evaluates the utility of its performance measures, and makes changes to individual measures, as well as its suite of measures, when doing so provides meaningful improvement. In its July 2020 update, the Coast Guard added that targets established for performance measures are intended to be realistic expectations of future performance and targets are continually evaluated and changed when current performance modify expectations. However, we continue to believe that in the absence of documentation explaining how existing performance goals address each mission, the extent to which the Coast Guard's performance goals encompass all of its mission activities is unclear. Either developing new goals to address mission activity gaps, or describing in the APR how existing goals sufficiently assess the performance of each mission could provide more meaningful information on progress in achieving Coast Guard's missions to executive branch decision makers, Congress, and the public. In order to fully implement the recommendation as intended, in instances in which performance goals do not fully address all of the respective mission activities, the Coast Guard's APR should include an explanation of the Coast Guard's rationale for why certain aspects of mission performance are measured while others are not. We will continue to follow-up on the Coast Guard's efforts to address this recommendation.

Recommendation: The Administrator of CMS should require plan sponsors to report to CMS on investigations and other actions taken related to providers who prescribe high amounts of opioids. (Recommendation 3)

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

Comments: HHS did not concur with this recommendation. As of September 2019, HHS had not provided information on actions taken to implement it. We will update its status when we receive additional information.

Recommendation: The Undersecretary for Health should take additional steps to ensure that VA's website reports health care quality measures that cover a broad range of health care services, highlights key differences in the clinical quality of care, and presents this information in an easily accessible and understandable way (Recommendation 1).

Agency: Department of Veterans Affairs
Status: Open

Comments: As of January 2020, VA provided information that they had updated information on its website to include more quality measures, particularly as they relate to outpatient care. While VA has made progress in reporting on additional measures, we reviewed VA's website-specifically, their Access and Quality webpage which is the primary webpage for veterans to access information on quality-as of February 2020 and found that VA has still yet to report on a broad range of quality measures that would assist veterans in making health care decisions for inpatient care. For example, VA does not report any quality measures related to readmissions and mortality; length-of-stay; or efficiency. VA also continues to report only one timely and effective care measure for inpatient care. With regards to presentation of its quality measures, VA no longer links its Access and Quality webpage to the homepage of VA's website, making it more difficult to find. Additionally, for the new outpatient measures that VA has added to its website, VA has not presented these measures in an easily understandable way as there is little explanation of what they are measuring and how veterans can use these measures to make healthcare decisions. We will keep this recommendation open until VA has made further updates to its website.

Recommendation: The Undersecretary for Health should direct VA Central Office to conduct a systematic assessment of the completeness and accuracy of patient clinical information across VAMCs that is used to calculate the health care quality measures VA reports and address any deficiencies that affect the accuracy of these measures (Recommendation 2).

Agency: Department of Veterans Affairs
Status: Open

Comments: As of January 2020, VA has said they have focused on three main efforts as it relates to documenting information on VA quality of care, including: timeliness of access information (e.g., wait times) to health care within VA facilities; timeliness and accuracy of payments to community care providers; and accuracy of coding and documentation within VA and from community providers. In particular, VA has conducted several efforts to improve education and training on clinical documentation and coding, particularly for providers. VA has also said it has made efforts in requiring programs across regional networks aimed at improving clinical documentation and coding. While these efforts can help with improving documentation of care to veterans, it is unclear how VA Central Office has assessed whether these efforts have actually achieved its goals and improved the accuracy of its quality measures. As we stated in our report, VA Central Office has not conducted a systematic assessment of the completeness and accuracy of the clinical data recorded in VA patient medical records across all VAMCs. The results of such a systematic analysis could help identify the deficiencies, if any, in the recording of patient clinical information and what steps, if any, VA Central Office may need to take to address them. We will keep this recommendation open until VA provides information on a systematic assessment of clinical documentation.

Recommendation: The Director of OMB should revise and publicly issue OMB guidance--through an update to its Circular No. A-11, a memorandum, or other means--to provide time frames and associated milestones for implementing the federal program inventory. (Recommendation 2)

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

Comments: As of October 2020, OMB has taken some actions toward addressing this recommendation. In its June 2019 and July 2020 updates to Circular No. A-11, OMB provided a time frame for implementing some of the federal program inventory requirements. In that guidance, OMB states that beginning with the 2021 budget cycle, agencies' program activities will be used for the inventory's program-level reporting requirements. This will allow OMB and agencies to leverage federal spending data reported on USASpending.gov as required by the Digital Accountability and Transparency Act. Those data can be presented at the program activity level, and therefore could meet the inventory requirements to present program-level spending data. However, OMB's guidance does not yet present any time frames or milestones for meeting other inventory requirements, such as describing the purpose of each program or how it contributes to the agency's mission and goals. We will continue to monitor OMB's actions to address this recommendation.

Recommendation: The Director of OMB should consider--as OMB determines its strategy for resumed implementation of the federal program inventory--using a systematic approach, such as the information architecture framework, to help ensure that GPRAMA requirements and our past recommendations for the inventory are addressed. (Recommendation 3)

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

Comments: As of October 2020, OMB has taken some actions toward addressing this recommendation. In its June 2019 and July 2020 updates to Circular No. A-11, OMB states that it and agencies will meet some of the federal inventory requirements by leveraging the spending data reported on USASpending.gov. The guidance notes that this information is provided in a structured information architecture format on USASpending.gov. In July 2019, OMB staff told us that they considered an information architecture approach in response to our past reports on the topic. However, OMB has not yet clarified in guidance or elsewhere how the information architecture format of USASpending.gov-which is currently focused on spending data-could be used to meet additional information reporting requirements and our past recommendations related to the inventory. We will continue to monitor OMB's actions to address this recommendation.

Recommendation: The Director of OMB should work with the Performance Improvement Council to identify and share among agencies practices for expanding the use of data-driven performance reviews beyond agency priority goals, such as for other performance goals and at lower levels within agencies, that have led to performance improvements. (Recommendation 4)

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

Comments: As of October 2020, OMB and the PIC have taken some actions toward addressing this recommendation. OMB and the PIC, in guidance provided through Circular No. A-11 and the Goal Playbook respectively, have encouraged agencies to expand their use of data-driven reviews beyond agency priority goals. In March 2019, OMB staff told us that they would work with the PIC to provide agencies with case studies and other resources that could help expand their use of data-driven reviews, should agencies choose to do so. However, as of October 2020, OMB and the PIC have not yet identified and shared practices related to expanding the use of those reviews as we recommended. We will continue to monitor OMB's actions to address this recommendation.

Recommendation: The Associate Director of Merit System Accountability and Compliance should ensure that OPM's finalized records schedule on retaining conversion case files specifically lists all documentation that must be saved in its case files. (Recommendation 1)

Agency: Office of Personnel Management
Status: Open

Comments: In response to our recommendation, OPM drafted a retention schedule for its pre-appointment review case files. As of June 2019, according to OPM, National Archives and Records Administration (NARA) was in the process of reviewing the draft retention schedule. Once NARA approves and OPM finalizes the schedule, OPM will be better able to maintain complete documentation to justify conversion request decisions and ensure such documentation is available for subsequent review. On July 8, 2020, OPM informed us it is getting closer to fully responding to this recommendation and providing us with appropriate documentation to support is efforts.

Recommendation: To improve CMS's oversight of states' MLTSS programs, the Administrator of CMS should take steps to identify and obtain key information needed to oversee states' efforts to monitor beneficiary access to quality services, including, at a minimum, obtaining information specific to network adequacy, critical incidents, and appeals and grievances.

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

Comments: The Department of Health and Human Services (HHS) agreed with this recommendation. In December 2017, HHS communicated its intent to review regulations and enhance its capacity to measure, monitor, and improve care and quality across a number of domains, including MLTSS. As of February 2020, HHS stated that it is developing guidance related to reporting on key information needed to oversee beneficiary access to care. GAO will continue to monitor the department's actions and any steps taken to address this recommendation.

Recommendation: To improve the consistency and effectiveness of governmentwide efforts to reduce the unnecessary use of SSNs and thereby mitigate the risk of identity theft, the Director of OMB should specify elements that agency plans for reducing the unnecessary collection, use, and display of SSNs should contain and require all agencies to develop and maintain complete plans.

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

Comments: As of April 2020, we have not yet received information to validate the agency's actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.

Recommendation: To improve the consistency and effectiveness of governmentwide efforts to reduce the unnecessary use of SSNs and thereby mitigate the risk of identity theft, the Director of OMB should require agencies to modify their inventories of systems containing personally identifiable information to indicate which systems contain SSNs and use the inventories to monitor their reduction of unnecessary collection and use of SSNs.

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

Comments: As of April 2020, we have not yet received information to validate the agency's actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.

Recommendation: To improve the consistency and effectiveness of governmentwide efforts to reduce the unnecessary use of SSNs and thereby mitigate the risk of identity theft, the Director of OMB should provide criteria to agencies on how to determine unnecessary use of SSNs to facilitate consistent application across the federal government.

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

Comments: As of April 2020, we have not yet received information to validate the agency's actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.

Recommendation: To improve the consistency and effectiveness of governmentwide efforts to reduce the unnecessary use of SSNs and thereby mitigate the risk of identity theft, the Director of OMB should take steps to ensure that agencies provide up-to-date status reports on their progress in eliminating unnecessary SSN collection, use, and display in their annual Federal Information Security Modernization Act of 2014 reports.

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

Comments: As of April 2020, we have not yet received information to validate the agency's actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.

Recommendation: To improve the consistency and effectiveness of governmentwide efforts to reduce the unnecessary use of SSNs and thereby mitigate the risk of identity theft, the Director of OMB should establish performance measures to monitor agency progress in consistently and effectively implementing planned reduction efforts.

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

Comments: As of April 2020, we have not yet received information to validate the agency's actions on this recommendation. Subsequent to the agency stating that is has taken action, we plan to verify whether implementation has occurred.

Recommendation: The Commissioner of CBP should identify and collect additional performance information on the impact of the ISF rule data, such as the identification of shipments containing contraband, to better evaluate the effectiveness of the ISF program.

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

Comments: In March 2018, the CBP liaison informed GAO that offices within CBP are collaborating on a plan to assess additional performance metrics to evaluate the effectiveness of the ISF program. On June 13, 2018, the CBP liaison stated that CBP staff continue to work on additional performance metrics to evaluate the effectiveness of the ISF program and noted, in particular, are analyzing data to: (1) identify the number of unmanifested containers and determine how/if they were mitigated before arrival; (2) determine the number of times C-TPAT companies were identified and given targeting benefits, but did not receive the same treatment based on manifest information; and (3) identify the number of times potential terrorism matches were made against an ISF entities vs. the number of times not matched using the same manifest data. In March 2019, the CBP liaison stated that the new estimated completed date for this recommendation is the end of 2019. This recommendation will remain open until CBP's planned actions are completed and meet the intent of GAO's recommendation. In late February 2020, CBP liaison staff informed GAO that they are continuing to work on this recommendation, which they expect to complete by March 31, 2020.

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

Recommendation: The Secretary of the Army should conduct a comprehensive assessment to better understand the resources necessary for the requirements development process and determine the extent to which the shortfalls can be addressed given other funding priorities.

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

Comments: The Army concurred with our recommendation. Previously, Army officials told GAO that they planned to implement this recommendation after the new Army Futures Command-which currently manages capabilities development for the Army-became fully operational. Although this command became fully operational in July 2019, Army officials stated that more time is needed to fully coordinate and implement this recommendation. The Army Futures Command will work with the U.S. Army Manpower Analysis Agency to assess the capabilities development workforce focused on requirements prior to programs entering the system development phase. Army officials estimate that this assessment will be completed in March 2021. In June 2020, GAO staff received a brief status update from the Army PAO who confirmed that this is still the plan.

Recommendation: To ensure that DOD program managers have the necessary information to maintain complete visibility and accountability of ITEF-funded equipment in SCIP, the Secretary of Defense should identify the root causes, such as potential interoperability and data reporting issues within SCIP and other DOD data systems, for why DOD components are not ensuring that ITEF-funded equipment transportation dates are captured in SCIP.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. As of October 2019, DOD was in the process of developing a plan to address this recommendation. GAO is continuing to monitor DOD's progress in addressing this recommendation.

Recommendation: To ensure that DOD program managers have the necessary information to maintain complete visibility and accountability of ITEF-funded equipment in SCIP, the Secretary of Defense should develop an action plan with associated milestones and time frames for addressing the root causes for why DOD components are not ensuring that ITEF-funded equipment transportation dates are captured in SCIP.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. As of October 2019, DOD was in the process of developing a plan to address this recommendation. GAO is continuing to monitor DOD's progress in addressing this recommendation.

Recommendation: To ensure that DOD program managers have the necessary information to maintain complete visibility and accountability of ITEF-funded equipment in SCIP, the Secretary of Defense should develop written procedures that specify under which data field ITEF-funded equipment transfer dates should be captured in the Enhanced Freight Tracking System in SCIP.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation. The department commented that the relevant organizations have most, if not all, of the written procedures that are necessary for reporting these dates in the Enhanced Freight Tracking System. However, it would coordinate with all interested parties to update these procedures if needed. As of October 2019, GAO was continuing to monitor DOD's progress in addressing this recommendation.

Recommendation: To ensure that DOD program managers have the necessary information to maintain complete visibility and accountability of ITEF-funded equipment in SCIP, the Secretary of Defense should update the 1st Theater Sustainment Command's (1st TSC) written standard operating procedures to include the 1st TSC commander's verbal order requiring the inclusion of unique equipment case identifier information for ITEF-funded equipment on transfer documentation.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. As of October 2019, DOD officials said they had updated the 1st TSC's written standard operating procedures to include the 1st TSC's commander's verbal order, and GAO was in the process of obtaining documentation of these changes.

Recommendation: To help FAA better manage and oversee its portfolio of R&D activities, the Secretary of Transportation should direct the FAA to take a more strategic approach to identifying research priorities across the agency, including developing guidance to identify long-term priorities and emerging issue areas, as part of FAA's portfolio development process.

Agency: Department of Transportation
Status: Open

Comments: In June 2019, FAA issued a redesigned National Aviation Research Plan (NARP) for 2017/2018. In September 2019, FAA officials told GAO that the redesigned NARP helped the agency take a more strategic approach to identifying research priorities. FAA officials also said that the agency has taken actions to understand emerging aviation issues requiring FAA's research attention and those emerging issues will be incorporated into future plans. In June 2020, FAA officials told us that they are developing guidance--to be finalized by December 2020--to ensure that future NARPs continue to take a strategic approach. GAO will review FAA's actions to implement the recommendation once the guidance is completed.

Recommendation: To help FAA better manage and oversee its portfolio of R&D activities, the Secretary of Transportation should direct the FAA to develop guidance to ensure that future National Aviation Research Plans (NARP) and R&D Annual Reviews meet statutory requirements to the extent practicable, including (a) The NARP lists activities that are carried under cooperative agreements. (b) The NARP describes the rationale for the prioritized research programs. (c) The NARP identifies how resources were allocated for long-term and near-term research. (d) The NARP identifies REDAC recommendations that are accepted, not accepted, and the reasons for non-acceptance. (e) The NARP provides a detailed description of technology transfer to government, industry, and academia. (f) The Annual Review describes new technologies developed and the dissemination of research results to the private sector. (g) The Annual Review allows a comparison to the NARP. (h) The Annual Review is prepared and presented in accordance with agency performance reporting requirements.

Agency: Department of Transportation
Status: Open

Comments: In June 2019, FAA issued a redesigned the National Aviation Research Plan (NARP) to include, among other things, information required by statue. In June 2020, FAA officials told us that they redesigned the R&D Annual Review in 2019 to also address the statutory requirements. The officials said that they are also in the process of revising guidance that the agency uses to develop the NARP and R&D Annual Review to ensure that future documents meet statutory requirements. FAA plans to finalize the guidance by December 2020. GAO will review FAA's actions to implement the recommendation once FAA provides GAO the redesigned R&D Annual Review and once guidance for both the NARP and R&D Annual Review are completed.

Recommendation: To help ensure that the pilot programs for disconnected youth can be effectively implemented over the lifetime of the initiative, the Director of OMB should coordinate with relevant federal agencies to identify and estimate expected annual financial and staff resource contributions from each agency, including during the implementation and evaluation phases of the pilots.

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

Comments: As of May 2020, the Office of Management and Budget (OMB) and relevant federal agencies described steps they have taken that could address the intent of this recommendation. However, they have not yet shared documentation so that we can independently verify those actions. Since we issued our report in April 2017, federal agencies discontinued contributing financial resources to support joint pilot program activities, such as start-up grants, general technical assistance, or evaluations. According to OMB staff and officials at several agencies in August 2018, that change in contributions began with the fiscal year 2018 pilots. At that time, they all told us that relevant agencies would continue to provide staff support to the pilots, as needed. In April 2020, officials from the Department of Education (Education)-the lead agency for overall performance partnership efforts-informed us that six pilots remain active, through September 2020, and were able to provide information about staff resource contributions. For example, Education officials told us that two of the department's employees devote less than 10 percent of their time to support those six pilots. We have requested additional information from Education to better understand staff resource commitments and contributions from other agencies involved in those six pilots.

Recommendation: To ensure that federal agencies involved in the disconnected youth pilots are able to evaluate pilot outcomes and ultimately communicate to Congress whether and to what extent the flexibilities tested by the pilots should be integrated into broader efforts, the Director of OMB should coordinate with relevant federal agencies to identify criteria or standards for assessing scalability, and collect data needed to address those criteria or standards.

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

Comments: As of May 2020, the Office of Management and Budget (OMB) and relevant federal agencies described steps they have taken that could address this recommendation. However, they have not yet shared documentation so that we can independently verify those actions. In August 2018, OMB staff told us that they were coordinating relevant work with the Department of Health and Human Services (HHS) and the Department of Labor (DOL), which is leading the national evaluation for the disconnected youth pilot programs. OMB staff told us this group was studying specific criteria or standards that could be used for assessing the scalability of the disconnected youth pilot programs. In April 2020, DOL officials told us that the department was examining issues related to scalability in products it is developing as part of the national evaluation. For example, the officials informed us that DOL plans to publish a report in summer 2020 that examines the effects of flexibilities tested by individual pilot programs, and their potential to be scaled. Furthermore, DOL officials told us that the department, in coordination with OMB, HHS, and other relevant agencies, had drafted, but not yet finalized, a memorandum that identifies criteria for assessing scalability. We have requested copies of relevant DOL evaluation products and the memorandum. When provided, we will assess the extent to which they address our recommendation.

Recommendation: The Secretary of Energy, working with the Administrator of the National Nuclear Security Administration, should include more complete information on the assessments--that is, security plans, vulnerability assessments, independent assessments, and other assessments--used in the annual reports to support the agencies' assessments that DOE and NNSA sites are secure.

Agency: Department of Energy
Status: Open

Comments: We reported in May 2019 that DOE and NNSA continued to make progress in responding to this recommendation. The draft 2018 annual report contained, as recommended, more complete and uniform information on assessments, though in some cases different terminology was used by programs and sites. As of June 2020, we have requested final 2018, 2019, and 2020 annual reports from NNSA to ensure progress has continued. Once we have received and reviewed the reports, we will update the status of this recommendation.

Recommendation: Additionally, the Secretary of Energy should develop a plan for addressing the physical security infrastructure needs at DOE sites. Similar to a report under development by NNSA, this plan could identify cost and time frames and enable DOE and the Congress to prioritize these projects.

Agency: Department of Energy
Status: Open

Comments: As of June 2020, DOE has not implemented this recommendation. While DOE program offices (Environmental Management, Science, and Nuclear Energy) are individually considering long-term needs, the program offices are not required by Congress to submit the kind of physical security plan that Congress requires of NNSA. In the absence of Congressional direction, we believe it is unlikely that DOE will fully implement this recommendation.

Recommendation: Additionally, the Secretary of Energy should, in future annual security certification reports, inform Congress of the reasons for the delayed implementation of the June 2011 DOE material control and accountability order at some sites, as well as the steps DOE and its sites are taking to implement it. DOE should also provide Congress with information on any vulnerabilities or deficiencies in the security at sites that may potentially exist while the sites complete implementation of the order as well as information on any concomitant adjustment to their security posture that is required.

Agency: Department of Energy
Status: Open

Comments: As of June 2020, we are continuing to monitor actions related to this recommendation. DOE has acknowledged in a classified memorandum the security risks associated with the slow pace of the material control and accountability order. DOE has also developed a plan to implement measures to address these risks in a phased approach with final implementation sometime in the 2020s. Some of the early phases will be complete between 2019 and 2022, but others will extend beyond 2022. As such, it will be important for DOE to continue to report to Congress on residual risk until planned actions are fully completed and their implementation has been verified by the relevant DOE program offices and DOE's Office of Enterprise Assessments. We will update the status of this recommendation once we have we have received and reviewed DOE's classified 2018-2020 annual reports to ensure this action is taken.

Recommendation: To enhance interagency collaboration in the Manufacturing USA program, the Secretary of Commerce should direct the Director of the National Institute of Standards and Technology to work with all non-sponsoring agencies whose missions contribute to or are affected by advanced manufacturing to revise the Manufacturing USA governance system to ensure the roles and responsibilities for how these agencies could contribute to the Manufacturing USA program are fully identified.

Agency: Department of Commerce
Status: Open

Comments: In October 2019, the National Institute of Standards and Technology (NIST) reported that, working through the Manufacturing USA interagency team and the National Science and Technology Subcommittee on Advanced Manufacturing, it had revised the Manufacturing USA governance document to include a section defining roles related to facilitating information sharing for agencies who are not sponsoring Manufacturing USA institutes. We are seeking clarification from NIST on which non-sponsoring agencies are covered by the new section. We will revisit the status of this recommendation once we receive clarification.

Recommendation: To improve consistency in CMS oversight of federal spending under section 1115 demonstrations, the Secretary of Health and Human Services should require the Administrator of CMS to develop and document standard operating procedures for monitoring spending under demonstrations that (1) require setting reporting requirements for states that provide CMS the data elements needed for CMS to assess compliance with demonstration spending limits; (2) require consistent enforcement of states' compliance with financial reporting requirements; and (3) require consistent tracking of the amount of unspent funds under demonstration spending limits.

Agency: Department of Health and Human Services
Status: Open

Comments: The Department of Health and Human Services (HHS) has taken steps to improve the consistency of oversight of federal spending under section 1115 demonstrations. In November 2018, HHS officials reported that they have developed draft guidance, including a standard reporting tool for states, to better ensure consistent reporting of the elements needed to assess compliance with demonstration spending limits and was in the process of testing the tool with two states. In addition, the agency is developing standard operating procedures for agency staff to require consistent tracking of unspent funds under the spending limit. As of November 2019, HHS has not provided any updates. GAO will continue to monitor HHS's actions and once procedures are in place, GAO will assess whether they address our recommendation.

Recommendation: To improve management and oversight of the SAVE program, the director of USCIS should develop and implement a mechanism to oversee agencies' completion of training on additional verification in accordance with SAVE MOA provisions and program policies.

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

Comments: In March 2017, we found that USCIS does not track or monitor whether SAVE users have completed training and therefore does not have reasonable assurance that users have mastered SAVE policies and procedures prior to accessing the system. We recommended that USCIS develop and implement a mechanism to oversee agencies' completion of training on additional verification in accordance with SAVE provisions and program policies. The USCIS Verification Division reported that it planned to address providing additional training for SAVE users developed by December 31, 2017. The SAVE Program would then offer training events for agencies on the new material reflecting the agency user requirements for additional verification as well as system enhancements. In September 2017, the Verification Division implemented part one of this recommendation, a monthly webinar training session on user agency responsibilities and additional verification. This training can also be delivered to user agencies upon request. For part two of this recommendation, the SAVE program also developed training features to oversee agencies' completion of training. These training features are a system enhancement that will be incorporated into SAVE's overall modernization effort and was expected to be completed by September 30, 2019. In the interim, SAVE is implementing several other enhancements that will reduce the number of cases sent to additional verification, including the completion of modernized matching logic and initial verification screens and retiring less efficient access methods. In September 2019, SAVE officials told us that SAVE has reduced the number of cases sent to additional verification by retiring inefficient access methods and completing modernization of SAVE matching logic and initial verification screens. However, SAVE officials said they also determined that they must update the SAVE tutorial platform and content to account for these and other changes. Officials said that while SAVE is updated, the program continues to provide training, resources, and other support to user agencies to help ensure they are performing additional verification in accordance with SAVE MOA provisions and program policies. The new estimated completion date is February 28, 2021.

Recommendation: The Board of Directors should ensure that TVA propose, and work with the TVA Retirement System board to adopt, funding rules designed to ensure the plan's full funding.

Agency: Tennessee Valley Authority
Status: Open

Comments: In their initial response to our report, TVA neither agreed nor disagreed with this recommendation. In response to our report, TVA has taken some steps to improve the plan's funding status. For example, in fiscal year 2017, TVA made a one-time pension contribution of $500 million to the TVA Retirement System (TVARS) in addition to its $300 million required annual contribution, resulting in a total of $1.7 billion in contributions from fiscal year 2017 through fiscal year 2020 . TVA's one-time contribution and investment returns have improved the funding status of the TVARS plan but the TVARS Rules do not adjust TVA's required contributions to ensure pension liabilities will be fully funded. In order to fully implement this recommendation, the Rules need a mechanism that adjusts TVA's contributions to ensure adequate funding regardless of future plan experience.

Recommendation: To support the consistent application of agency telework policy throughout the agency, the Secretaries of the Departments of Education and Labor and the Chair of the Securities and Exchange Commission should implement controls to verify that supervisors have completed telework training prior to entering into telework agreements with their employees and that completion of this training is documented.

Agency: Department of Labor
Status: Open

Comments: In a letter to GAO dated May 26, 2017, the Department of Labor stated that the department currently offers interactive manager/supervisor telework training to all supervisors, the completion of which is documented in the manager and supervisor training records. However, officials said this training was strongly encouraged but not required. In fiscal year 2019, telework training was added as a mandatory course for all managers and supervisors, the completion of which is documented in manager and supervisor training records and reported to departmental leadership. As of August 2020, the Department of Labor was developing and testing a telework tracking application system that will require and document completion of manager/supervisor telework training through the Department's internal learning development system before a supervisor can use the system to approve telework agreements. The Department of Labor anticipates the system will be ready for implementation in FY 2021. We will continue to follow up with the Department of Labor on this and will provide an update when available.

Recommendation: To help ensure that telework agreements accurately reflect telework participation, and to further ensure the accuracy of telework data reported internally and externally, the Secretary of the Department of Labor, the Administrator of the General Services Administration, and the Chair of the Securities and Exchange Commission should require documentation of regular or periodic reviews of all telework agreements in agency telework policies.

Agency: Department of Labor
Status: Open

Comments: In a letter to GAO dated May 26, 2017, the Department of Labor stated that the current policy requires supervisors to conduct an annual review of telework agreements to ensure the arrangement is current and the needs of the agency are being met. In October 2019, Department of Labor officials stated the department is revising its telework processes to include a defined procedure for managers/supervisors to document and report the annual reviews. As of August 2020, the Department of Labor was developing and testing a telework tracking application system that will require and document annual telework agreement recertification for all telework program participants and their supervisors to ensure a regular review of telework agreements. The Department of Labor anticipates the system will be ready for implementation in FY 2021. When we confirm that Labor has fully completed these actions, we will provide updated information.

Recommendation: To improve the accuracy of telework data transmitted to OPM, the Secretary of the Department of Labor should direct the Chief Human Capital Officer to work with the Telework Managing Officer to develop and implement a plan to modernize Labor's telework agreement tracking system to enable more timely access to accurate telework data.

Agency: Department of Labor
Status: Open

Comments: In a letter to GAO dated May 26, 2017, the Department of Labor stated that it will benchmark best practices used by other federal agencies to explore options for utilizing its existing telework agreement tracking system to facilitate more timely access to telework agreement data. As of October 2019, Labor is developing a telework tracking application to improve access to telework data and the quality of telework data reported by its agencies. It is projected this tracking application will be launched as part of a broader internal web-based collaborative platform in FY 2021. When we confirm that Labor has fully completed these actions, we will provide updated information.

Recommendation: To provide additional guidance to agencies and encourage the elimination of barriers to increased telework opportunities consistent with the act, and to ensure the accuracy of telework information OPM annually reports to Congress, the Director of OPM should strengthen controls for reviewing, validating, and reporting telework data in annual Status of Telework in the Federal Government reports. Specifically, OPM should follow up with agency officials on data outliers, including significant changes in year-to-year data.

Agency: Office of Personnel Management
Status: Open

Comments: In a letter dated May 16, 2017, the acting director stated that OPM did not agree with the recommendation. While OPM recognizes the importance of data accuracy to effectively evaluate federal telework programs, OPM does not agree that the Telework Enhancement Act imposes any obligation on OPM to allocate significant resources necessary to validate telework data collected from agencies or that a year-over-year comparison of survey data is needed or advantageous to ensuring a reasonable and rigorous data analysis. We agree that OPM should not independently validate agency data, but OPM should take the steps necessary to identify and explain data outliers and limitations. Because OPM is the agency responsible for reporting telework data, OPM should ensure its annual reports to Congress include a clear discussion of data reliability limitations. Following up on data outliers and large year-to-year changes can help OPM identify data errors that could be corrected by agencies and provide OPM with the opportunity to discuss data limitations with agencies. Including such information clearly in the annual telework reports to Congress can make them more useful to Congress and to others. As of January 2020, OPM has not taken action on this recommendation. If we confirm that OPM does take action in response to this recommendation, we will provide updated information.

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

Agency: Department of Agriculture
Status: Open
Priority recommendation

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

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

Agency: Department of Agriculture
Status: Open
Priority recommendation

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

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

Agency: Department of Agriculture
Status: Open

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

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

Agency: Department of Agriculture
Status: Open
Priority recommendation

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

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

Agency: Department of Agriculture
Status: Open
Priority recommendation

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

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

Agency: Department of Agriculture
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

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

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The D.C. Mayor should direct the Deputy Mayor for Education and the Office of the State Superintendent of Education to deepen collaboration with PCSB and other relevant stakeholders, such as charter school local educational agencies, to develop a coordinated plan to continue progress in reducing discipline rates and, as part of this process, make explicit their respective roles, responsibilities, and authorities with regard to discipline in D.C. charter schools. This plan could include developing additional guidance, training, or resources, consistent with the unique autonomy of charter schools.

Agency: District of Columbia: Executive Office of the Mayor
Status: Open

Comments: In 2017, D.C. education officials stated they planned to continue to deepening their collaboration to reduce disciple rates. In May 2018, the D.C. Council passed the Student Fair Access to School Amendment Act of 2018 which, among other things, directs the Office of the State Superintendent of Education to provide schools (including charters) with a variety of supports and assistance on discipline and trauma-informed programs. We have reached out to OSSE and the Deputy Mayor's office for updates on implementation of the law and any additional collaboration. As of June 2020, we are awaiting a response.

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

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

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

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

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

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

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

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

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

Agency: Department of Defense
Status: Open
Priority recommendation

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

Recommendation: 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: In order to help ensure that DOD and the military departments are providing timely and consistent information on privately financed construction projects to Congress under DOD Instruction 7700.18, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness--in collaboration with any other relevant DOD stakeholders--to identify the categories of privately financed construction projects, including gifts of major construction, that should be reported through the process outlined in DOD Instruction 7700.18; revise DOD Instruction 7700.18 and any other related policies, as appropriate, to clarify which project types are to be included in and excluded from this reporting process; and require that the military departments update their relevant policies to incorporate the revised policy.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation, and stated that it will make clarifications in the next revision of DOD Instruction 7700.18 to clarify the types of privately financed major construction projects that should be reported through the process outlined in the instruction. In July 2020 an official from the Office of the Deputy Assistant Secretary of Defense (Military Community and Family Policy) said that DOD had completed a draft update of the instruction that included language implementing GAO's recommendation. The official also stated that DOD Instruction 7700.18 is interrelated with other DOD guidance which is also being updated. DOD plans to complete the updates to all the relevant policies by June 2021.

Recommendation: In order to ensure that Congress receives all desired information on all gifts of major construction in a timely manner, the Secretary of Defense--in collaboration with any other relevant DOD stakeholders--should identify the lead organization(s) within DOD that will be responsible for developing DOD-wide policy for reporting gifts of major construction that are not reported through the process outlined in DOD Instruction 7700.18, as appropriate.

Agency: Department of Defense
Status: Open

Comments: DOD did not concur with this recommendation, stating that there was already an official, the Under Secretary of Defense for Acquisition, Technology, and Logistics, responsible for developing policies related to gifts of real property, including major construction. However, DOD has not formally assigned responsibility to the Under Secretary (now the Under Secretary for Acquisition and Sustainment) for developing DOD-wide policy on reporting gifts of major construction not covered by the process outlined in DOD Instruction 7700.18. As of July 2020, the department had not taken action to address this recommendation, according to a representative of the Office of the Under Secretary of Defense for Acquisition and Sustainment.

Recommendation: In order to ensure that Congress receives all desired information on all gifts of major construction in a timely manner, the Secretary of Defense--in collaboration with any other relevant DOD stakeholders--should establish DOD-wide policy, as appropriate, on congressional notification of gifts of major construction to cover all such gifts that are not to be reported to Congress through the process outlined in DOD Instruction 7700.18, and require that the military departments update their gift acceptance policies--and any other relevant policies--to incorporate procedures to support DOD's notification requirements.

Agency: Department of Defense
Status: Open

Comments: DOD did not concur with this recommendation, stating that Congress has provided a statutory framework for the department to accept gifts, including gifts of construction, without stipulating any reporting requirements. However, this is inconsistent with DOD Instruction 7700.18, which states that construction projects funded by donations are subject to reporting to Congress. The military departments have been accepting gifts of major construction and reporting some of them to Congress while not reporting others. If DOD does not take action to clarify its policy on reporting such gifts, Congress is likely to continue receiving inconsistent and incomplete information, and to lack an explanation of the scope of the information it is receiving. This in turn may impair Congressional oversight over such projects and their potential effects on future maintenance funding requirements since some projects will not be brought to Congress' attention. As of July 2020, the department had not taken action to address this recommendation, according to a representative of the Office of the Under Secretary of Defense for Acquisition and Sustainment.

Recommendation: To provide additional information for congressional decision makers regarding DOD's budget, the Secretary of Defense should direct the Under Secretary of Defense (Comptroller), in consultation with the OMB, to reevaluate and revise the criteria for determining what can be included in DOD's OCO budget requests to reflect current OCO-related activities and relevant budget policy directing in which budget requests OCO funds may be included.

Agency: Department of Defense
Status: Open

Comments: In DOD's response to a draft of our report, DOD concurred with our recommendation and stated it planned to propose updated criteria to OMB to reflect current and evolving threats and reflect any changes in OCO policy under the new Administration. In October 2017, a DOD official stated that the department has discussed possible modifications to the criteria with the military departments and combatant commands, but had not made any formal recommendations to the OMB to revise the criteria. In May 2020, DOD officials stated they had re-evaluated the criteria, and were considering modifications that would take into account mission, instead of location, but OMB did not accept the modifications. The National Defense Authorization Act for Fiscal Year 2018 included a provision requiring DOD and OMB to update their OCO criteria by September 2018. As of May 2020, neither DOD nor OMB has issued updated criteria, and DOD had not made any updates to Volume 12, Chapter 23 of its Financial Management Regulation that governs contingency operations to reflect updated criteria.

Recommendation: To improve the collection of complete and consistent personal care services data and better ensure CMS can effectively monitor the states' provision of and spending on Medicaid personal care services, CMS should better ensure that personal care services data collected from states through T-MSIS and MBES comply with CMS reporting requirements.

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

Comments: The Centers for Medicare & Medicaid Services (CMS) concurs with GAO's recommendation. In December 2017, CMS cited ongoing efforts related to claims data submitted by states through T-MSIS, CMS's new claims reporting system. Efforts included validation checks of personal care service claims to ensure that key data are not missing or incorrect. In addition, CMS stated it was working with the states to address concerns that are identified with the quality of claims data submitted. However, as of March 2020, CMS had not reported that it had addressed inaccurate state reporting of expenditures through CMS's expenditure reporting system, Medicaid Budget and Expenditure System (MBES). Complete implementation of the recommended action will better ensure state reporting of claims and expenditures is accurate and will allow CMS to effectively perform key management functions.

Recommendation: To improve the collection of complete and consistent personal care services data and better ensure CMS can effectively monitor the states' provision of and spending on Medicaid personal care services, CMS should develop plans for analyzing and using personal care services data for program management and oversight.

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

Comments: The Centers for Medicare & Medicaid Services (CMS) concurred with this recommendation. However, as of March 2020, CMS had not developed a plan for analyzing and using personal care services data as GAO recommended in January 2017. Developing a plan for analyzing and using personal care services data for program management and oversight is an important step CMS needs to take to improve the oversight and management of personal care services.

Recommendation: To improve oversight of states' payment structures for MLTSS, the Administrator of CMS should require all states to collect and report on progress toward achieving MLTSS program goals, such as whether the program enhances the provision of community-based care.

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

Comments: As of June 2020, CMS has not informed us of any additional actions taken to implement this recommendation. CMS previously reported that it is working to develop guidance on how states report on progress towards achieving MLTSS program goals, such as the extent to which the program enhances the provision of community-based care. CMS has contracted with a vendor to produce recommendations for what would be included in the state reporting. We will update the status of this recommendation when we receive additional information.

Recommendation: To improve oversight of states' payment structures for MLTSS, the Administrator of CMS should establish criteria for what situations would warrant exceptions to the federal standards that the data used to set rates be no older than the three most recent and complete years.

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

Comments: As of June 2020, CMS has not informed us of any additional actions taken to implement this recommendation. CMS previously reported that it has monitored rate certifications and the data used for rating periods starting on or after July 1, 2017. CMS said that it has not had any states set rates that do not meet the federal standards for the data being no older than the three most recent and complete years and, therefore, does not believe that it should publish guidance on what situations would warrant exceptions. In order to better determine whether there is a need for such guidance, we believe that CMS should continue to monitor rate certifications and assess the data being used, particularly as additional states are developing or considering implementation of MLTSS programs. We will update the status of this recommendation as CMS conducts reviews of other states' payment structures and data used to establish them.

Recommendation: To improve oversight of states' payment structures for MLTSS, the Administrator of CMS should provide states with guidance that includes minimum standards for encounter data validation procedures.

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

Comments: As of June 2020, CMS has not informed us of any additional actions taken to implement this recommendation. CMS previously reported to GAO that it has convened a workgroup to develop an Encounter Data Toolkit, which will provide best practices for encounter data submissions and validation procedures. The workgroup is also discussing minimum standards for states to determine if the encounter data are complete and accurate for purposes of rate setting. The workgroup met in June and July 2018, and two additional workgroup meeting are planned prior to the drafting of the toolkit. We will update the status of this recommendation when we receive additional information.

Recommendation: To assist IRA owners in addressing challenges associated with investing their retirement savings in unconventional assets, the Commissioner of Internal Revenue should provide guidance to IRA owners and custodians on how to determine and document fair market value (FMV) for certain categories of hard-to-value unconventional assets. For example, IRS could consider updating Form 5498 instructions to custodians on how to document FMV for hard-to-value assets (e.g., last-known FMV based on independent appraisal, acquisition price) and provide guidance directed at account owners that provides examples of how to ascertain FMV for different types of unconventional assets.

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

Comments: IRS agreed that guidance should be provided to IRA owners and custodians. In 2018, IRS stated that it had discussed this issue with Counsel and Treasury, and it was agreed that fair market value would be a part of the IRA guidance project under the 2017 Priority Guidance Plan. IRS officials said that these new regulations would address FMV for certain categories of hard-to-value unconventional assets. IRS further noted that it would be premature to modify instructions and guidance to custodians on how to determine and document FMV for hard-to- value assets until the new regulations are issued. In their October 2019 update of planned guidance projects, Treasury's Office of Tax Policy and IRS still listed planned IRA regulations. GAO will not close this recommendation as implemented until the new valuation guidance is issued.

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 enhance program oversight and provide more robust input to budget deliberations, Congress should consider requiring DOD to report on each major acquisition program's systems engineering status in the department's annual budget request, beginning with the budget requesting funds to start development. The information could be presented on a simple timeline--as done for the case studies in this report--and at a minimum should reflect the status of a program's functional and allocated baselines as contained in the most current version of the program's systems engineering plan.

Agency: Congress
Status: Open

Comments: As of August 2020, Congress has not yet taken action on the matter for consideration. The Department of Defense (DOD) non-concurred and as of March 16, 2018, DOD officials reported they had closed this recommendation because they did not agree that the systems engineering plan was the most effective means to provide Congress insight into program risk. DOD officials stated that the timing of the systems engineering plan and any updates are not aligned to inform a budget decision that could occur as much as 18 months prior to program initiation; and existing statutory certifications and reports, such as 2366a and 2366b requirements, submitted to Congress contain adequate information regarding program risk and technical maturity. GAO initiated work in 2020 to examine recent congressionally mandated changes in DOD's acquisition and requirements processes and will assess whether those changes meet the intent of this recommendation.

Recommendation: To improve the management of DOD's credentialing program and better determine whether the program is achieving its desired results, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness to develop and implement program performance measures that include key attributes, such as a baseline and goals, that can be used to assess performance.

Agency: Department of Defense
Status: Open

Comments: DOD did not concur with our recommendation to develop and implement performance measures for its credentialing program. In its response to the recommendation, DOD stated that servicemembers are not required to earn credentials and more than half of the credentials earned by servicemembers are voluntary. Therefore, establishing criteria that might create an incentive to force servicemembers into earning voluntary credentials would be counterproductive. DOD also stated that a basic reporting system is in place that captures credential attainment and associated costs that provides basic information to gauge the program's performance. As of April 2020, the department still does not plan to develop performance measures for the program.

Recommendation: To provide agencies access to SSA's more complete set of death data, Congress should consider amending the Social Security Act to explicitly allow SSA to share its full death file with Treasury for use through the DNP working system.

Agency: Congress
Status: Open

Comments: In fiscal year 2020, the Senate passed S.4104, which included language to address the recommendation. In the context of the Do Not Pay (DNP) working system, the bill, if enacted, would authorize comparison of the Social Security Administration's (SSA) full death file with personally identifiable information reviewed through the working system and would allow redisclosure of such comparison of information to any federal or state agency authorized to use the working system. As of July 15, 2020, the House has not introduced a related bill for fiscal year 2020. Additionally, in February 2020, the administration released its President's 2021 Budget, which proposes legislation to allow the DNP Business Center full access to the SSA full death file. This proposal would include the Department of the Treasury and the SSA working together to determine the most efficient manner to make full death information available for use in preventing improper payment and fraud. We will continue to monitor congressional legislation to address this recommendation. .

Recommendation: To better monitor agency use of the DNP working system once a strategy has been developed, the Director of OMB should develop and implement monitoring mechanisms--such as goals, benchmarks, and performance measures--to evaluate agency use of the DNP working system.

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

Comments: OMB agreed with the concept of monitoring mechanisms and will continue to work with agencies to reduce improper payments and encourage agencies to establish goals to improve payment accuracy that will be monitored and evaluated by OMB. In fiscal year 2019, OMB provided us a status update on July 31, 2019, stating that Treasury does this monitoring and reports updates to OMB on a quarterly basis and that monitoring will occur in conjunction with the President's Management Agenda. In August 2020, Treasury provided us examples of reports that it provides to OMB to assist OMB with evaluating agency use of the DNP working system. We plan to meet with OMB to discuss how it uses these reports and will continue to monitor OMB's actions to address this recommendation.

Recommendation: To reasonably assure that agency-reported information on use of the DNP working system is reliable, the Director of OMB should develop a process for comparing agency reporting on the use of the DNP working system to available sources, such as OMB guidance and DNP working system adjudication reports.

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

Comments: The Office of Management and Budget (OMB) agreed with the concept of ensuring that data are reliable and will consider the feasibility of a process to compare agency submissions to available sources to reasonably assure that agency-reported information on use of the Do Not Pay working system is reliable. OMB provided us a status update on July 1, 2019, stating that OMB will work with Treasury to determine feasibility of doing this review and establishing a process during fiscal year 2019. As of February 2020, OMB has not provided any new status updates for this recommendation. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: To reasonably assure that agency-reported information on use of the DNP working system is complete, the Director of OMB should revise its guidance to clarify whether agencies should report on their uses of all of the functionalities of the DNP working system in their agency financial reports.

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

Comments: The Office of Management and Budget (OMB) agreed with ensuring the completeness of data and will continue to work with agencies and the Chief Financial Officer community to ensure that agency-reported information on the use of the Do Not Pay (DNP) working system is complete. In fiscal year 2019, OMB provided us a status update on July 1, 2019, stating that this recommendation was addressed in OMB's Circular A-136. Additionally, we met with OMB officials on July 31, 2019. During the meeting, OMB officials informed us that the OMB Circular A-136, Section II.4.5 (bullet 3) (dated June 28, 2019) states that "Agencies should provide a brief narrative of the reduction in improper payments that is attributable to the DNP Initiative, as applicable. See OMB Circular A-123, Appendix C, Part V for a thorough overview of the roles and responsibilities of agencies to use centralized data sources such as the Treasury Working System and other government databases to prevent improper payments." We have reviewed OMB Circular A-136 and confirmed that the circular does contain the statements above. However, we do not believe that the OMB Circular A-136 meets the intent of our recommendation. GAO issued its recommendation, in part, because GAO found that OMB guidance does not indicate whether agencies should report on all uses of the DNP working system, including those outside payment integration that the DNP working system does not track. For this reason, GAO report concluded that without complete and reliable data and clear guidance on what information agencies should report, OMB cannot effectively monitor and evaluate the use of the DNP working system. Therefore, we do not believe that the OMB Circular A-136 sufficiently clarifies whether agencies should report on their uses of all of the functionalities of the DNP working system in their agency financial reports. As of February 2020, OMB has not provided any new status updates for this recommendation. We will continue to monitor OMB's actions to address this recommendation.

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: To provide greater transparency in the reporting of FOIA litigation costs, Congress could consider requiring Justice to provide a cost estimate for collecting and reporting information on costs incurred when defending lawsuits in which the plaintiffs prevailed.

Agency: Congress
Status: Open

Comments: As of February 2020, Congress has not yet considered if it plans to amend FOIA regarding the reporting of costs for defending lawsuits in which the plaintiffs prevailed.

Recommendation: Congress could consider amending the act to require Justice to reflect in its Litigation and Compliance reports, changes in the award of attorneys' fees and costs resulting from the appeals process and settlement agreements between agencies and plaintiffs, if deemed to be cost-effective.

Agency: Congress
Status: Open

Comments: As of February 2020, Congress has not yet considered if it plans to amend FOIA to require Justice to make changes to its Litigation and Compliance reports.

Recommendation: To improve the accessibility and reliability of SNF expenditure data, the Acting Administrator of CMS should take steps to improve the accessibility of SNF expenditure data, making it easier for public stakeholders to locate and use the data.

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

Comments: In September 2016, GAO recommended that CMS improve the accessibility and reliability of SNF expenditure data, thereby making it easier for public stakeholders to locate and use the data. The agency concurred with this recommendation in 2016 and stated that it would review the feasibility of increasing the accessibility of this data. However, in August 2017, HHS told GAO that it now believes that the cost of implementing this recommendation would outweigh its benefits. HHS confirmed in July 2019 that its position on this recommendation has not changed. GAO continues to hold that data on SNFs' relative expenditures should be readily accessible to the public to ensure transparency in SNF expenditures.

Recommendation: To improve the accessibility and reliability of SNF expenditure data, the Acting Administrator of CMS should take steps to ensure the accuracy and completeness of SNF expenditure data.

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

Comments: In September 2016, GAO recommended that CMS take steps to ensure the accuracy and completeness of SNF expenditure data. However, the agency did not concur with this recommendation. HHS reported in 2016 that the amount of time and resources to verify the accuracy and completeness of SNF expenditure data could be substantial, without assurance of benefit to the agency and the public. However, during the course of our work, GAO found that CMS uses this expenditure data to update overall SNF payment rates, in addition to more general purposes. GAO continues to believe that CMS should take steps to ensure reliable expenditure data are accurate and complete. As of July 2019, the agency continues to non-concur with this 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 the certification of adequate incremental development, the Secretaries of Defense, Education, Health and Human Services, and the Treasury should direct their CIOs to establish a department policy and process for the certification of major IT investments' adequate use of incremental development, in accordance with OMB's guidance on the implementation of the Federal Information Technology Acquisition Reform Act.

Agency: Department of Health and Human Services
Status: Open

Comments: The Department of Health and Human Services (HHS) concurred with our recommendation and has taken steps to establish a department policy and process for the certification of major IT investments' use of incremental development. Specifically, in September 2020, HHS officials reported that they have established a draft policy and anticipate publishing the finalized guidance by March 2021. We will continue to evaluate HHS's progress in implementing this recommendation.

Recommendation: To improve the certification of adequate incremental development, the Secretaries of Defense, Education, Health and Human Services, and the Treasury should direct their CIOs to establish a department policy and process for the certification of major IT investments' adequate use of incremental development, in accordance with OMB's guidance on the implementation of the Federal Information Technology Acquisition Reform Act.

Agency: Department of the Treasury
Status: Open

Comments: In September 2020, an official from the Department of the Treasury (Treasury) reported that the department had developed draft guidance to address our recommendation, but did not provide time frames for when the guidance would be finalized. Until the department establishes a CIO certification policy, Treasury will not be able to fully ensure adequate implement of, or benefit from, incremental development practices. We will continue to evaluate Treasury's progress in implementing this recommendation.

Recommendation: The EPA Administrator should direct the Office of Grants and Debarment (OGD) and program and regional offices, as appropriate, as part of EPA's ongoing streamlining initiatives and the development of a grantee portal, to incorporate expanded search capability features, such as keyword searches, into its proposed web-based portal for collecting and accessing performance reports to improve their accessibility.

Agency: Environmental Protection Agency
Status: Open

Comments: In correspondence to GAO, EPA reiterated its agreement with this recommendation. EPA also stated that its vision for grants management includes having grant recipients submit performance reports and other information to the agency through a web-based portal. The portal would incorporate capabilities such as key word searches to allow for easier access to performance report information. EPA expected this recommendation to be addressed by its new grants management system (GrantsSolutions). However, in January 2020, EPA officials told us that EPA had ceased its migration to GrantSolutions after determining the long-term costs were unsustainable and that the system lacked fundamental functionality necessary for core grant operations and to maintain appropriate internal controls. EPA is now migrating towards a modernized grants administration and management cloud solution. EPA expects this recommendation to be addressed when the new grants management system is fully implemented. EPA anticipates deployment of the new cloud solution in December 2020.

Recommendation: The EPA Administrator should direct OGD and program and regional offices, as appropriate, as part of EPA's ongoing streamlining initiatives and the development of a grantee portal, once EPA's new performance system is in place, to ensure that the Office of Water adopts software tools, as appropriate, to electronically transfer relevant data on program results from program-specific databases to EPA's national performance system.

Agency: Environmental Protection Agency
Status: Open

Comments: In correspondence to GAO, EPA reiterated its general agreement with this recommendation and stated that it will apply it, where appropriate and cost effective, to program-specific databases, not only the Office of Water databases. EPA noted that not all data from program-specific databases may be appropriate for direct electronic transfer to the national performance system; some individual grant data may need to be analyzed before being rolled up into national data. As of December 2018, EPA officials said that continued work on this recommendation is dependent upon EPA's Office of the Chief Financial Officer's deployment of a new performance tracking system and individual program funds for developing systems that interact with it. As of April 2020, GAO is following up with EPA on the status of this recommendation.

Recommendation: The EPA Administrator should direct OGD and program and regional offices, as appropriate, as part of EPA's ongoing streamlining initiatives and the development of a grantee portal, to clarify the factors project officers should consider when determining whether performance reports are consistent with EPA's environmental results directive.

Agency: Environmental Protection Agency
Status: Open

Comments: In correspondence to GAO, EPA reiterated its agreement with this recommendation and stated that it will make conforming changes to the implementation guidance for the Environmental Results Order (directive). In December 2018, EPA stated that its existing environmental results directive may be superseded or incorporated into a different policy as part of the agency's migration to a new grants management system (GrantsSolutions). EPA stated that it would incorporate the recommendation into its new policy. However, in January 2020, EPA officials told us that EPA had ceased its migration to GrantSolutions after determining the long-term costs were unsustainable and that the system lacked fundamental functionality necessary for core grant operations and to maintain appropriate internal controls. EPA is now migrating towards a modernized grants administration and management cloud solution. EPA expects this recommendation to be addressed when the new grants management system is fully implemented. EPA anticipates deployment of the new cloud solution in December 2020.

Recommendation: The EPA Administrator should direct OGD and program and regional offices, as appropriate, as part of EPA's ongoing streamlining initiatives and the development of a grantee portal, to expand aspects of EPA's policy for certain categorical grants, specifically, the call for an explicit reference to the planned results in grantees' work plans and their projected time frames for completion, to all grants.

Agency: Environmental Protection Agency
Status: Open

Comments: In correspondence to GAO, EPA reiterated its agreement with this recommendation and stated that it will make conforming changes to existing policy. In December 2018, EPA stated that its existing policies may be superseded or incorporated into different policies as part of the agency's migration to a new grants management system (GrantsSolutions). EPA stated that it would incorporate the recommendation into its new policy. However, in January 2020, EPA officials told us that EPA had ceased its migration to GrantSolutions after determining the long-term costs were unsustainable and that the system lacked fundamental functionality necessary for core grant operations and to maintain appropriate internal controls. EPA is now migrating towards a modernized grants administration and management cloud solution. EPA expects this recommendation to be addressed when the new grants management system is fully implemented. EPA anticipates deployment of the new cloud solution in December 2020.

Recommendation: The EPA Administrator should direct OGD and program and regional offices, as appropriate, as part of EPA's ongoing streamlining initiatives and the development of a grantee portal, to incorporate built-in data quality controls for performance reports into the planned web-based portal based on EPA's environmental results directive.

Agency: Environmental Protection Agency
Status: Open

Comments: In correspondence to GAO, EPA reiterated its general agreement with this recommendation. However, EPA emphasized that identifying and deploying appropriate data quality controls is a long-term effort subject to budgetary considerations, completion of its new grants management system, and extensive collaboration with internal and external stakeholders. EPA officials said that the agency expected this recommendation to be addressed by its new grants management system (GrantsSolutions). However, in January 2020, EPA officials told us that EPA had ceased its migration to GrantSolutions after determining the long-term costs were unsustainable and that the system lacked fundamental functionality necessary for core grant operations and to maintain appropriate internal controls. EPA is now migrating towards a modernized grants administration and management cloud solution. EPA expects this recommendation to be addressed when the new grants management system is fully implemented. EPA anticipates deployment of the new cloud solution in December 2020.

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 help improve reporting of emissions data on the OGOR, the Secretary of the Interior should direct BLM to provide additional guidance on how to estimate natural gas emissions from federal oil and gas leases.

Agency: Department of the Interior
Status: Open

Comments: In November 2018, BLM's "Waste Prevention, Production Subject to Royalties, and Resource Conservation; Rescission or Revision of Certain Requirements" rule (43 C.F.R. 3179.301) took effect, revising the 2016 rule. According to BLM in July 2020, the revision satisfies the intent of the recommendation because the rule specifies the acceptable means of estimation or measurement of vented or flared gas. The rule says the operator may estimate or measure vented gas in accordance with applicable state or tribal regulatory agency rules or regulations, estimate using the gas to oil ratio (GOR) test (which, during GAO's review, some BLM officials said was not accurate), or to "measure" the volume of the flared gas. We do not believe the revised rule provides sufficient additional specificity on how natural gas emissions should be estimated by operators.

Recommendation: To help improve reporting of emissions data on the OGOR, the Secretary of the Interior should direct ONRR to provide additional guidance on how to differentiate between combusted and noncombusted lease use volumes reported on the OGOR, which could assist Interior in measuring its progress toward greenhouse gas reduction goals.

Agency: Department of the Interior
Status: Open

Comments: In July 2020, ONRR reported that it developed and implemented two disposition codes--one for the royalty-bearing flaring of gas and another for the royalty-bearing venting of gas volumes. ONRR did not develop additional disposition codes because, according to BLM, other disposition codes would not be required due to BLM's 2018 revision of the methane rule. However, we do not believe the measurement provisions in the revised methane rule contain any specific provisions requiring reporting for combusted and non-combusted lease use gas. Gas could be used on lease in pneumatic valves, which is released into the atmosphere as methane; or combusted to power up generators, where it's released as carbon dioxide. Knowing whether the emissions are in the form of methane or carbon dioxide is critical to helping Interior accurately estimate greenhouse gas emissions.

Recommendation: To help the Department of Health and Human Services ensure accuracy in Part B drug payment rates, Congress should consider requiring all manufacturers of Part B drugs paid at ASP, not only those with Medicaid drug rebate agreements, to submit sales price data to CMS, and ensure that CMS has authority to request source documentation to periodically validate all such data.

Agency: Congress
Status: Open

Comments: As of June 2020, no action has been taken on this Matter for Congressional Consideration.

Recommendation: CMS should periodically verify the sales price data submitted by a sample of drug manufacturers by requesting source documentation from manufacturers to corroborate the reported data, either directly or by working with the HHS Office of Inspector General as necessary.

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

Comments: In September 2018, HHS officials reiterated that they believe the agency has addressed our recommendation because CMS works with HHS's Office of Inspector General (OIG) as appropriate to collect source documentation from drug manufacturers and takes action as warranted. HHS stated that CMS has continued to provide information regarding problematic ASP submissions to OIG for evaluation of misreporting and continues to use AMP and other benchmarks as comparisons for pricing determinations. They further stated that they do not believe that additional collection of detailed sales information about ASP, such as invoices, is authorized under Part B drug payment provisions in section 1847A or under section 1927(b). As of June 2020, CMS did not provide any additional updates. While we recognize that CMS conducts routine checks to assess the completeness of ASP data submitted by drug manufacturers, we do not believe these activities are enough to close the recommendation. Specifically, CMS only collects source documentation from manufacturers under very limited circumstances (e.g., when there are obvious inconsistencies in the data submitted by manufacturers). CMS does not periodically verify the accuracy of ASP data for a sample of manufacturers by tracing the data to and from drug manufacturers' source documents, such as sales invoices. Because CMS does not routinely verify the accuracy of the underlying data used to determine Medicare payment rates, the resulting payment rates may be inaccurate if drug manufacturers do not report accurate data. With regards to CMS's authority to collect additional information, such as invoices, we believe the agency could work through OIG to collect such information.

Recommendation: To provide reasonable assurance that the property, equipment, and software transactions are properly tracked and capitalized or expensed as appropriate, the Director of CFPB should direct the program offices to require vendors to provide detailed invoices with costs broken out by project.

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: During our fiscal year 2019 audit, we continued to find control deficiencies over CFPB's accounting for its property, equipment, and software. CFPB was still in the process of working with its Office of Procurement and program offices to require more detailed invoices with costs broken out by project. We will continue to evaluate CFPB's actions to address this recommendation during our fiscal year 2020 financial statement audit.

Recommendation: To better ensure that the Dashboard ratings more accurately reflect risk, the Secretaries of the Departments of Agriculture, Education, Energy, Health and Human Services, the Interior, State, and Veterans Affairs; and the Director of the Office of Personnel Management should direct their CIOs to factor active risks into their IT Dashboard CIO ratings.

Agency: Department of Health and Human Services
Status: Open

Comments: The Department of Health and Human Services (HHS) agreed with the recommendation and, in a written response, stated that it updated its CIO evaluation methodology to measure active risks in areas such as budget variance, performance, policy and governance compliance, risk management, and contract risk. HHS submitted a draft version of this methodology in June 2018. Upon reviewing this documentation, however, we did not see evidence that the department was factoring active risks into its CIO ratings. In May 2019, HHS officials stated that they planned to update their CIO rating methodology to focus on active risk; however, department documentation from August 2020 stated that the new CIO rating methodology is still in draft form and is not finalized. We will continue to monitor HHS's efforts in implementing this recommendation.

Recommendation: To better ensure that the Dashboard ratings more accurately reflect risk, the Secretaries of the Departments of Agriculture, Education, Energy, Health and Human Services, the Interior, State, and Veterans Affairs; and the Director of the Office of Personnel Management should direct their CIOs to factor active risks into their IT Dashboard CIO ratings.

Agency: Department of Veterans Affairs
Status: Open

Comments: The Department of Veterans Affairs (VA) agreed with the recommendation and, in a written response, stated that the department was amending its CIO rating review process to ensure that active risks are factored into its IT Dashboard CIO ratings. In August 2020, VA submitted documentation for this new process; however, this documentation did not state how the department incorporates active risks into its investments' CIO ratings. We will continue to monitor the implementation of this recommendation.

Recommendation: To better ensure that the Dashboard ratings more accurately reflect risk, the Secretaries of the Departments of Agriculture, Education, Energy, Health and Human Services, the Interior, State, and Veterans Affairs; and the Director of the Office of Personnel Management should direct their CIOs to factor active risks into their IT Dashboard CIO ratings.

Agency: Department of State
Status: Open

Comments: The Department of State (State) agreed with the recommendation, and, in an October 2017 response, stated that it currently evaluates risk as part of its IT governance activities. In March 2019, State informed us that its Bureau of Information Resource Management was developing a new policy and associated guidance for calculating its CIO risk ratings; however, as of September 2020, we have not received this new documentation. We will continue to monitor the status of this recommendation.

Recommendation: To better ensure that the Dashboard ratings more accurately reflect risk, the Secretaries of the Departments of Agriculture, Commerce, Defense, Education, Energy, Health and Human Services, Homeland Security, State, Transportation, the Treasury, Veterans Affairs; the Administrator of the Environmental Protection Agency; and the Commissioner of the Social Security Administration should direct their CIOs to ensure that their CIO ratings reflect the level of risk facing an investment relative to that investment's ability to accomplish its goals.

Agency: Department of Health and Human Services
Status: Open

Comments: The Department of Health and Human Services (HHS) agreed with the recommendation and, in a written response, stated that it updated its CIO evaluation methodology to measure active risks in areas such as budget variance, performance, policy and governance compliance, risk management, and contract risk. According to HHS, these risk areas reflect both internal and external risks that affect an investment's ability to accomplish its goals. HHS submitted a draft version of this methodology in June 2018. While this documentation showed that HHS factored investment qualities related to overall project riskiness, it did not specify that active investment risks were also being factored as part of the evaluation. Without an additional focus on active risk, this methodology is unlikely to ensure that HHS's CIO ratings reflect the level of risk facing an investment. In May 2019, HHS officials stated that they planned to update their CIO rating methodology; however, per HHS documentation dated August 2020, this new methodology is still in draft form and is not finalized. We will continue to monitor HHS's efforts in implementing this recommendation.

Recommendation: To better ensure that the Dashboard ratings more accurately reflect risk, the Secretaries of the Departments of Agriculture, Commerce, Defense, Education, Energy, Health and Human Services, Homeland Security, State, Transportation, the Treasury, Veterans Affairs; the Administrator of the Environmental Protection Agency; and the Commissioner of the Social Security Administration should direct their CIOs to ensure that their CIO ratings reflect the level of risk facing an investment relative to that investment's ability to accomplish its goals.

Agency: Department of Veterans Affairs
Status: Open

Comments: The Department of Veterans Affairs (VA) agreed with the recommendation and, in a written response, stated that it will ensure that CIO ratings reflect the level of risk facing its investments. In August 2020, VA submitted documentation for an updated CIO ratings process; however, this process documentation did not state how the department incorporates active risks into its investments' CIO ratings. Without a consideration of active risks, VA's CIO rating process may not produce ratings that reflect the level of risk facing VA's investments. We will continue to monitor the status of this recommendation.

Recommendation: To better ensure that the Dashboard ratings more accurately reflect risk, the Secretaries of the Departments of Agriculture, Commerce, Defense, Education, Energy, Health and Human Services, Homeland Security, State, Transportation, the Treasury, Veterans Affairs; the Administrator of the Environmental Protection Agency; and the Commissioner of the Social Security Administration should direct their CIOs to ensure that their CIO ratings reflect the level of risk facing an investment relative to that investment's ability to accomplish its goals.

Agency: Department of State
Status: Open

Comments: The Department of State (State) agreed with the recommendation and has provided information on how investment risk is evaluated as part of its IT governance activities. In March 2019, State informed us that its Bureau of Information Resource Management was developing a new policy and associated guidance for calculating its CIO risk ratings; however, as of September 2020, we have not received this new documentation. We will continue to monitor the status of this recommendation.

Recommendation: The IRS Commissioner should direct the appropriate IRS officials to determine the reason(s) why staff did not always comply with IRS's established policies and procedures related to initiating, monitoring, and reviewing the monitoring of manual refunds and, based on this determination, establish a process to better enforce compliance with these requirements.

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

Comments: During fiscal year 2019, we identified instances where staff did not comply with IRS's policies and procedures related to monitoring and reviewing the monitoring of manual refunds. IRS officials stated that the Wage and Investment (W&I) organization determined that a fully automated process to perform monitoring of manual refunds is the optimal solution to address, at an enterprise level, deficiencies associated with reliance on employees to monitor refunds in process and take appropriate action when potential duplicate or erroneous refund conditions are encountered. In addition, IRS officials indicated that the W&I organization will develop business requirements and request programming through the Unified Work Request process; however, limited resources and competing priorities prevent the identification of an implementation date. As a result, IRS will place this recommendation on hold until an implementation date is known.

Recommendation: The IRS Commissioner should direct the appropriate IRS officials to identify the cause of and implement a solution for dealing with the periodic backlogs of ICO inventory that is hampering the performance of quality reviews.

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

Comments: During fiscal year 2019, the Wage and Investment (W&I) organization determined that periodic backlogs of Input Correction Operation (ICO) inventory were caused by a combination of factors, such as systemic issues, fluctuations in projected filings, and hiring challenges. IRS officials stated that the W&I organization has also identified and implemented several strategies to address ICO backlogs and mitigate the impact on the quality review program, including hiring more staff in ICO functions, using seasonal employees, cross-training, overtime, transferring of work, and updating the Internal Revenue Manual. Since IRS provided us with this information near the end of our fiscal year 2019 audit in September 2019, we will evaluate IRS's actions to address this recommendation during our fiscal year 2020 audit.

Recommendation: The IRS Commissioner should direct the appropriate officials to establish and implement monitoring procedures designed to reasonably assure that the key detailed information for tangible capitalized P&E is properly recorded and updated in the KISAM system.

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

Comments: IRS established the Asset Management Program Monitoring and Review procedure, effective October 1, 2016, for performing quarterly sample reviews of Information Technology (IT) assets in the Knowledge, Incident/Problem, Service Asset Management (KISAM) system. In September 2017, IRS also revised the Internal Revenue Manual to require Facilities Management and Security Services territory managers or section chiefs to review KISAM key data elements for non-IT assets to verify that they are correct and updated. However, during our fiscal year 2018 floor-to-book inventory testing, we identified exceptions where (1) a key detailed information element (e.g., building code) for property and equipment (P&E) assets was not properly recorded in KISAM and (2) P&E assets found on the floor did not have asset records in KISAM. We will conduct inventory testing and follow-up to determine the status of this issue during our audit of IRS's fiscal year 2020 financial statements.

Recommendation: To improve agency information security programs, Acting Director of the Office of Personnel Management should provide and track specialized training for all individuals, including contractors, who have significant security responsibilities.

Agency: Office of Personnel Management
Status: Open
Priority recommendation

Comments: OPM partially agreed with this recommendation. In December 2018, OPM stated that it is working with its learning management system vendor to develop requirements, but had not yet targeted an expected completion date. To fully implement the recommendation, OPM needs to complete its efforts to ensure that it provides and tracks training for individuals with significant security responsibilities. As of March 2020, OPM has not provided evidence that it has completed these actions.

Recommendation: To improve agency information security programs, the Secretary of the Department of Veterans should conduct security control assessments for the two selected systems and ensure the procedures comprehensively test technical controls.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA concurred with our recommendation. The agency has conducted security control assessments for the two systems, but these assessments did not show that technical controls were comprehensively tested. According to VA, the agency will complete the next security control assessment in October 2019 and complete the system assessment report in December 2019. As of March 2020, the agency has not provided evidence that it has implemented this recommendation. Subsequent to VA informing us that it has completed implementation, we plan to verify the agency's actions.

Recommendation: To improve security over federal systems, including those considered to be high impact, the Director of the Office of Management and Budget should issue plan and practices specified in the Cybersecurity Strategy and Implementation Plan.

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

Comments: OMB concurred with our recommendation. On December 9, 2016, OMB issued memorandum M-17-09, Management of Federal High Value Assets, which lists some existing policies and guidance and other actions that agencies need to take to protect IT assets. Further information is needed to validate implementation of the recommendation. As of March 2020, the agency has not provided evidence that it has implemented this recommendation. Subsequent to OMB informing us that it has completed implementation, we plan to verify the agency's actions.

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology and Logistics to establish a strategic policy that incorporates key elements of leading practices for sound strategic management planning, such as a mission statement and long-term goals, to inform the military services' plans for retrograde and reset to support overseas contingency operations and to improve DOD's response to section 324 of the NDAA for Fiscal Year 2014.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation in GAO-16-414. Although in its comments to that report DOD agreed that it should establish a strategic policy that incorporates key elements of leading practices for sound strategic management planning to inform the military services' plans for retrograde and reset to support overseas contingency operations, DOD did not agree with identifying the Under Secretary of Defense for Acquisition, Technology and Logistics as the lead for this recommendation. In our August 2018 update (GAO-18-621R) we found that DOD had not yet developed a strategic policy, had not yet determined which DOD organization would lead that effort, and that there was no consensus among officials we spoke with regarding which organization should lead that effort. In is comments to this update, DOD generally concurred with these findings and stated that it had established standardized terms and definitions for the services to use to assess the cost of contingency operations and that the Air Force had recommended OSD form a working group to develop a unified strategic implementation plan and standard terminology, to include a common operating picture. We agree that these are steps in the right direction, but until the department establishes a strategic policy for the retrograde and reset of equipment that incorporates key elements of leading practices for sound strategic management as we recommended in May 2016, it will not be positioned to effectively manage the retrograde and reset of equipment. As of September 2020, DOD has not taken any action to address this recommendation; DOD is in the process of determining who the appropriate PAO should be.

Recommendation: To enhance the accuracy of budget reporting to Congress, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology and Logistics, in coordination with the DOD Comptroller, to develop and require the use of consistent information and descriptions of key terms regarding retrograde and reset in relevant policy and other guidance.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation in GAO-16-414. In December 2017, DOD updated the relevant chapter of the its Financial Management Regulation (DOD 7000.14-R) to include definitions of "reset" and "retrograde." However, in our August 2018 update (GAO-18-621R) we found that despite this action, the terms retrograde and reset were not being used or defined consistently by the department and the military services. Specifically, while some services were using the term reset as defined in the regulation, others were not. In commenting on our 2018 update, DOD noted that the Under Secretary of Defense Comptroller had established standardized terms and definitions for the services to use to assess the cost of contingency operations, which allows for a common budget framework, while retaining service flexibility to fulfill their Title 10 responsibilities to man, train, and equip. DOD further stated that the Air Force recommended the Office of the Secretary of Defense form a working group to develop a unified strategic implementation plan and standard terminology, to include a common operating picture. We believe that these actions would be a step in the right direction, but to fully meet the intent of our May 2016 recommendation, DOD needs to take action to ensure that these terms are uniformly defined and consistently used throughout the services. As of September 2020, DOD has not taken any action to address this recommendation; DOD is in the process of determining who the appropriate PAO should be.

Recommendation: To improve Army, Navy, and Air Force planning, budgeting, and execution for retrograde and reset efforts, the Secretary of Defense should direct the Secretaries of the Army, Navy, and Air Force to develop service-specific implementation plans for retrograde and reset that incorporate elements of leading practices for sound strategic management planning, such as strategies that include how a goal will be achieved, how an organization will carry out its mission, and the resources required to meet goals.

Agency: Department of Defense
Status: Open

Comments: In its response to our recommendation in GAO-16-414, DOD partially concurred, stating that the department would determine the appropriate Principal Staff Assistant to lead the development and application of service-related implementation plans. However, in our August 2018 update (GAO-18-621R) we found that DOD had not yet identified a lead for this effort, and that the Army, Navy, and Air Force had not yet developed implementation plans for the retrograde and reset of their equipment. Navy and Air Force officials further cited the need for a DOD-wide policy before they can establish service-specific plans for resetting equipment for contingency operations while Army officials told us that the Army relies on multiple guidance documents for the reset of equipment and does not currently have plans to develop a unified reset implementation plan. In its response to GAO-18-621R, DOD notes that detailed guidelines and processes for the rotation of personnel in contingency and non-contingency operations are in place, and that if a strategic policy is developed for the retrograde and reset of equipment, consideration should be given to the Under Secretary of Defense (Acquisition and Sustainment) as the lead. We continue to believe that our recommendation remains valid and that DOD also needs to establish a strategic policy consistent with leading practices on sound strategic management planning to guide and inform the services' plans, as we also recommended in 2016. As of September 2020, DOD has not taken any action to address this recommendation; DOD is in the process of determining who the appropriate PAO should be.

Recommendation: As part of their ongoing efforts to strengthen oversight and improve the overall quality of information included in DOD's annual prepositioning reports in order to provide congressional decision makers with complete and relevant information, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology, and Logistics, in coordination with the Chairman of the Joint Chiefs of Staff, to disclose in the report the fact that reconstitution funding data are current as of the end of the fiscal year, identify significant changes reported in these data from year to year, and provide explanations as to the reasons for the changes.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with the recommendation. As of May 2020, DOD did state that the statutory requirement is for the department to provide information on the status of the prepositioned stocks as of the end of the fiscal year in its fiscal year 2019 prepositioning report, the most recent annual report. Also, DOD had an explanation that the reconstitution funding data may continue to be refined after the report's submission in the report. However, the report did not identify significant changes reported in the reconstitution data from year to year or provide explanations as to the reasons for the changes. In May 2020, DOD stated it would consider adding information in future reports about whether the reconstitution data changed and associated explanations. We will keep this recommendation open pending our review of the fiscal year 2020 prepositioning report.

Recommendation: As part of their ongoing efforts to strengthen oversight and improve the overall quality of information included in DOD's annual prepositioning reports in order to provide congressional decision makers with complete and relevant information, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology, and Logistics, in coordination with the Chairman of the Joint Chiefs of Staff, in its planned update to its War Reserve Materiel Policy document, to add language to clarify when and how risk assessments should be performed.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with the recommendation. At the time our report was issued, DOD stated that it would re-evaluate the need to perform risk assessments for prepositioned war reserve material during the update of DOD Instruction 3110.06 War Reserve Policy document, and that it will determine whether changes are needed in the Chairman of the Joint Chiefs of Staff risk assessment process. However, as of May 2020, DOD had not included information regarding when and how risk assessments should be performed in its DOD Instruction 3110.06 War Reserve Policy document, which it last revised in January 2019. Nor has DOD included this information in it Chairman of the Joint Chiefs of Staff Instruction 4310.10E, which it last revised in January 2020. In May 2020, DOD stated it would consider issuing a Guidance Memorandum--to supplement existing policy--that clarifies when and how risk assessments should be performed. We will continue to monitor DOD's efforts in this area.

Recommendation: As part of their ongoing efforts to strengthen oversight and improve the overall quality of information included in DOD's annual prepositioning reports in order to provide congressional decision makers with complete and relevant information, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology, and Logistics, in coordination with the Chairman of the Joint Chiefs of Staff, to include in the annual prepositioned stock report a section that identifies omitted prepositioned stock information and indicates where that information can be found.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. However, as of May 2020, DOD had no section that identifies omitted prepositioned stock information or indicates where that information can be found in its fiscal year 2019 prepositioning report, the most recent annual report.

Recommendation: To help improve the management of MAIS programs, the Secretary of the Navy should direct the Common Aviation Command and Control System program manager to identify weaknesses in the requirements traceability process and take corrective actions to manage the traceability of requirements to the respective lower-level requirements, and periodically evaluate work products, including the requirements management plan, and update them in accordance with the requirements guidance.

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

Comments: DOD concurred with this recommendation and stated in March 2016 that the Navy had corrected the data query issue that caused 11 requirements to be eliminated from the traceability matrix we reviewed. DOD also stated that the Navy had identified the weakness in the traceability process that led to 14 general requirements not being fully traced. However, as of June 2020, DOD had not provided us with documentation that supports that it identified the weakness in the requirements traceability process. It also had not demonstrated that the program office has updated its requirements management guidance to address the weakness it identified.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Agriculture should revise existing department policies for managing hazardous biological agents in high-containment laboratories to contain specific requirements for reporting laboratory incidents to senior department officials, including the types of incidents that should be reported, to whom, and when, or direct the Administrator of the Food Safety and Inspection Service to develop agency policies that contain these requirements.

Agency: Department of Agriculture
Status: Open

Comments: In October 2016, the United States Department of Agriculture (USDA) stated that its Joint Committee on Biorisk Management Policy (JCBMP) would oversee the revisions of existing policies to include department-wide incident reporting requirements and time frames. As of July 2020, USDA estimated that these revisions should be completed by October 2020. Officials stated that updates to component agency policies would be completed shortly after issuance of the departmental policy. We will update the status of this recommendation when we receive additional information.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Agriculture should review and update outdated department policies for managing hazardous biological agents in high-containment laboratories and direct the Administrators of the Animal and Plant Health Inspection Service (APHIS) and Agricultural Research Service to update their policies and, in the case of APHIS, establish a regular review schedule.

Agency: Department of Agriculture
Status: Open

Comments: In October 2016, USDA stated that the JCBMP would oversee the revisions of existing outdated departmental policies. In addition, officials stated that APHIS reviews and updates agency policies every 3-5 years, and that this schedule will be reflected in the updated departmental policy. In October 2019, the Agricultural Research Service (ARS) updated its agency policy for its institutional biological safety committee, the entity responsible for ensuring biosafety in its laboratories. As of July 2020, USDA estimated that revisions to the departmental, APHIS, and Food Safety and Inspection Service (FSIS) policies should be completed by December 2020. We will update the status of this recommendation when we receive additional information.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Agriculture should routinely analyze results of the department's laboratory inspections and incident reports to identify potential trends that may highlight recurring laboratory safety or security issues and share lessons learned with laboratory personnel.

Agency: Department of Agriculture
Status: Open

Comments: In October 2016, USDA stated that the JCBMP would oversee efforts to collect and analyze laboratory inspection results and incident reports and share these reports and critical analyses with USDA senior leadership on an annual basis. As of July 2020, USDA estimated that revisions to its departmental policy-which would reflect the JCBMP's role in analyzing inspection results and incident reports, identifying potential trends, and sharing lessons learned-should be completed by October 2020. We will update the status of this recommendation when we receive additional information.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Agriculture should require routine reporting of the results of department, agency, and select agent laboratory inspections to senior department officials.

Agency: Department of Agriculture
Status: Open

Comments: In October 2016, USDA stated that the JCBMP would oversee the revisions of existing policies to include requirements for routine reporting of inspection results to senior USDA officials. In July 2020, USDA estimated that these revisions should be completed by October 2020. We will update the status of this recommendation when we receive additional information.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Agriculture should require routine reporting of incidents at agency laboratories to senior department officials.

Agency: Department of Agriculture
Status: Open

Comments: In October 2016, USDA stated that the JCBMP would oversee the revisions of existing policies to include requirements for routine reporting of laboratory incidents to senior USDA officials. In July 2020, USDA estimated that these revisions should be completed by October 2020. Officials stated that updates to component agency policies would be completed shortly after issuance of the departmental policy. We will update the status of this recommendation when we receive additional information.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Defense should revise existing department policies for managing hazardous biological agents in high-containment laboratories to contain specific requirements for inventory control for all of DOD's high-containment laboratories, not just for its select agent-registered laboratories, or direct the Secretaries of the Air Force, Army, and Navy to revise their existing, respective policies to contain these requirements.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. In June 2018, DOD stated that it had completed evaluation of existing DOD and service level guidance related to inventory control. DOD also stated that it will continue to analyze the adequacy of existing policy and the need to expand that policy across the DOD Lab Enterprise as the draft Department of Defense Manual (DoDM) 6055.18 is finalized for publication. As of August 2019, DoD said the draft DoDM 6055.18 was still in review and the agency estimated it would complete work to respond to this recommendation in February 2020.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Defense should direct the Secretaries of the Air Force and Army to review and update their respective outdated policies for managing hazardous biological agents in high-containment laboratories.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. DOD stated that it had updated the Air Force policy (AF Instruction 10-2611-0) as of January 19, 2017; this document updates the biological safety standards used in AF labs and implements the draft update to Department of Defense Manual 6055.18M: Safety Standards for Microbiological and Biomedical Laboratories. As of July 2019, DOD provided GAO with the updated Army policy AR 190-17; however DOD officials stated that as the draft Department of Defense Manual (DoDM) 6055.18 was still undergoing review, this recommendation should remain open. DOD estimated it would complete work to respond to this recommendation in February 2020.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Defense should require routine reporting of the results of Air Force, Army, and Navy inspections of non-select agent registered laboratories to senior department officials.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. In August 2019, DOD reported that the Air Force is planning to close its BSAT program by the summer of 2019 and planning was underway to move the Air Force BSAT inventory to another DOD BSAT facility. Additionally, the Army was revising its AR 385-10, which contains biosafety criteria unique to the Army, and estimated the revision would be completed by December 2019. Finally, the draft Department of Defense Manual (DoDM) 6055.18 was still undergoing review, and DOD estimated it would complete work to respond to this recommendation in February 2020.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Defense should require routine reporting of laboratory incidents at Air Force, Army, and Navy non-select agent registered laboratories to senior department officials.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. In August 2019, DOD reported that the Air Force is planning to close its BSAT program by the summer of 2019 and planning was underway to move the Air Force BSAT inventory to another DOD BSAT facility. Additionally, the Army was revising its AR 385-10, which contains biosafety criteria unique to the Army, to include a new mishap classification for biosafety mishaps to effect better reporting and analysis of these mishaps, and estimated the revision would be completed by December 2019. Finally, the draft Department of Defense Manual (DoDM) 6055.18 was still undergoing review, and DOD estimated it would complete work to respond to this recommendation in February 2020.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Defense should direct the Secretaries of the Army and Navy to require reporting of agency and select agent laboratory inspection results to senior agency officials.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. As of June 2018, DOD stated that the draft directive DODD 5101.XXE, which is expected to be published in October 2018, formally designates the Executive Agent Responsible Official for Biosafety and Biosecurity and will establish roles and responsibilities including a role for reporting inspection results. Further, DOD stated that all inspection results of a joint inspection team are provided to the Executive Agent Responsible Official, and that the joint inspection team was established in September 2016. As of September 2019, DOD officials had provided updated documentation regarding this recommendation, and GAO was reviewing these updates.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Health and Human Services should develop department policies for managing hazardous biological agents in high-containment laboratories that contain specific requirements for reporting laboratory incidents to senior department officials, including the types of incidents that should be reported, to whom, and when, or direct the Director of CDC and the Commissioner of FDA to incorporate these requirements into their respective policies.

Agency: Department of Health and Human Services
Status: Open

Comments: In August 2016, HHS reported that both CDC and FDA were working to incorporate incident reporting requirements and time frames into formal agency policies and practices but did not provide an anticipated completion date. In summer 2017, CDC and FDA reported that they were continuing to incorporate incident reporting, which includes all laboratory incidents, accidents, injuries, infections, and near-misses, into formal agency policies. In August 2019, FDA reported that it continues to work with the Biosafety and Biosecurity Coordinating Council to establish a process for the routine reporting of these results but had not yet completed its actions. As of September 2019 we had not received an update from HHS on the status of CDC's implementation of this recommendation.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Health and Human Services should develop department policies for managing hazardous biological agents in high-containment laboratories that contain specific requirements for training and inspections for all high-containment component agency laboratories and not just for their select-agent-registered laboratories; or direct the Director of CDC to provide these requirements in agency policies.

Agency: Department of Health and Human Services
Status: Open

Comments: In August 2016, HHS reported that CDC plans to revise its policies to include training and inspection requirements for inspections for all high-containment laboratories but did not provide an anticipated completion date. In June 2017, HHS reported that CDC was in the process of revising its formal policies to ensure they included requirements for training and inspections for all of the agency's high-containment laboratories but did not provide an anticipated completion date. In December 2017, HHS reported that CDC's policies were in the initial stages of the clearance process and anticipated they would be finalized in fall 2018. As of September 2019, HHS had not provided an update on the status of these policies.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Health and Human Services should require routine reporting of the results of agency and select agent laboratory inspections to senior department officials.

Agency: Department of Health and Human Services
Status: Open

Comments: In August 2016, HHS reported that CDC was working with FDA and NIH to establish a process for notifying HHS leadership of inspection results through the department's Biosafety and Biosecurity Coordinating Council. HHS did not provide us with an anticipated time frame for implementing this notification practice or when the agencies plan to begin notifying HHS of inspection results. In August 2019, FDA reported that it continues to work with the Biosafety and Biosecurity Coordinating Council to establish a process for the routine reporting of these results but had not yet completed its actions. As of September 2019, HHS had not provided an update on the status NIH's actions.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Health and Human Services should direct the Director of NIH and the Commissioner of FDA to require routine reporting of the results of agency laboratory inspections--and in the case of FDA, require routine reporting of select agent inspection results--to senior agency officials.

Agency: Department of Health and Human Services
Status: Open

Comments: In August 2016, HHS reported that NIH's ongoing practice is to report the results of external inspections to senior agency officials and, in May 2016, developed a standard operating procedure that outlines this reporting process. In March 2017, NIH officials provided assurance that its Division of Occupational Safety and Health provides NIH's intramural governing body with information about NIH's safety performance at least annually; officials further assured that this information includes the overall results of annual inspections (or audits, as NIH calls them) of all NIH laboratories and discussion of the top 10 most report safety infractions for the year. GAO considers NIH to have implemented the recommended action. GAO will close the overall recommendation once FDA has taken equivalent, appropriate action. As of August 2019, FDA reported that the agency began piloting a standardized agency-wide laboratory safety inspection checklist to ensure that all laboratories are inspected rigorously and consistently. As part of the pilot, all laboratories were to be inspected during the first 3 quarters of the calendar year. The agency said it planned to aggregate the results of the inspections, and trends and significant findings would be reported to FDA senior leadership in the fourth quarter of 2019. GAO will continue to monitor FDA's actions to implement this recommendation.

Recommendation: To ensure that federal departments and agencies have comprehensive and up-to-date policies and stronger oversight mechanisms in place for managing hazardous biological agents in high-containment laboratories and are fully addressing weaknesses identified after laboratory safety lapses, the Secretary of Health and Human Services should require routine reporting of incidents at CDC, FDA, and NIH laboratories to senior department officials.

Agency: Department of Health and Human Services
Status: Open

Comments: In August 2016, HHS reported that its Biosafety and Biosecurity Council was working to establish incident reporting requirements for CDC, FDA, and NIH but did not provide an anticipated completion date. HHS noted that NIH formally adopted a standard operating procedure that lays out the agency's requirements for reporting incidents to senior officials. In August 2019, FDA reported that it continues to work with the Biosafety and Biosecurity Coordinating Council to establish a process for the routine reporting of these results but had not yet completed its actions. As of September 2019, HHS had not provided an update on the status of NIH or CDC actions.

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

Agency: Congress
Status: Open

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

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

Agency: Congress
Status: Open

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

Recommendation: To ensure that senior leadership within the Office of the Secretary of Defense and the military departments are better positioned to make informed decisions regarding the volume and type of services that should be acquired over the future year defense program, the Secretaries of the Army, Navy, and Air Force should revise their programming guidance to collect information on how contracted services will be used to meet requirements beyond the budget year.

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

Comments: DOD partially concurred with our recommendation. In its response, the Department did not identify what action, if any, it planned to take to implement this recommendation, and noted the difficulties in accurately quantifying service contract requirements beyond the budget year. We maintain that collecting this information will assist the department in gaining insights into contracted service requirements and making more strategic decisions about the services it plans to acquire. In December 2019, DOD officials stated that DOD annually reviews requirements for services during program budget reviews and services requirements review boards. These officials noted, however, that the volatility of future program and budget cycles constrains the department's ability to accurately quantify contract service requirements beyond the budget year. We agree that the reviews identified by DOD have merit, but they do not provide senior leadership the visibility necessary to make informed decisions regarding the volume and type of services that should be acquired over the future year defense program. In August 2020, DOD officials stated the department is working to identify actions to address this recommendation. We will continue to monitor this recommendation and will provide updated information.

Recommendation: To ensure that senior leadership within the Office of the Secretary of Defense and the military departments are better positioned to make informed decisions regarding the volume and type of services that should be acquired over the future year defense program, the Secretaries of the Army, Navy, and Air Force should revise their programming guidance to collect information on how contracted services will be used to meet requirements beyond the budget year.

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

Comments: DOD partially concurred with our recommendation. In its response, the Department did not identify what action, if any, it planned to take to implement this recommendation, and noted the difficulties in accurately quantifying service contract requirements beyond the budget year. We maintain that collecting this information will assist the department in gaining insights into contracted service requirements and making more strategic decisions about the services it plans to acquire. In December 2019, DOD officials stated that DOD annually reviews requirements for services during program budget reviews and services requirements review boards. These officials noted, however, that the volatility of future program and budget cycles constrains the department's ability to accurately quantify contract service requirements beyond the budget year. We agree that the reviews identified by DOD have merit, but they do not provide senior leadership the visibility necessary to make informed decisions regarding the volume and type of services that should be acquired over the future year defense program. In August 2020, DOD officials stated the department is working to identify actions to address this recommendation. We will continue to monitor this recommendation and will provide updated information.

Recommendation: To ensure the military departments' efforts to integrate services into the programming process and senior service managers efforts to develop forecasts on service contract spending provide the department with consistent data, the Secretary of Defense should establish a mechanism, such as a working group of key stakeholders--which could include officials from the programming, budgeting and requirements communities as well as the senior services managers--to coordinate these efforts.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD partially concurred with our recommendation. In its response, DOD did not indicate any actions it planned to take to implement this recommendation, and instead noted a number of efforts intended to aid in the management and oversight of services acquisitions. We maintain that a coordinated approach is needed to ensure that collected data is consistent to inform DOD leadership on future contract spending. In December 2019, DOD officials stated that DOD annually reviews requirements for services during program budget reviews and services requirements review boards. These officials noted, however, that the volatility of future program and budget cycles constrains the department's ability to accurately quantify contract service requirements beyond the budget year. We agree that the reviews identified by DOD have merit, but they do not provide senior leadership the visibility necessary to make informed decisions regarding the volume and type of services that should be acquired over the future year defense program. In August 2020, DOD officials stated the department is working to identify actions to address this recommendation. We will continue to monitor this recommendation and will provide updated information.

Recommendation: To provide greater compliance with the GIDEP reporting requirement among the DOD components and their defense supplier-base, the Undersecretary of Defense for Acquisition, Technology and Logistics should establish mechanisms for department-wide oversight of defense agencies' compliance with the GIDEP reporting requirement.

Agency: Department of Defense: Office of the Secretary of Defense: Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics
Status: Open

Comments: In providing comments to this report DOD concurred with this recommendation but has not completed actions to implement it. DOD has drafted new combined DOD instruction and guidance that addresses the process of reporting suspected counterfeit parts to GIDEP. As of August 2020, the document is still in the process of being formally approved. DOD estimated that it could be approved in the first quarter of fiscal year 2021.

Recommendation: To provide greater compliance with the GIDEP reporting requirement among the DOD components and their defense supplier-base, the Undersecretary of Defense for Acquisition, Technology and Logistics should develop a standardized process for determining the level of evidence needed to report a part as suspect counterfeit in GIDEP, such as a tiered reporting structure in GIDEP that provides an indication of where the suspect part is in the process of being assessed.

Agency: Department of Defense: Office of the Secretary of Defense: Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics
Status: Open

Comments: In providing comments to this report DOD concurred with this recommendation but has not completed actions to implement it. DOD has drafted new combined DOD instruction and guidance that addresses the process of reporting suspected counterfeit parts to GIDEP. As of August 2020, the document is still in the process of being formally approved. DOD estimated that it could be approved in the first quarter of fiscal year 2021.

Recommendation: To provide greater compliance with the GIDEP reporting requirement among the DOD components and their defense supplier-base, the Undersecretary of Defense for Acquisition, Technology and Logistics should develop guidance for when access to GIDEP reports should be limited to only government users or made available to industry.

Agency: Department of Defense: Office of the Secretary of Defense: Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics
Status: Open

Comments: In providing comments to this report DOD concurred with this recommendation but has not completed actions to implement it. DOD has drafted new combined DOD instruction and guidance that addresses the process of reporting suspected counterfeit parts to GIDEP. As of August 2020, the document is still in the process of being formally approved. DOD estimated that it could be approved in the first quarter of fiscal year 2021.

Recommendation: To enhance and to promote more consistent oversight of efforts within the department to address the incidence of hazing, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness to regularly monitor the implementation of DOD's hazing policy by the military services.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its written comments on our report. In February 2018 DOD issued a policy on harassment prevention and response in the armed services that defined hazing as one form of harassment, and required each military department secretary to provide a plan to implement the policy. As of October 2020, DOD stated that it had assessed that the military services had fully implemented DOD's hazing policy by September 2020. This determination was based on an assessment of military service implementation plans for DOD's harassment prevention and response policy, which includes prevention of hazing. Through ongoing work on hazing in the military, we continue to monitor the extent to which DOD has regularly monitored the extent to which the military services have implemented its hazing policy.

Recommendation: To promote greater visibility over the extent of hazing in DOD to better inform DOD and military service actions to address hazing, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness, in collaboration with the Secretaries of the Military Departments, to evaluate prevalence of hazing in the military services.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in its written comments on our report. As of September 2017, DOD had added questions to its survey of servicemembers that would facilitate an evaluation of hazing prevalence but had not yet conducted the evaluation. In October 2020, DOD stated that it need to conduct additional analysis on its survey data and on a hazing/bullying metric developed for DOD by the RAND Corporation, and estimated it would implement this recommendation by October 2023.

Recommendation: To promote greater visibility over the extent of hazing in the Coast Guard to better inform actions to address hazing, the Commandant of the Coast Guard should evaluate the prevalence of hazing in the Coast Guard.

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

Comments: DHS concurred with this recommendation in its written comments on our report. In 2017 the Coast Guard surveyed servicemembers on hazing and stated that it planned to, but had not yet conducted an evaluation of prevalence. However, in July 2018, the Coast Guard stated that no further analysis was planned for the 2017 survey data. The Coast Guard stated that a second survey was planned for 2019, but did not identify any plans to evaluate the prevalence of hazing in the Coast Guard. As of October 2020, the Coast Guard has not provided a requested update on the status of the implementation of this recommendation or indicated any ongoing plans to implement it.

Recommendation: To help ensure that agencies report consistent and comparable data on federal spending, the Director of OMB, in collaboration with the Secretary of the Treasury, should provide agencies with additional guidance to address potential clarity, consistency, or quality issues with the definitions for specific data elements including Award Description and Primary Place of Performance and that they clearly document and communicate these actions to agencies providing this data as well as to end-users.

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

Comments: OMB has taken some actions to address this recommendation related to procurement awards, such as adopting a shorter character limit for the "Award Description" element and providing additional guidance for the "Primary Place of Performance" element. However, it needs to provide additional guidance for these data elements related to grant awards to ensure collection of consistent and comparable information.

Recommendation: To improve the consistency and completeness of Amtrak's financial reporting and to provide Congress with accurate information to make funding decisions, the President of Amtrak should ensure that Amtrak's depreciation expenses are appropriately allocated to its lines of business once the underlying capital asset data are determined reliable.

Agency: National Railroad Passenger Corporation
Status: Open

Comments: As of April 2020, Amtrak had not allocated its depreciation costs to its lines of business, as we recommended. In 2019, Amtrak stated that federal law required Amtrak to allocate and report its capital spending by line of business. Amtrak further stated that depreciation expense is a good proxy for capital spending and that the changed reporting requirements eliminated the need to report depreciation by line of business. In addition, although Amtrak's external auditor did not find any material weaknesses or significant deficiencies in Amtrak's fiscal year 2019 audited financial statement-the most recent available-those statements do not allocate Amtrak's depreciation costs to its various business lines. We will update this recommendation's status with any new information from Amtrak.

Recommendation: In addition, to better inform congressional decision making regarding the funding of Northeast Corridor infrastructure improvements, the Northeast Corridor Commission should work with its members to establish criteria for its members to use in selecting and prioritizing capital projects to be included in future editions of its 5-year capital plan.

Agency: Northeast Corridor Commission
Status: Open

Comments: As of April 2020, the Northeast Corridor (NEC) Commission and its members had yet to establish criteria for selecting and prioritizing capital projects in its 5-year capital plan. The Commission staff told GAO that it had developed potential criteria for selecting projects for both regional and NEC-wide priorities to be included the Northeast Corridor Capital Investment Plan, Fiscal Years 2020 - 2024, published in April 2019 and updated in December 2019. However, those potential criteria were not formally adopted by the Commission members. Specifically, the Commission's proposed criteria for selecting NEC-wide priorities included projects that would prevent the potential severing of the Northeast Corridor and advance state-of-good repair. Proposed criteria for regional priorities included projects that would increase train capacity and improve passenger access to rail services. While the proposed criteria were not used to select or prioritize projects in the Capital Investment Plan, Fiscal Years 2020 - 2024, the plan presented the proposed criteria as "benefits" for the projects in that plan. While this information may be helpful to stakeholders in understanding some of the rationale for the inclusion of projects in the plan, it does not demonstrate that the Commission and its members have established formal criteria for selecting and prioritizing projects, as GAO recommended. GAO will continue to monitor the Commission's progress in addressing this recommendation.

Recommendation: To better ensure agencies fulfill their requirements, including implementing IQA guidelines and helping to promote easier public access to IQA information on agency websites, the Director of OMB should consolidate and centralize on OMB's IQA guidance website a government-wide summary of requests for correction submitted under the IQA.

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

Comments: According to OMB, during the last two years OIRA has significantly improved the ease of access to and findability of documents on OMB's information quality website. OMB says it has a number of additional improvements in progress. We have requested information on those additional improvements. We will continue to monitor OMB's efforts related to this recommendation.

Recommendation: To better ensure agencies fulfill their requirements, including implementing IQA guidelines and helping to promote easier public access to IQA information on agency websites, the Director of OMB should work with the Department of Defense and the Federal Housing Finance Agency to help ensure that they post their IQA administrative mechanisms and IQA guidance online.

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

Comments: According to OMB, it worked with the Federal Housing Finance Agency (FHFA) to improve the accessibility of their Information Quality Act guidance. In addition, OMB stated that FHFA took it upon themselves to update their guidelines. OMB has not provided any information regarding its work with DOD in this area. We will continue to monitor OMB's efforts related to this recommendation.

Recommendation: To better ensure agencies fulfill their requirements, including implementing IQA guidelines and helping to promote easier public access to IQA information on agency websites, the Director of OMB should provide additional guidance for agencies to help improve the transparency and usability of their IQA websites to help ensure the public can easily find and access online information about agency IQA implementation. Such guidance should include (1) specific time frames for agencies to post information on the IQA correction requests they have received, including making it clear when agencies have not received IQA requests; (2) instructions for agencies to include a statement on their IQA websites that the agencies may address correction requests through other administrative processes; (3) instructions for agencies to include, when responding to correction requests, whether those agencies plan to address the request through another administrative processes, and if so, which process they will use; and (4) suggestions for improving usability of agencies' websites including fixing broken links.

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

Comments: According to OMB, in conjunction with its annual data call, the agency has and will continue to provide guidance to agencies about improving the transparency and usability of their websites, including the need to update broken links. In addition OMB issued M-19-15, designed to address a number of related and additional implementation concerns, including transparency and procedural improvements. OMB's guidance to date has not included specific items as specified in the recommendation. We will continue to monitor OMB's efforts related to this recommendation.

Recommendation: To improve the data on tracked safety issues and postmarket studies that are needed for required reporting and for systematic oversight of postmarket drug safety, the Secretary of HHS should direct the Commissioner of FDA to work with stakeholders within FDA to identify additional improvements that could be made to FDA's current database or future information technology investments to capture information in a form that can be easily and systematically used by staff for oversight purposes.

Agency: Department of Health and Human Services
Status: Open

Comments: FDA has made changes intended to improve its process for overseeing tracked safety issues, but as of August 2020, FDA was still working on changes to its process for postmarket study data. For tracked safety issues, FDA held a one-day workshop to solicit input from staff on changes to its tracked safety issue process and collect user requirements for a new IT system to support tracking safety issues. In April 2020, FDA finalized new policies and procedures and implemented a new IT system for tracking safety issues. The new IT system allows anyone within FDA's Center for Drug Evaluation and Research to enter new safety signals and has integrated product and adverse event dictionaries. FDA stated that integrating standardized data will support consistent regulatory decisions and improve the quality of analysis. For postmarket studies, FDA has indicated that it intends to formally assess the IT needs of users as part of the planned transfer of postmarket data to its new informatics platform. As of August 2020, FDA anticipated creating a project team to address specific concerns related to postmarket study data by the end of calendar year 2020 or the beginning of calendar year 2021. GAO is keeping this recommendation open until FDA has completed its planned improvements to its process for tracking postmarket study data.

Recommendation: To further ensure the effective screening of work reports, SSA should monitor its process for handling work reports to determine whether staff are taking action on work reports in accordance with proper procedures, and provide feedback to staff as needed.

Agency: Social Security Administration
Status: Open

Comments: SSA continues to disagree with this recommendation as of December 2019. As we reported, when SSA accepts a beneficiary's return to work allegation (work report), staff have 30 days to determine whether additional action is needed, such as a continuing disability review (CDR) to assess continued eligibility and determine whether benefits should be adjusted. However, not all work reports result in a CDR, and GAO reported that SSA lacks an oversight process to help determine whether work reports are not resulting in CDRs when they should. SSA continues to maintain that its staff carefully review work reports and make independent determinations on the need for a CDR. Absent an oversight process to ensure that work reports are properly screened, SSA may be missing opportunities to prevent overpayments for unreported work. SSA further reported that it may decide to complete a CDR through alternative approaches, such as its Continuing Disability Review Enforcement Operation process using Internal Revenue Service data, its Quarterly Earnings Project using Office of Child Support Enforcement data, or its analysis of electronically reported wages. However, SSA did not indicate whether these alternative avenues for conducting CDRs could identify errors made by its staff handling work reports and result in feedback. Implementing this recommendation will help ensure that SSA staff appropriately take action on work reports.

Recommendation: To enhance beneficiary understanding of work reporting requirements, SSA should: (a) Clarify work reporting requirements provided to beneficiaries. (b) Explore options for increasing the frequency of reporting reminders to DI beneficiaries, similar to those currently available to SSI recipients.

Agency: Social Security Administration
Status: Open

Comments: As of December 2019, SSA reported taking several steps to clarify work reporting requirements. For instance, SSA reported it has developed outreach materials to share information with beneficiaries and advocacy groups. However, SSA has not provided sufficient documentation for GAO to determine if it has clarified issues identified in GAO's 2015 report, such as how and when to report work, and that beneficiaries may have to repay overpayments that occur even when they report work. Finally, SSA has not indicated whether it has assessed options for increasing the frequency of reporting reminders to DI beneficiaries. Until SSA can demonstrate that it has improved the clarity of its work reporting requirements and frequency of its work reporting reminders, DI beneficiaries may continue to incur overpayments, or be required to repay overpayments that occurred even though they reported work.

Recommendation: To help districts address key challenges in meeting MOE and mitigate unintended consequences that may affect services for students with disabilities, while preserving the safeguard for funding for students with disabilities, Congress should consider options for a more flexible MOE requirement. This could include adopting a less stringent MOE requirement to align with the MOE requirements in other education programs or adding to or modifying exceptions. For example, current exceptions could be changed to allow one-time increases in spending without changing a district's MOE baseline in order to encourage pilot innovations or to allow certain spending decreases (e.g., state caps on teacher benefits), as long as a district can demonstrate the decrease does not negatively affect services.

Agency: Congress
Status: Open

Comments: As of February 2020, Congress has not taken legislative action on this issue.

Recommendation: To improve the department's IT savings reinvestment plans, the Secretary of Agriculture should direct the CIO to ensure that the department's integrated data collection submission to OMB includes, for all reported initiatives, complete plans to reinvest any resulting cost savings and avoidances from OMB-directed IT reform-related efforts.

Agency: Department of Agriculture
Status: Open

Comments: The Department of Agriculture agreed with our recommendation and has taken initial steps to implement it. Specifically, as of May 2020, the department's integrated data collection submission to the Office of Management and Budget included reinvestment plans for 37 of 68 reported cost savings and avoidance initiatives. However, the department reported about $122.8 million in cost savings and avoidances in the 31 initiatives that did not include plans regarding how these savings would be reinvested. The department expects to provide an update in June 2020. We will continue to evaluate the department's progress in implementing this recommendation.

Recommendation: To improve the department's IT savings reinvestment plans, the Secretary of Housing and Urban Development should direct the CIO to ensure that the department's integrated data collection submission to OMB includes, for all reported initiatives, complete plans to reinvest any resulting cost savings and avoidances from OMB-directed IT reform-related efforts.

Agency: Department of Housing and Urban Development
Status: Open

Comments: The Department of Housing and Urban Development agreed with, and has taken initial steps to implement, our recommendation. Specifically, as of May 2020, the department's integrated data collection submission included reinvestment plans for one of the eight cost savings and avoidance initiatives reported. However, the seven remaining initiatives, with savings and avoidances totaling approximately $6.3 million, did not include reinvestment plans. The department expects to provide an update in June 2020. We will continue to evaluate the department's progress in implementing this recommendation.

Recommendation: To improve the department's IT savings reinvestment plans, the Secretary of the Treasury should direct the CIO, as part of any future update to the department's IRM strategic plan or equivalent document, to include information regarding the approach to reinvesting savings from the consolidation of commodity IT resources (including data centers) in accordance with OMB's guidance.

Agency: Department of the Treasury
Status: Open

Comments: The Department of the Treasury has not yet taken steps to implement our recommendation. Specifically, as of May 2020, the department had not yet updated its Information Resources Management (IRM) Strategic Plan to include information regarding the approach to reinvesting savings from the consolidation of commodity IT resources. In addition, in an April 2020 e-mail, the department's GAO liaison stated that Treasury had not yet updated its IRM strategic plan, but might have other, more current, strategic documents that described its reinvestment plans. The department expects to provide an update in June 2020. We will continue to evaluate the department's progress in implementing this recommendation.

Recommendation: To improve the department's IT savings reinvestment plans, the Secretary of the Treasury should direct the CIO to ensure that the department's integrated data collection submission to OMB includes, for all reported initiatives, complete plans to use any resulting cost savings and avoidances from OMB-directed IT reform-related efforts.

Agency: Department of the Treasury
Status: Open

Comments: The Department of the Treasury has not yet taken steps to implement our recommendation. Specifically, as of May 2020, the department's quarterly integrated data collection submission to the Office of Management and Budget did not include reinvestment plans for 15 of the 27 reported cost savings and avoidance initiatives. For example, the department reported about $100 million in cost avoidances from its data center consolidation and optimization initiatives, but did not provide information regarding how it plans to reinvest these avoidances. The department expects to provide an update in June 2020. We will continue to evaluate the department's progress in implementing this recommendation.

Recommendation: To improve the department's IT savings reinvestment plans, the Secretary of Veterans Affairs should direct the CIO to ensure that the department's integrated data collection submission to OMB includes, for all reported initiatives, complete plans to reinvest any resulting cost savings and avoidances from OMB-directed IT reform-related efforts.

Agency: Department of Veterans Affairs
Status: Open

Comments: The Department of Veterans Affairs agreed with, and took initial steps to implement, our recommendation. Specifically, in November 2015, the department's Chief of Staff stated that the Office of Information and Technology was working to establish an office to close monitor program performance, deliver, cost, schedule, return on investment, and total cost of ownership, which will enable reinvestment opportunities. However, as of May 2020, the department's quarterly integrated data collection submission to the Office of Management and Budget did not include reinvestment plans for five of the 10 reported cost savings and avoidance initiatives. For example, the department reported about $229 million in cost avoidances associated with renegotiating an enterprise license agreement with Microsoft, but did not provide information regarding how it plans to reinvest these avoidances. The department expects to provide an update in June 2020. We will continue to evaluate the department's progress in implementing this recommendation.

Recommendation: To improve the agency's IT savings reinvestment plans, the Administrator of the Environmental Protection Agency should direct the CIO to ensure that the agency's integrated data collection submission to OMB includes, for all reported initiatives, complete plans to reinvest any resulting cost savings and avoidances from OMB-directed IT reform-related efforts.

Agency: Environmental Protection Agency
Status: Open

Comments: The Environmental Protection Agency agreed with our recommendation, but has not yet taken steps to implement it. Specifically, as of May 2020, the agency's quarterly integrated data collection submission to the Office of Management and Budget did not include reinvestment plans for any of the 12 reported cost savings and avoidance initiatives. For example, the agency reported about $34.0 million in cost savings and avoidances in 2019 related to data center, commodity IT, and software licensing initiatives, but did not provide information regarding how it plans to reinvest these savings and avoidances. The agency expects to provide an update in June 2020. We will continue to evaluate the agency's progress in implementing this recommendation.

Recommendation: To improve the agency's IT savings reinvestment plans, the Director of the Office of Personnel Management should direct the CIO, as part of any future update to the agency's IRM strategic plan or equivalent document, to include information regarding the approach to reinvesting savings from the consolidation of commodity IT resources (including data centers) in accordance with OMB's guidance.

Agency: Office of Personnel Management
Status: Open

Comments: The Office of Personnel Management (OPM) agreed with our recommendation, but has not yet taken action to implement it. Specifically, in November 2015, OPM's Acting Director stated that information regarding the approach to reinvesting savings from the consolidation of commodity IT resources (including data centers) would be included in future updates to OPM's Strategic IT Plan. In August 2019, OPM's GAO liaison stated that the agency intended to update its Strategic IT Plan in fiscal year 2020 and intended to include reinvestment language as part of the update. However, as of May 2020, the agency had not yet updated its strategic plan to include this information. The agency expects to provide an update in June 2020. We will continue to evaluate the OPM's progress in implementing this recommendation.

Recommendation: To improve the public reporting about how agencies are ensuring the quality of performance information used to measure progress towards their priority goals, the Secretaries of Agriculture, Defense, Homeland Security, Interior, and Labor, and the Administrator of NASA should more fully address GPRAMA requirements and OMB guidance by working with OMB to describe on Performance.gov how they are ensuring the quality of performance information used to measure progress towards their APGs.

Agency: Department of Agriculture
Status: Open

Comments: The Department of Agriculture (USDA) has identified five priority goals (APGs) for fiscal years 2020 and 2021. USDA states that action plans and progress updates for these goals are "coming soon". In a November 2018 letter to the Comptroller General, USDA's Inspector General acknowledged that additional efforts are needed to better describe the quality of the data supporting the APGs and said that the Department will increase the amount of information provided in the quarterly APG updates. In April 2020, we followed up and once more requested updated information from USDA officials. As of May 6, 2020, we have not received the requested information. We will continue to monitor USDA's efforts to address our recommendation.

Recommendation: To improve the public reporting about how agencies are ensuring the quality of performance information used to measure progress towards their priority goals, the Secretaries of Agriculture, Defense, Homeland Security, Interior, and Labor, and the Administrator of NASA should more fully address GPRAMA requirements and OMB guidance by working with OMB to describe on Performance.gov how they are ensuring the quality of performance information used to measure progress towards their APGs.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) has identified three priority goals (APGs) for fiscal years 2020 and 2021. DOD states action plans and progress updates are "coming soon" for Performance.gov. In March 2020, DOD officials reported that they continue to work to address our recommendation. We will continue to monitor DOD's efforts to address our recommendation.

Recommendation: To improve the public reporting about how agencies are ensuring the quality of performance information used to measure progress towards their priority goals, the Secretaries of Agriculture, Defense, Homeland Security, Interior, and Labor, and the Administrator of NASA should more fully address GPRAMA requirements and OMB guidance by working with OMB to describe on Performance.gov how they are ensuring the quality of performance information used to measure progress towards their APGs.

Agency: Department of the Interior
Status: Open

Comments: The Department of the Interior (Interior) has identified six priority goals (APGs) for fiscal years 2020 and 2021. Interior states on Performance.gov that action plans and progress updates are "coming soon". We will continue to monitor Interior's efforts to address our recommendation.

Recommendation: To improve the public reporting about how agencies are ensuring the quality of performance information used to measure progress towards their priority goals, the Secretaries of Agriculture, Defense, Interior, and Labor, and the Administrator of NASA should more fully address GPRAMA requirements and OMB guidance by describing in their agencies' annual performance plans and reports how they are ensuring the quality of performance information used to measure progress towards their APGs.

Agency: Department of Agriculture
Status: Open

Comments: The Department of Agriculture's (USDA) Fiscal Year 2021 Annual Performance Plan and Fiscal Year 2019 Annual Performance Report provides a general statement on how the agency uses a standardized methodology to measure its performance and that agency officials attest to the quality of the performance information. USDA also identifies its priority goals for fiscal years 2020 and 2021, but specific data quality explanation is not provided for these APGs. In a November 2018 letter to the Comptroller General, USDA's Inspector General stated that the Department agrees with the recommendation and will begin providing data quality explanation for the APGs in its next annual performance plan and report to be published in February 2019, but our review in 2019 found no such explanation. Further, as noted above the most recent plan and report do not provide the required explanation. In April 2020, we once more requested updated information from USDA officials and as of May 6, 2020 have not received the requested information. We will continue to monitor USDA's efforts to address our recommendation.

Recommendation: To improve the public reporting about how agencies are ensuring the quality of performance information used to measure progress towards their priority goals, the Secretaries of Agriculture, Defense, Interior, and Labor, and the Administrator of NASA should more fully address GPRAMA requirements and OMB guidance by describing in their agencies' annual performance plans and reports how they are ensuring the quality of performance information used to measure progress towards their APGs.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense's (DOD) Fiscal Year (FY) 2021 Annual Performance Plan and FY2019 Annual Performance Report states that, "each goal owner has attested the performance results and narrative information included in this report is complete, accurate, and reliable; and that data validation and verification procedures are documented and available upon request," and DOD refers readers to Performance.gov for more information about its priority goals (APGs). However, the GPRA Modernization Act of 2010 requires agencies to publish more specific data quality explanation for each APG in performance plans and reports and on Performance.gov. DOD's performance plan and report does not contain the more specific explanation required. Nor did our review of Performance.gov find the required explanation. In March 2020, DOD officials reported that they continue to work to address our recommendation. We will continue to monitor DOD's efforts to address our recommendation.

Recommendation: To improve the public reporting about how agencies are ensuring the quality of performance information used to measure progress towards their priority goals, the Secretaries of Agriculture, Defense, Interior, and Labor, and the Administrator of NASA should more fully address GPRAMA requirements and OMB guidance by describing in their agencies' annual performance plans and reports how they are ensuring the quality of performance information used to measure progress towards their APGs.

Agency: Department of the Interior
Status: Open

Comments: The Department of the Interior's (Interior) 2021/2020 Annual Performance Plan & 2019 Report (APP&R) includes a section concerning data accuracy and reliability and describes in general terms how Interior ensures the accuracy and reliability of performance information and how it addresses the five data quality requirements in the GPRA Modernization Act of 2010. Interior states in this section that measurement procedures for agency performance goals are described on Performance.gov. As of May 2020, our review found that Interior has not provided specific data quality explanation for its APGs on Performance.gov. We will continue to monitor Interior's efforts to address our recommendation.

Recommendation: To improve the availability of information needed for effective and efficient management of the PCS program, including program costs and time-on-station requirements, the Secretary of Defense should direct the Under Secretary of Defense (Comptroller), in coordination with the military services, to improve the completeness and consistency of PCS data in service budget materials. This action should include revising existing guidance on the reporting of non-temporary storage costs, and clarifying existing guidance on the presentation of other PCS data.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. DOD formed a working group to address issues concerning the PCS program, including the Office of the Deputy Assistant Secretary of Defense (Military Personnel Policy) within the Office of the Assistant Secretary of Defense (Manpower and Reserve Affairs), and the Director, Military Personnel and Construction within the Office of the Deputy Comptroller (Program/Budget). As of September 2018 the working group has met multiple times, with its initial focus primarily on adjudication of major legislation associated with housing flexibility during PCS. In addition, the working group reported to Congress in June 2017 on military family stability and PCS, and sponsored a family stability review by RAND. However, as of September 2018 DOD stated that the Office of the Undersecretary of Defense (Comptroller) was continuing to coordinate with the military services to synchronize and clarify budgetary reporting requirements. As such, we believe that this recommendation remains open.

Recommendation: To improve the availability of information needed for effective and efficient management of the PCS program, including program costs and time-on-station requirements, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness, in coordination with the military services, to complete periodic evaluations of whether the PCS program is efficiently supporting DOD's requirements for assigning military personnel to new locations while reimbursing servicemembers for allowable expenses incurred during PCS moves. These periodic evaluations should identify changes in PCS per-move costs over time, factors driving such changes, and steps that could be taken to manage and control cost growth.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation. DOD formed a working group to address issues concerning the PCS program, including the Office of the Deputy Assistant Secretary of Defense (Military Personnel Policy) within the Office of the Assistant Secretary of Defense (Manpower and Reserve Affairs), and the Director, Military Personnel and Construction within the Office of the Deputy Comptroller (Program/Budget). As of September 2018 the working group has met multiple times, with its initial focus primarily on adjudication of major legislation associated with housing flexibility during PCS. In addition, the working group reported to Congress in June 2017 on military family stability and PCS, and sponsored a family stability review by RAND. The working group has also reviewed PCS initiatives completed by the military services, and the timeliness of PCS orders. As of September 2018, a combatant commander review of overseas tour lengths and an initiative led by the Office of the Undersecretary of Defense (Comptroller) to review PCS data and costs are ongoing. DOD expects these initiatives, as well as additional efforts to collect and analyze PCS data, will continue into fiscal year 2019. While the initiatives DOD mentioned in its response demonstrate progress toward fully implementing our recommendation, we believe that this recommendation should remain open until more progress is made.

Recommendation: To improve the availability of information needed for effective and efficient management of the PCS program, including program costs and time-on-station requirements, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness, in coordination with the military services, to improve the completeness and consistency of data on exceptions used for PCS moves that occur prior to established time-on-station lengths. This action should include clarifying existing guidance with regard to how the services collect, maintain, and report data on exceptions for use in evaluating performance in meeting time-on-station requirements and addressing challenges related to the services' abilities to collect, maintain, and report exceptions data.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. DOD formed a working group to address issues concerning the PCS program, including the Office of the Deputy Assistant Secretary of Defense (Military Personnel Policy) within the Office of the Assistant Secretary of Defense (Manpower and Reserve Affairs), and the Director, Military Personnel and Construction within the Office of the Deputy Comptroller (Program/Budget). As of September 2018 the working group has met multiple times, with its initial focus primarily on adjudication of major legislation associated with housing flexibility during PCS. In addition, the working group reported to Congress in June 2017 on military family stability and PCS, and sponsored a family stability review by RAND. The working group has also reviewed PCS initiatives completed by the military services, and the timeliness of PCS orders. As of September 2018, a combatant commander review of overseas tour lengths and an initiative led by the Office of the Undersecretary of Defense (Comptroller) to review PCS data and costs are ongoing. DOD expects these initiatives, as well as additional efforts to collect and analyze PCS data, will continue into fiscal year 2019. While the initiatives DOD mentioned in its response demonstrate progress toward fully implementing our recommendation, we believe that this recommendation should remain open until more progress is made.

Recommendation: To improve the availability of information needed for effective and efficient management of the PCS program, including program costs and time-on-station requirements, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness, in coordination with the military services, to improve the completeness and consistency of data on waivers used for PCS moves that occur prior to established time-on-station lengths. This action should include establishing guidance for the military services to collect, maintain, and report data on waivers for use in evaluating performance in meeting time-on-station requirements and addressing challenges related to the services' abilities to collect, maintain, and report waiver data.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. DOD formed a working group to address issues concerning the PCS program, including the Office of the Deputy Assistant Secretary of Defense (Military Personnel Policy) within the Office of the Assistant Secretary of Defense (Manpower and Reserve Affairs), and the Director, Military Personnel and Construction within the Office of the Deputy Comptroller (Program/Budget). As of September 2018 the working group has met multiple times, with its initial focus primarily on adjudication of major legislation associated with housing flexibility during PCS. In addition, the working group reported to Congress in June 2017 on military family stability and PCS, and sponsored a family stability review by RAND. The working group has also reviewed PCS initiatives completed by the military services, and the timeliness of PCS orders. As of September 2018, a combatant commander review of overseas tour lengths and an initiative led by the Office of the Undersecretary of Defense (Comptroller) to review PCS data and costs are ongoing. DOD expects these initiatives, as well as additional efforts to collect and analyze PCS data, will continue into fiscal year 2019. While the initiatives DOD mentioned in its response demonstrate progress toward fully implementing our recommendation, we believe that this recommendation should remain open until more progress is made.

Recommendation: To help inform decision makers on the SAMP's progress as well as the decision regarding the extension of the SAMP's term, the Secretary of Defense should direct the SAMP to define timelines and measures to assess its progress in completing its major tasks.

Agency: Department of Defense
Status: Open

Comments: DOD did not concur with this recommendation, stating that the department will submit its Fiscal Year 2015 National Defense Authorization Act report on military programs and controls regarding professionalism to Congress on September 1, 2015, thereby satisfying the requirements of this recommendation. DOD confirmed its position with regard to this recommendation on October 19, 2015. As of September 16, 2020, DOD has not responded to further inquiries regarding any actions it has taken to implement this recommendation. When we confirm what actions DOD has taken, we will update the status of this recommendation.

Recommendation: To increase assurance that commanders are conducting command climate assessments in accordance with statutory requirements and departmental guidance, the Secretary of Defense should direct the Secretaries of the Air Force, the Army, and the Navy, and the Commandant of the Marine Corps to modify existing guidance or develop new guidance to comply with requirements set forth in the Fiscal Year 2014 National Defense Authorization Act and internal DOD guidance.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation, stating that existing Army practice is consistent with the intent of departmental guidance for command climate survey utilization. DOD confirmed its position with regard to this recommendation on October 19, 2015. As of September 16, 2020, DOD has not responded to further inquiries regarding any actions it has taken to implement this recommendation. When we confirm what actions DOD has taken, we will update the status of this recommendation.

Recommendation: To better inform the department's approach to senior officers' professional development, the Secretary of Defense should direct the Secretary of the Navy, the Commandant of the Marine Corps, and the Chairman of the Joint Chiefs of Staff to assess the need for and feasibility of implementing 360-degree assessments for all general and flag officers.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation, stating that it concurs with the recommendation to assess the need for and feasibility of implementing 360-degree assessments, or 360-degree-like feedback assessments, where they are not already being performed, but that it believes that it should only do so for general and flag officers at the three star ranks and below. DOD confirmed its position with regard to this recommendation on October 19, 2015. At that time, DOD also stated that it believes in a holistic approach to developing and assessing professionalism, noting, as an example, the Joint Staff's use of staff assistance visits and Senior Leader "roundtables" to complement the use of 360-degree assessments. In April 2018, DOD stated that each military department and the Chairman of the Joint Chiefs of Staff had implemented a 360-degree assessment requirement for all general and flag officers. As of September 16, 2020, DOD has not responded to inquiries regarding documentation in support of these actions. When we confirm what actions DOD has taken, we will update the status of this recommendation.

Recommendation: To improve DOD's ability to assess its progress in addressing ethics and professionalism issues, the Secretary of Defense should direct the SAMP, through the Under Secretary of Defense for Personnel and Readiness, or SAMP's successor organization(s), to identify information sources and develop intermediate goals and performance metrics. At minimum, these performance metrics should be clear, quantifiable, and objective, and they should include a baseline assessment of current performance.

Agency: Department of Defense
Status: Open

Comments: DOD concurred, with comment, with this recommendation, noting that the office of the Senior Advisor for Military Professionalism is a temporary office established by Secretary Hagel for a two year term ending no later than March of 2016. DOD confirmed its position with regard to this recommendation on October 19, 2015. In April 2018, DOD identified activities it had undertaken in the spirit and intent of the recommendation. As of September 16, 2020, DOD has not responded to inquiries for documentation in support of these actions and the related development of intermediate goals and performance metrics. When we confirm what actions DOD has taken, we will update the status of 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: The EPA Administrator should direct OGD to develop a timetable with milestones and identify and allocate resources for adopting electronic records management for all 10 regional offices.

Agency: Environmental Protection Agency
Status: Open

Comments: According to EPA officials, the Office of Grants and Debarment (OGD) established an agency-wide electronic grants record workgroup in fiscal year 2016. The workgroup identified the contents of the electronic grant file, technical options, and evaluation criteria. OGD completed its alternatives analysis for scope, general approach, and requirements in fiscal year 2017 and EPA expected this recommendation to be addressed by its new grants management system (GrantsSolutions). However, in January 2020, EPA officials told us that EPA had ceased its migration to GrantSolutions after determining the long-term costs were unsustainable and that the system lacked fundamental functionality necessary for core grant operations and to maintain appropriate internal controls. EPA is now migrating towards a modernized grants administration and management cloud solution. EPA expects this recommendation to be addressed when the new grants management system is fully implemented. EPA anticipates deployment of the new cloud solution in December 2020.

Recommendation: The EPA Administrator should direct OGD to implement plans for adopting an up-to-date and comprehensive IT system by 2017 that will provide accurate and timely data on agencywide compliance with grants management directives.

Agency: Environmental Protection Agency
Status: Open

Comments: Implementation efforts are ongoing. According to EPA officials, OGD is conducting a multi-modular project to upgrade the agency's grants management IT system. EPA expected this recommendation to be addressed by its new grants management system (GrantsSolutions), which had been targeted for deployment in March 2020. However, in January 2020, EPA officials told us that EPA had ceased its migration to GrantSolutions after determining the long-term costs were unsustainable and that the system lacked fundamental functionality necessary for core grant operations and to maintain appropriate internal controls. EPA is now migrating towards a modernized grants administration and management cloud solution. EPA expects this recommendation to be addressed when the new grants management system is fully implemented. EPA anticipates deployment of the new cloud solution in December 2020.

Recommendation: To ensure that federal program spending data are provided to the public in a transparent, useful, and timely manner, the Director of OMB should accelerate efforts to determine how best to merge DATA Act purposes and requirements with the GPRAMA requirement to produce a federal program inventory.

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

Comments: OMB issued guidance in June 2019 that provides an overview and timeline for merging DATA Act reporting with implementation of a federal program inventory. To fully address this recommendation, OMB needs to provide additional details on the implementation of these requirements.

Recommendation: To ensure that the integrity of data standards is maintained over time, the Director of OMB, in collaboration with the Secretary of the Treasury, should establish a set of clear policies and processes for developing and maintaining data standards that are consistent with leading practices for data governance.

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

Comments: OMB issued several guidance documents in 2019 that set out key aspects of a process for agencies to establish standards for, and practices for governing, managing, and protecting, all federal data. These and related efforts represent significant progress, but OMB needs to ensure this broad guidance is followed by clear and specific requirements for agency data governance to ensure the quality of their DATA Act reporting.

Recommendation: The Secretary of Education should develop a risk-based, cost-effective strategy to verify that states are implementing a process for assessing whether any teacher preparation programs are low-performing.

Agency: Department of Education
Status: Open

Comments: In 2016, Education published an issue brief about identifying low-performing schools, which referenced GAO's report and the potential risks of limited state action to identify and address low performance. In December 2019, Education provided GAO with a revised data collection instrument for collecting information about states' criteria for identifying low-performing teacher preparation programs. Officials stated that the instrument has been approved by OMB and Education plans to start using it in October 2020. Officials said that the instrument is designed to provide more structured information about state criteria and allow Education to better monitor states' responses from year to year. We are encouraged by these efforts and will revisit the status of this recommendation when the new template is implemented in 2020.

Recommendation: To increase the efficiency and improve the accuracy of the interagency UAC referral and placement process, the Secretaries of Homeland Security and Health and Human Services should jointly develop and implement a documented interagency process with clearly defined roles and responsibilities, as well as procedures to disseminate placement decisions, for all agencies involved in the referral and placement of UAC in HHS shelters.

Agency: Department of Homeland Security
Status: Open
Priority recommendation

Comments: Since our 2015 report, DHS and HHS developed two documents to guide interagency procedures related to the processing of UAC. Specifically, in April 2018, HHS and DHS established a memorandum of agreement regarding information sharing for UAC. Subsequently, on July 31, 2018, DHS and HHS issued a Joint Concept of Operations to memorialize interagency policies, procedures, and guidelines related to the processing of UAC. However, in February 2020, we reported that DHS and HHS officials' indicated that, in practice, the agencies have not resolved long-standing differences in opinion about whether and how agencies are to share information, and what type of information is needed to inform decisions about the care and placement of UAC. In commenting on our draft report, DHS stated that its components are working with HHS to document current information sharing practices, to validate remaining information sharing gaps, and to draft a joint plan between DHS and HHS to ensure that HHS receives information needed to make decisions for UAC. In their comments, HHS officials stated that they intend to reach out to counterparts at DHS in June 2020 to discuss potential periodic updates to the Joint Concept of Operations. In August 2020, DHS informed us that the department is working with HHS to document current information sharing practices, validate gaps, and draft a joint plan between DHS and HHS, among other actions. DHS estimates that it will complete these actions by March 31, 2021. To fully address the recommendation, DHS and HHS should ensure that they have implemented procedures aimed at improving the efficiency and accuracy of the interagency UAC referral and placement process.

Recommendation: To increase the efficiency and improve the accuracy of the interagency UAC referral and placement process, the Secretaries of Homeland Security and Health and Human Services should jointly develop and implement a documented interagency process with clearly defined roles and responsibilities, as well as procedures to disseminate placement decisions, for all agencies involved in the referral and placement of UAC in HHS shelters.

Agency: Department of Health and Human Services
Status: Open
Priority recommendation

Comments: Since our 2015 report, DHS and HHS developed two documents to guide interagency procedures related to the processing of UAC. Specifically, in April 2018, HHS and DHS established a memorandum of agreement regarding information sharing for UAC. Subsequently, on July 31, 2018, DHS and HHS issued a Joint Concept of Operations to memorialize interagency policies, procedures, and guidelines related to the processing of UAC. However, in February 2020, we reported that DHS and HHS officials' indicated that, in practice, the agencies have not resolved long-standing differences in opinion about whether and how agencies are to share information, and what type of information is needed to inform decisions about the care and placement of UAC. In commenting on our draft report, DHS stated that its components are working with HHS to document current information sharing practices, to validate remaining information sharing gaps, and to draft a joint plan between DHS and HHS to ensure that HHS receives information needed to make decisions for UAC. In their comments, HHS officials stated that they intend to reach out to counterparts at DHS in June 2020 to discuss potential periodic updates to the Joint Concept of Operations. In August 2020, DHS informed us that the department is working with HHS to document current information sharing practices, validate gaps, and draft a joint plan between DHS and HHS, among other actions. DHS estimates that it will complete these actions by March 31, 2021. To fully address the recommendation, DHS and HHS should ensure that they have implemented procedures aimed at improving the efficiency and accuracy of the interagency UAC referral and placement process.

Recommendation: To help ensure that agency review processes provide frequent, regular opportunities to assess progress on agency priority goals (APG), and are conducted in a manner consistent with GPRA Modernization Act of 2010 (GPRAMA) requirements, OMB guidance, and leading practices, the Secretary of Defense should work with the COO and PIO to modify the Department's review processes to ensure that review meetings are led by the agency head or COO.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) partially concurred with this recommendation. DOD officials previously told us that they interpreted relevant guidance from the Office of Management and Budget (OMB) to provide them with flexibility to delegate responsibility for conducting these reviews. However, as of July 2020, OMB's guidance continues to clearly state that the agency head and/or Chief Operating Officer, with support of the Performance Improvement Officer, are responsible for leading agency reviews. In May and June 2020, DOD officials described to us meetings that agency officials used to review progress on each of the agency's priority goals. However, neither the Secretary nor Deputy Secretary of Defense were involved in those review meetings. We will continue to monitor DOD's actions to address this recommendation.

Recommendation: To help ensure that agency review processes provide frequent, regular opportunities to assess progress on agency priority goals (APG), and are conducted in a manner consistent with GPRA Modernization Act of 2010 (GPRAMA) requirements, OMB guidance, and leading practices, the Secretary of State should work with the COO and PIO to modify the Department's review processes to ensure that progress on each APG is reviewed in an in-person review meeting at least quarterly.

Agency: Department of State
Status: Open

Comments: The State Department concurred with this recommendation. In October 2019, State Department officials described to us actions the agency has taken to conduct reviews consistent with what we recommended. For example, they provided a document confirming that officials reviewed one of the priority goals in an in-person meeting. However, they did not provide documentation to demonstrate that review processes for the agency's other priority goals are held in-person or at least quarterly. We have requested, but as of April 2020 have not received, this additional documentation. We will continue to monitor the agency's progress.

Recommendation: To help ensure that agency review processes provide frequent, regular opportunities to assess progress on agency priority goals (APG), and are conducted in a manner consistent with GPRA Modernization Act of 2010 (GPRAMA) requirements, OMB guidance, and leading practices, the Secretary of State should work with the COO and PIO to modify the Department's review processes to ensure that the reviews are led by the agency head or COO.

Agency: Department of State
Status: Open

Comments: The State Department did not agree or disagree with this recommendation and, as of March 2020, has taken limited actions to address it. In October 2019, State Department officials described to us how the Chief Operating Officer (COO) is involved in reviewing progress on one of the agency's priority goals. However, as of April 2020, the State Department has not provided documentation we requested to corroborate the COO's involvement in this review, or reviews for the agency's other priority goals. We will continue to monitor the agency's progress.

Recommendation: To enhance the effectiveness of its preparations for conducting a retrospective review of its QM regulations, HUD should develop a plan that identifies the metrics, baselines, and analytical methods to be used. Furthermore, to account for and help mitigate the limitations of existing data and the uncertain availability of enhanced datasets, HUD should include in its plan alternate metrics, baselines, and analytical methods that could be used data were to remain unavailable.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In February 2017, HUD noted that it does not currently collect data on the annual percentage rate (APR) for each loan that would allow for a perfect comparison to the average prime offer rate. According to HUD, its Office of Housing has on its long-term list of systems priorities to collect specific information from the Uniform Closing Data that could be used to conduct such a comparison. However, HUD stated that it has not received adequate funding to meet these systems enhancements. According to HUD, it is considering the feasibility and potential utility of alternative data sources or the use of a proxy in an appropriate methodology. For instance, whether it may be possible to approximate the APR based upon the note rate and information on closing costs that is collected in the current data system, or alternatively, whether the APR could be obtained or approximated through matching Home Mortgage Disclosure Act data for FHA loans. In a September 2020 email, HUD officials stated that HUD has certain unique considerations for review of its own QM rule as compared to the other federal agencies covered in the GAO report. HUD officials explained that HUD's QM rule implemented certain changes intended to conform with the Consumer Financial Protection Bureau's (CFPB) rule and constituted only a small subset of FHA's overall requirements related to underwriting and loan characteristics. According to HUD officials, HUD's QM rule was intended to make conforming changes to FHA's requirements, as statutorily required, in order to bring them into greater alignment with the new CFPB-promulgated QM rule requirements. They stated that HUD assesses FHA loan performance on an ongoing basis through a variety of mechanisms including the annual audit requirement and monitoring of the overall market and mortgage portfolio. According to the HUD officials, these mechanisms are used to assess the need for adjustments in underwriting criteria and mortgage insurance premiums as well as to assess the health and risks to safety and soundness of the MMIF Fund. HUD officials said that given these considerations, there is no specific stand-alone full evaluation of the HUD QM rule planned at this time.

Recommendation: The Commissioner of IRS should direct the appropriate IRS officials to establish procedures to monitor whether non-IRS contractors with unescorted physical access to IRS facilities are receiving unauthorized access awareness training.

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

Comments: During fiscal year 2018, Facilities Management and Security Services (FMSS) established training requirements for non-IRS contractors with unescorted physical access to IRS facilities and communicated these requirements to its employees. However, FMSS did not establish procedures to monitor whether these non-IRS contractors receive the required unauthorized access awareness training. In addition, during our fiscal year 2019 audit, we found instances in which non-IRS contractors with unescorted physical access to an IRS facility did not complete the required training.

Recommendation: The Commissioner of IRS should direct the appropriate IRS officials to determine why staff did not consistently comply with IRS's existing requirements for the final candling of receipts at service center campuses and lockbox banks, including logging remittances found during final candling on the final candling log at the time of discovery, safeguarding the remittances at the time of discovery, transferring the remittances to the deposit unit promptly, and passing one envelope at a time over the light source, and based on this determination, establish a process to better enforce compliance with these requirements.

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2017, IRS held a meeting with Submission Processing executives, staff, and the Receipt and Control Operation managers from all five service center campuses (SCC), and as a result of the meeting, IRS developed an action plan to resolve the residual risks associated with candling at the SCCs. IRS officials stated that during fiscal year 2020, it will complete the developed action plan.

Recommendation: To improve the military whistleblower reprisal investigation process and oversight of such investigations, the Secretary of Defense should work in coordination with the Department of Defense Inspector General (DODIG) to direct the services to follow standardized investigation stages and issue guidance clarifying how the stages are defined.

Agency: Department of Defense
Status: Open

Comments: DOD officials concurred with this recommendation and provided an update in May 2019, in which they stated that the office was preparing an issuance for coordination that will direct the services to follow standardized investigation stages and guidance clarifying how the stages are defined. DOD officials estimated that the issuance would be completed by December 31, 2019.

Recommendation: To help ensure that the Navy has adequate oversight of on-order excess inventory termination decisions and necessary performance measures consistent with DOD guidance, the Secretary of the Navy should direct the Commander, Naval Supply Systems Command, to incorporate the graduated management reviews and the ability to track and review the reasons for not canceling and modifying on-order excess items into its automated termination module that is under development.

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

Comments: DOD concurred with our recommendation. As of August 2019, Naval Supply Systems Command has taken some steps, such as defining the requirement and piloting some aspects of the effort, to incorporate graduated management reviews and the ability to track and review the reason for not canceling and modifying on-order excess items into its automated termination module. However, this capability is not implemented into the automated termination module, according to Naval Supply Systems Command officials. Navy Supply Systems Command provided information on its plans to implement this capability in fiscal year 2020 and we will continue to monitor their efforts to address this implementation.

Recommendation: To improve CMS's oversight of Medicaid payments, the Administrator of CMS should take steps to ensure that states report accurate provider-specific payment data that include accurate unique national provider identifiers (NPI).

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

Comments: In November 2019, CMS issued a proposed rule that the agency said would promote state accountability, improve federal oversight, and strengthen the fiscal integrity of the Medicaid program. Among other things, the proposed rule would require states to report supplemental payments made to individual providers; furthermore, it would require states to include the National Provider Identifier (NPI) number-a unique 10-digit identification number assigned to health care providers. GAO will continue to monitor the status of the proposed rule and will review a final rule, if one is issued, to determine the extent it addresses the recommendation.

Recommendation: To improve CMS's oversight of Medicaid payments, the Administrator of CMS should develop a policy establishing criteria for when such payments at the provider level are economical and efficient.

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

Comments: In November 2019, CMS issued a proposed rule that the agency said would require states to demonstrate to CMS that supplemental payments to individual providers are economical and efficient and also require states to end and then seek CMS approval to renew supplemental payments every three years. GAO will monitor the status of the proposed rule and will review a final rule, if one is issued, to determine the extent to which it addresses the recommendation.

Recommendation: To improve CMS's oversight of Medicaid payments, the Administrator of CMS should, once criteria are developed, develop a process for identifying and reviewing payments to individual providers in order to determine whether they are economical and efficient.

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

Comments: In November 2019, CMS issued a proposed rule that the agency said would require states to demonstrate to CMS that supplemental payments to individual providers are economical and efficient and also require states to end and then seek CMS approval to renew supplemental payments every three years. GAO will monitor the status of the proposed rule and will review a final rule, if one is issued, to determine the extent to which it addresses the recommendation.

Recommendation: To enhance the usefulness of NNSA's future reports to Congress describing the costs and benefits of its competition of M&O contracts under the requirements contained in Section 3121 of the National Defense Authorization Act for fiscal year 2013, as amended, the NNSA Administrator should take steps to ensure that future reports reflect DOE's information quality guidelines, federal cost accounting standards, and GAO's best practices guidance relevant to the clear and complete presentation of information on each of the required topics. In particular, future reports should clearly and completely describe costs and benefits, including the agency's expectations, as well as the associated analysis, assumptions, information sources, and key limitations and uncertainties about costs and benefits described. The description of uncertainties should include key excluded or unspecified costs and benefits, such as those that are anticipated but not fully known at the time of report writing.

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

Comments: NNSA believes it has met the requirements of the recommendation and considers it closed. In our March 2015 report--which examined NNSA's report on the contract to manage and operate the Pantex Plant and the Y-12 National Security Complex under a single management and operating (M&O) contract with Consolidated Nuclear Services (CNS)--we recommended that NNSA enhance the clarity and completeness of its future reports on the costs and benefits of M&O contract competitions. While NNSA demonstrated progress in implementing this recommendation in its September 2017, August 2018, and April 2019 reports to Congress on the costs and benefits of the contract competitions for the Sandia, Nevada, and Los Alamos sites respectively, NNSA did not provide clear and complete information on all required elements of these reports. Specifically, for the Sandia National Laboratories M&O contract, in our August 2018 report we found that NNSA addressed most but not all reporting requirements. For example, NNSA's report addressed all requirements pertaining to cost savings, other benefits, and disruptions or delays, but only partially addressed the reporting requirements on the limitations or uncertainties about cost savings and on the immediate costs of competition and over the life of the contract. NNSA issued a report in August 2018 on the costs and benefits of its competition of the M&O contract for the Nevada National Security Site. In our April 2019 report on NNSA's cost-benefit analysis of that contract competition, we found that, of the five required reporting elements, NNSA's report addressed one with detail but addressed the other four without detail. In April 2019 NNSA issued its cost-benefit analysis of the competition for the Los Alamos National Laboratory contract. In our January 2020 report on NNSA's cost-benefit report for that contract competition, we found that it addressed five reporting elements on costs and disruption during contract transition with detail, partially addressed two reporting elements on uncertainties and benefits, and did not address one reporting element on activities to be covered by the M&O contractor. Since our 2015 recommendation, NNSA's cost-benefit reports on M&O contract competitions have generally provided clearer and more complete information on most of the required reporting elements, but they have not provided clear and complete information on all required reporting elements. In June 2020, NNSA announced that it would end the current CNS contract for Pantex and Y-12 management and operations instead of awarding the contractor its final option term. This will result in a new contract competition and award by the end of the current contract's term on September 30, 2021. The NNSA report on the costs and benefits of that competition may give us another opportunity to assess the quality of NNSA's reports for clarity and completeness on the required reporting elements.

Recommendation: To improve DOD's ability to prevent sexual assaults of male servicemembers, to increase its responsiveness to male servicemembers who are sexually assaulted, and to help DOD's sexual assault prevention and response program realize the full benefit of the data it collects on sexual assault incidents, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness, in collaboration with the Secretaries of the military services, to develop a plan for data-driven decision making to prioritize program efforts.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in written comments on our report. In October 2016, DOD published its plan for preventing and responding to sexual assaults of military men. In that plan, DOD generally outlined its intent to develop metrics to assess prevention and response efforts pertaining to males who experience sexual assault. In July 2019, officials from DOD's Sexual Assault Prevention and Response Office stated that DOD's efforts outlined in the October 2016 plan include data-driven decision making. However, DOD has not provided evidence that it has developed a plan for data-driven decision making to prioritize its sexual assault prevention efforts. We will continue to monitor DOD's efforts to address this recommendation.

Recommendation: To improve DOD's ability to prevent sexual assaults of male servicemembers, to increase its responsiveness to male servicemembers who are sexually assaulted, and to address challenges faced by male servicemembers as DOD continues to seek to transform its culture to address sexual assault, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness, in collaboration with the Secretaries of the military services, to develop clear goals with associated metrics to drive the changes needed to address sexual assaults of males and articulate these goals, for example in the department's next sexual assault prevention strategy.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in written comments on our report. In October 2016, DOD issued a plan to prevent and respond to sexual assault of military men. In August 2018, DOD's Sexual Assault Prevention and Response Office (SAPRO) stated that objectives 1-4 of this plan constitute DOD's goals to address sexual assaults of military men. However, the plan does not contain metrics; one of the plan's objectives is to develop metrics to assess prevention and response efforts pertaining to men who experience sexual assault. In July 2019, SAPRO officials stated that they are waiting to complete most actions for objectives 1-3 of the plan before developing associated metrics, and that completion of the metrics is expected by 2024. We will continue to monitor DOD's planned development of metrics for its prevention and response efforts for sexual assault of male servicemembers.

Recommendation: To improve DOD's ability to prevent sexual assaults of male servicemembers, to increase its responsiveness to male servicemembers who are sexually assaulted, and to address challenges faced by male servicemembers as DOD continues to seek to transform its culture to address sexual assault, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness, in collaboration with the Secretaries of the military services, to include information about the sexual victimization of males in communications to servicemembers that are used to raise awareness of sexual assault and the department's efforts to prevent and respond to it.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in written comments on our report. DOD's October 2016 plan to prevent and respond to sexual assault of military men included objectives to develop a unified communications plan tailored to men across DOD, and to improve servicemember understanding of sexual assault against men. Officials of DOD's Sexual Assault Prevention and Response Office stated in July 2019 that DOD estimates that it will complete this task in 2021.

Recommendation: To improve DOD's ability to prevent sexual assaults of male servicemembers, to increase its responsiveness to male servicemembers who are sexually assaulted, and to address challenges faced by male servicemembers as DOD continues to seek to transform its culture to address sexual assault, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness, in collaboration with the Secretaries of the military services, to revise sexual assault prevention and response training to more comprehensively and directly address the incidence of male servicemembers being sexually assaulted and how certain behavior and activities--like hazing--can constitute a sexual assault.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation in written comments on our report. DOD's October 2016 plan to prevent and respond to sexual assault of military men contained objectives to develop research-informed training for servicemembers involved with sexual assault prevention and response to improve understanding of male victimization and how to prevent the crime, commander/supervisor training; and gender-responsive treatment guidelines for providers, among other things. Officials of DOD's Sexual Assault Prevention and Response Office stated in July 2019 that DOD expects to complete these tasks in 2021.

Recommendation: To improve DOD's ability to prevent sexual assaults of male servicemembers, to increase its responsiveness to male servicemembers who are sexually assaulted, and to help ensure that all of DOD's medical and mental health providers are generally aware of any gender-specific needs of sexual assault victims, and that victims are provided the care that most effectively meets those needs, the Assistant Secretary of Defense for Health Affairs should, in collaboration with the services' Surgeons General, develop and issue guidance for the department's medical and mental health providers--and other personnel, as appropriate--based on the results of this evaluation that delineates these gender-specific distinctions and the care regimen that is recommended to most effectively meet those needs.

Agency: Department of Defense: Office of the Assistant Secretary of Defense (Health Affairs)
Status: Open

Comments: DOD concurred with this recommendation in written comments on our report. In August 2018, the Office of the Assistant Secretary of Defense for Health Affairs stated that DOD is writing an Instruction and two accompanying Defense Health Agency Procedural Instructions that will delineate gender-specific distinctions and care regimens where appropriate. The guidance will incorporate the findings of a report by the Psychological Health Center of Excellence of the Defense Health Agency resulting from a planned study of the patterns of health care utilization of servicemembers reporting a sexual assault, including any gender differences. As of September 2019, DOD had not yet issued the guidance. We will continue to monitor DOD's actions to implement this recommendation.

Recommendation: To help improve awareness of OCS roles and responsibilities and to collect OCS issues at the military services and the service component commands, the Secretary of Defense should direct the Secretaries of the military departments, in coordination with the Chairman of the Joint Chiefs of Staff, to establish an OCS training requirement for commanders and senior leaders.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. As of September 2020, DOD has taken steps to focus OCS training to all planners, including those outside the logistics directorate. In December 2015, the Joint Staff J7 certified the Joint OCS Planning and Execution (JOPEC) course of instruction for Joint training. The Joint Staff, per this training certification, is working with the Joint Deployment Training Center and the Joint Force Staff College to provide student administrative and course catalog support for future JOPEC training. In August 2020, OSD officials stated that they have secured funding for development of a new, online strategic-level OCS course, which they plan to develop, test, and field in 2021. Finally, OSD officials said that the updated OCS instruction will also address training for planners beyond the logistics directorate; officials anticipate the instruction being issued in late 2020. We will continue to monitor these efforts and this recommendation will remain open at this time.

Recommendation: To improve DOD's ability to collect and maintain reliable data on its acquisitions, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology, and Logistics, in consultation with DOD components, to establish guidelines on what constitutes a "current" ACAT II or III program for reporting purposes; the types of programs, if any, that do not require ACAT designations; and whether the rules for identifying current MDAPs would be appropriate for ACAT II and III programs.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation and stated that it planned to review existing policy to see if revisions were needed. Since that time, DOD has taken some steps to implement this recommendation, but has not established department-wide guidelines as we recommended. Starting in September 2018, DOD began providing the military departments with a capability to identify ACAT II and III programs using the Defense Acquisition Visibility Environment (DAVE) system. The DAVE system is now considered to be a trusted source for ACAT II and III program data. DOD, in consultation with the military departments, established standard data elements for collection across ACAT II and III programs for inclusion in DAVE, but the military departments determine individually what constitutes a "current" program and the types of programs that do not require ACAT designations. As of August 2019, the Army and Navy have established guidance regarding what constitutes an active ACAT II or III program for reporting purposes. We have requested an update on DOD's recent actions to address this recommendation, but have not received information as of September 2020. We will continue to monitor DOD's progress in implementing this recommendation.

Recommendation: To improve DOD's ability to collect and maintain reliable data on its acquisitions, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology, and Logistics, in consultation with DOD components, to determine what metrics should be used and what data should be collected on ACAT II and III programs to measure cost and schedule performance; and whether the use of DAMIR and the MDAP selected acquisition report format may be appropriate for collecting data on ACAT II and III programs.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation and stated that it planned to review existing policy to see if revisions were needed. DOD has taken steps to implement this recommendation, but has yet to determine at the department level what metrics should be collected on ACAT II and III cost and schedule performance as we recommended. DOD determined that the use of the Defense Acquisition Visibility Environment (DAVE) system, which is closely related to DAMIR, was appropriate to collect information on ACAT II and III programs and has made that system available to the military departments. Specifically, DOD provided the military departments with the capability to identify ACAT II and III programs in DAVE/DAMIR in September 2018 and made the DAVE/DAMIR Acquisition Program Baseline (APB) workflow tool for cost and schedule data collection available for components' use in April 2019. However, according to officials from the Office of the Under Secretary of Defense for Acquisition and Sustainment, the military departments are responsible for individually determining what cost and schedule metrics to collect and monitor for ACAT II and III programs. According to December 2018 Army guidance, the Army will require all ACAT II and III programs use DOD's APB tool by the end of fiscal year 2019 to capture baseline cost, schedule, and performance parameters for ACAT II and III programs. According to Navy officials, the Navy is developing an APB tool in its for a future update of its acquisition information system that will collect APB cost and schedule information for ACAT II and III programs. We have requested an update on DOD's recent actions to address this recommendation, but have not received information as of September 2020. We will continue to monitor DOD's progress in implementing this recommendation.

Recommendation: To improve DOD's ability to collect and maintain reliable data on its acquisitions, the Secretary of Defense should direct the Secretaries of the Air Force, Army, and Navy and the Commander of SOCOM to assess the reliability of data collected on ACAT II and III programs and work with PEOs to develop a strategy to improve procedures for the entry and maintenance of data.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation and stated that it would direct DOD components to evaluate data on ACAT II and III programs and report back on the reliability of the data and plans to improve it. In September 2015, the Assistant Secretary of Defense directed the military departments and DOD components to assess the reliability of ACAT II and III data, but in July 2018, the Office of the Under Secretary of Defense for Acquisition & Sustainment confirmed that based on the results of the assessments reported by the components, it does not plan to take any additional action to implement this recommendation. Since that time, as of September 2018, DOD began providing standard data elements and definitions of those elements that it collects for ACAT II and III program identification in order to improve the consistency of data. However, officials from the Office of the Under Secretary of Defense for Acquisition and Sustainment stated that it is still up to the military departments to ensure the accuracy of data entered. We have requested an update on DOD's recent actions to address this recommendation, but have not received information as of September 2020. We will continue to monitor DOD's progress in implementing this recommendation.

Recommendation: To improve DOD's ability to collect and maintain reliable data on its acquisitions, the Secretary of Defense should direct the Secretaries of the Air Force, Army, and Navy and the Commander of SOCOM to develop implementation plans to coordinate and execute component initiatives to improve data on ACAT II and III programs.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation and stated that it would direct DOD components to evaluate data on ACAT II and III programs and report back plans to improve it. In September 2015, the Office of the Assistant Secretary of Defense for Acquisition requested that DOD components provide an update on their plans to improve the availability and quality of ACAT II and III data. In July 2018, the Office of the Under Secretary of Defense for Acquisition & Sustainment confirmed that based on an assessment of the information reported by the components, it does not plan to take any additional action to implement this recommendation. Officials from the Office of the Under Secretary of Defense for Acquisition & Sustainment reiterated in August 2019 that while DOD now provides a department-wide system to be used for collecting basic program data for ACAT II and III programs, it remains the responsibility of the military departments to enter complete and accurate data. We have requested an update on DOD's recent actions to address this recommendation, but have not received information as of September 2020. We will continue to monitor DOD's progress in implementing this recommendation.

Recommendation: To help ensure compliance with relevant provisions of DOD acquisition policy with the purpose of improving DOD's ability to provide oversight for ACAT II and III programs, including those programs that may become MDAPs, the Secretary of Defense should direct the Secretary of the Air Force and Commander of SOCOM to establish a mechanism to ensure compliance with APB requirements in DOD policy.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation and stated that the Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics would issue guidance to DOD components related to APB requirements for ACAT II and III programs. DOD has taken some steps related to this recommendation. In September 2015, the Office of the Assistant Secretary of Defense for Acquisition requested that DOD components review their mechanisms for establishing and enforcing the APB requirements for all ACAT II and III programs. In July 2018, the Office of the Under Secretary of Defense for Acquisition & Sustainment confirmed that, based on the results of these reviews, it does not plans to take any action to implement this recommendation. However, in 2019, DOD made its DAVE/DAMIR APB workflow tool available for military department use, and the Air Force elected to use the tool to create and track APBs for ACAT II and III programs. We have requested an update on DOD's recent actions to address this recommendation, but have not received information as of September 2020. We will continue to monitor DOD's progress in implementing this recommendation.

Recommendation: To help ensure compliance with relevant provisions of DOD acquisition policy with the purpose of improving DOD's ability to provide oversight for ACAT II and III programs, including those programs that may become MDAPs, the Secretary of Defense should direct the Secretaries of the Air Force, Army, and Navy to improve component procedures for notifying the Defense Acquisition Executive of programs with a cost estimate within 10 percent of ACAT I cost thresholds.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation and stated that the Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics would issue guidance to DOD components related to notification requirements for programs approaching ACAT I cost thresholds. The Army and Navy have reiterated existing guidance and the Air Force is evaluating additional actions it might take to improve its notification procedures. The Office of the Under Secretary of Defense for Acquisition & Sustainment confirmed in July 2018 that it does not plan to take additional actions to implement this recommendation, and as of August 2019, that office has not directed DOD components to improve their processes as we recommended .We have requested an update on DOD's recent actions to address this recommendation, but have not received information as of September 2020. We will continue to monitor DOD's progress in implementing this recommendation.

Recommendation: To improve the reliability and reporting of investment performance information and management of selected major investments, the Commissioner of the IRS should direct the Chief Technology Officer to modify reporting of the Affordable Care Act Administration testing status to senior management to include a comprehensive report on all impacted systems--including an explanation for why impacted systems were not tested at a particular level--and ensure this reporting is aligned with the manner in which testing is being performed.

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

Comments: IRS disagreed with this recommendation at the time we made it stating that it followed a rigorous risk-based process for planning the tests of ACA-impacted systems, including the types and levels of testing, and that it had comprehensive reporting for the filing season 2015 release, which included ACA impacted systems. However, as noted in our report, our review of ACA Testing Review Checkpoint reports and filing season reports, which officials stated were used to provide comprehensive reports to senior managers, did not identify the status of testing for all systems impacted by ACA Releases 5.0 and 6.0. In September 2017, IRS finished developing ACA and the investment transitioned to the operations and maintenance phase. We followed up with IRS to determine the extent to which it might be implementing the recommendation in light of this transition. In response, in June and December 2019 , IRS provided some documentation, including systems acceptance test plans and end-of-test results reports for ACA releases completed since September 2017. We reviewed the documentation provided and determined that it did not provide a status of testing for all systems impacted as we recommended. As of September 2020, we were following up with IRS to determine if the agency has other documentation provided to senior managers that addresses our recommendation.

Recommendation: To help improve DOD, State, and USAID's ability to track contracts and contractor personnel in contingency operations and to help ensure that DOD possesses the capability to collect and report statutorily required information and to clarify responsibilities and procedures, the Secretary of Defense should direct the Under Secretary of Defense for Acquisition, Technology and Logistics to update SPOT provisions during the process of updating operational contract support guidance.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. In August 2018, the office of the Assistant Secretary of Defense for Logistics and Materiel Readiness reported that an update of DOD Instruction 3020.41 is in progress, and will include updated SPOT provisions. However, as of August 2020, the updated instruction had not been issued.

Recommendation: To help improve DOD, State, and USAID's ability to track contracts and contractor personnel in contingency operations and to provide clarity about expectations for the Joint Asset Movement Management System (JAMMS) that can help improve the timeliness and reliability of data for SPOT-ES from JAMMS uploads, the Secretary of Defense should direct the Chairman of the Joint Chiefs of Staff, in coordination with the combatant commanders, to develop comprehensive guidance regarding the purpose of JAMMS and its role in supporting plans for different types of missions. Such guidance could include direction on the number and location of JAMMS terminals and how frequently JAMMS's data should be uploaded into SPOT-ES to meet DOD's information needs.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with our recommendation. DOD stated that it agreed to provide clarity regarding the purpose and use of JAMMS to improve the timeliness and reliability of JAMMS data, though it did not agree that such guidance could include direction on the number and location of JAMMS terminals and how frequently JAMMS's data should be uploaded into SPOT-ES. DOD stated that it would revise language in DOD Instruction 3020.41, Operational Contract Support, to reflect in policy the requirement to use the entire SPOT Enterprise Suite (SPOT-ES), which includes JAMMS. DOD also stated that the combatant commander should establish the requirements for terminal quantities and locations and for data upload schedules based on operational needs in the relevant theater. We agreed with DOD that the combatant commands need flexibility based on operational requirements. In August 2018, the office of the Assistant Secretary of Defense for Logistics & Materiel Readiness reported that the update to DOD Instruction 3020.41 is in progress and will clarify information on the JAMMS capability. However, as of August 2020, the updated instruction had not been issued. Updated SPOT-ES Business Rules dated May 10, 2018 incorporate the role of JAMMS in maintaining visibility of contractor personnel.

Recommendation: To ensure that OPM builds the predictive capacity to identify emerging skills gaps across the government--including the ability to collect and use reliable information on the competencies of the federal workforce for government-wide workforce analysis--the Director of OPM should (1) establish a schedule specifying when OPM will modify its Enterprise Human Resources Integration database to capture staffing data that it currently collects from agencies through its annual workforce data reporting process; and (2) work with agency CHCOs to bolster the ability of agencies to assess workforce competencies by sharing competency surveys, lessons learned, and other tools and resources.

Agency: Office of Personnel Management
Status: Open
Priority recommendation

Comments: Although OPM did not initially concur with this recommendation, OPM has taken actions towards addressing it by using the EHRI database, in combination with other sources, to generate workforce data to assist agencies in their efforts to identify skills gaps. In March 2019, OPM reported that it believed that collecting staffing gap targets through an alternative system, MAX Collect, would provide a more efficient and accurate means to collect workforce data than EHRI. In February 2020, OPM officials reported that it has used MAX Collect to address a portion of the recommendation by sharing lessons learned to close skills gaps. MAX Collect also stores and makes relevant tools and training available to users. However, OPM still needs to collect and store a consistent set of staffing and competency data. Without the collection and sharing of this data, OPM cannot perform valuable government-wide analysis to predict and address skills gaps in occupations affecting multiple agencies.

Recommendation: If, in the next authorization for FAA, Congress chooses to mandate that FAA take actions to streamline and reform the agency, Congress may wish to consider requiring FAA to (1) track measures of and (2) report to Congress on the actual results of such efforts.

Agency: Congress
Status: Open

Comments: As of March 2019, Congress has passed several FAA authorization extensions and the FAA Reauthorization Act of 2018 that did not include any actions related to this matter. We will continue to monitor legislation, and when we determine what steps the Congress has taken regarding this matter, we will provide updated information.

Recommendation: To ensure that federal regulators have better information about lump sum windows and to better ensure that participants have ready access to key information they need to make a decision when presented with a lump sum offer, the Department of Labor should require plan sponsors to notify DOL at the time they implement a lump sum window offer, including the number and category of participants being extended the offer (e.g., separated vested; retiree) as well as examples of the materials provided to them.

Agency: Department of Labor
Status: Open

Comments: The Department of Labor (DOL) agreed that this type of information may be helpful in determining the extent to which lump sum window offers are made, as well as the types of disclosures the participants receive. However, as of July 2017, DOL reported that it has not identified authority under ERISA for it to impose such a requirement on plan sponsors either before or shortly after the plan offers the lump sum window. The agency states that ERISA expressly provides specific reporting and disclosure requirements. These include various filings, such as annual financial reports, reports upon plan termination, and reports upon making certain transfers of pension plan assets to health benefit accounts. The agency believes ERISA does not require plans to notify them regarding the benefit distribution options they offer or changes in those options, and does not read the broad rulemaking authority in ERISA in Section 505 (general regulations) and Section 110 (pension reporting and disclosure) as authorizing EBSA to establish the notice filing requirement GAO recommended. The agency also commented that ERISA expressly requires that most pension plans file a Form 5500 annual report with the statute specifying the required contents of this annual report in some detail and requiring "such other financial and actuarial information as the Secretary may find necessary or appropriate." Although the agency noted it could, by regulation, require reporting on lump sum window offers on the Form 5500, there would be a substantial time lag because ERISA by statute establishes the reporting cycle for the Form 5500 -- the report is not due until 210 days (7 months) after the plan year closes (e.g., for calendar year plans, July 31st of the following year). The agency recognizes that this might not be responsive to the recommendation, which appears to envision a notification system that is relatively contemporaneous with the lump sum window being offered to participants and beneficiaries. In 2018, DOL noted that it allocated its regulatory resources to other priority projects and, as of June 2020, reported that this status remains unchanged.

Recommendation: To ensure that federal regulators have better information about lump sum windows and to better ensure that participants have ready access to key information they need to make a decision when presented with a lump sum offer, the Department of Labor should coordinate with the Internal Revenue Service and the Pension Benefit Guaranty Corporation (PBGC) to clarify the guidance regarding the information sponsors should provide to participants when extending lump sum window offers and place the guidance on the agency's website. Guidance should include clear and understandable presentations of information, such as the relative value of the lump sum, the role and level of protections provided by PBGC, and the positive and negative ramifications of accepting the lump sum. Such guidance could also include promising practices for information materials from plan sponsors which are particularly effective in facilitating informed participant decision-making.

Agency: Department of Labor
Status: Open

Comments: The Department of Labor agreed with this recommendation, noting it is important to coordinate with the Treasury Department/IRS and PBGC to clarify the guidance regarding the information sponsors and other plan fiduciaries should provide to participants and beneficiaries when extending lump sum window offers. In 2016, the agency noted that the manner of publishing that guidance would be part of that coordination process. They may consider some formal public request for input (such as publishing a Request for Information in the Federal Register) and focus group or other field testing work. In addition, the agency noted that the 2015 ERISA Advisory Council announced that one of its projects this year concerns how to give participants effective notices and disclosures concerning lump sum window offers, including possible development of model participant notices. The 2015 Council developed recommendations and model notices on lump sum window offers in "pension risk transfer transactions," and suggested that DOL make the Model Notices available on its web site to plan sponsors and participant advocates and that plan sponsors use the Model Notices when engaging in risk transfer transactions. Similar to other model communications developed by the 2015 Council, the agency believes the model notice could be further enhanced if subjected to broader public input from, for example, plan sponsors, participant advocates, communications experts, and academics. Subject to the limits on its authority in this area and resource constraints. They are considering efforts to obtain public input on the Council's recommendations and model notice. They also intend to contact the Treasury Department/IRS and PBGC to discuss the Council's recommendations. In 2017, EBSA reported that it does not have a specific timeline for any next action but would alert GAO if a decision is made to add such a project to EBSA's agenda. In 2018, DOL noted that it allocated its regulatory resources to other priority projects and, as of June 2020, reported no additional changes.

Recommendation: To provide participants with useful information and to provide for lump sums that are based on up-to-date assumptions, Treasury should review its regulations governing the information contained in relative value statements to ensure these statements provide a meaningful comparison of all benefit options, especially in instances where the loss of certain additional plan benefits may not be disclosed.

Agency: Department of the Treasury
Status: Open

Comments: Treasury generally agreed with this recommendation but did not provide specific comments on plans to address it. As of August 2019, Treasury has not addressed this recommendation.

Recommendation: To provide participants with useful information and to provide for lump sums that are based on up-to-date assumptions, Treasury should review the applicability and appropriateness of allowing sponsors to select a "lookback" interest rate for use in calculating lump sums associated with a lump sum window that can serve to advantage the interests of the sponsor.

Agency: Department of the Treasury
Status: Open

Comments: Treasury generally agreed with this recommendation but did not provide specific comments on plans to address it. As of August 2019, Treasury has not addressed this recommendation.

Recommendation: To provide participants with useful information and to provide for lump sums that are based on up-to-date assumptions, Treasury should establish a process and a timeline for periodically updating the mortality tables used to determine minimum required lump sums-- including a means for monitoring when experts' views may indicate that mortality tables may have become outdated, and for taking expedited action if warranted.

Agency: Department of the Treasury
Status: Open

Comments: Treasury generally agreed with this recommendation but did not provide specific comments on plans to address it. As of August 2019, Treasury has not addressed this recommendation.

Recommendation: To better ensure that FBI whistleblowers have access to recourse under DOJ's regulations should the individuals experience retaliation, and to minimize the possibility of discouraging future potential whistleblowers, the Attorney General should clarify in all current relevant DOJ guidance and communications, including FBI guidance and communications, to whom FBI employees may make protected disclosures and, further, explicitly state that employees will not have access to recourse if they experience retaliation for reporting alleged wrongdoing to someone not designated in DOJ's regulations.

Agency: Department of Justice
Status: Open
Priority recommendation

Comments: In response to our report, in December 2016, Congress passed and the President signed the FBI Whistleblower Protection Enhancement Act of 2016, Pub. L. No. 114-302, which, among other things, provides a means for FBI employees to obtain corrective action for retaliation for disclosures of wrongdoing made to supervisors and others in the employees' chain of command. Following this, the FBI worked closely with the Department of Justice's Office of Inspector General (DOJ-OIG) to develop a training that clearly identifies to whom FBI employees may make protected disclosures. In addition, the FBI issued an aligned policy directive and two fact sheets detailing whistleblower rights. In October 2018, a DOJ official reported to us that the department was in the process of updating its regulations and, in February 2020, DOJ officials confirmed that the updated regulation was in the departmental clearance process but they could not provide an estimate for when it would be finalized. As a result, as of February 2020, DOJ's regulations have not been updated and are inconsistent with the current statute and FBI's guidance and training; as such, the problem of unclear or conflicting guidance to FBI employees still needs to be addressed. To address this recommendation, DOJ would need to update its regulations and ensure that all relevant guidance is clear and consistent across the department.

Recommendation: To help ensure that FSOC is comprehensively identifying and considering companies, the Secretary of the Treasury in consultation with FSOC members, should establish procedures to evaluate companies in Stage 2 and Stage 3 under both statutory determination standards when an evaluation in either stage concludes that a company does not meet one of the standards, or document--on a company-specific or more general basis--why the second determination standard is not relevant for determination evaluations.

Agency: Department of the Treasury: Financial Stability Oversight Council
Status: Open

Comments: In December 2019, FSOC adopted final interpretive guidance that revises its approach to evaluating and determining whether to designate nonbank financial companies. The final revised guidance prioritizes an activities-based approach to identifying and addressing potential risks to financial stability and states that FSOC will pursue company-specific determinations only if the activities-based approach is not sufficient. The guidance further states that if FSOC does consider a company-specific determination, its evaluation will focus primarily on the first determination standard. The guidance does not indicate the establishment of procedures to evaluate companies under both determination standards for the purpose of comprehensively identifying and considering companies or to document why the other standard is not relevant. We will continue to monitor FSOC's implementation of the guidance and any additional actions that may be responsive to our recommendation.

Recommendation: To help ensure that FSOC is comprehensively identifying and considering companies, the Secretary of the Treasury in consultation with FSOC members, should develop a process to collect information necessary for Stage 1 analysis, as appropriate, from certain nonbank financial companies for which public or regulatory information is otherwise unavailable. For example, FSOC could have companies for which such information is unavailable and that meet certain characteristics (such as quantitative thresholds similar to those used in Stage 1) report necessary information to the Office of Financial Research.

Agency: Department of the Treasury: Financial Stability Oversight Council
Status: Open

Comments: In December 2019, FSOC adopted final interpretive guidance that revises its approach to evaluating and determining whether to designate nonbank financial companies. The final revised guidance introduces a new stage 1 of the designation process in which FSOC would notify a nonbank financial company under review and consider available public and regulatory information. While the guidance states that a company under review in stage 1 may submit information it deems relevant to the evaluation, FSOC would not require the company to submit information during stage 1. We will continue to monitor FSOC's implementation of the revised guidance and any additional actions that may be responsive to our recommendation.

Recommendation: To improve the management of DHS FOIA requests, the Secretary of DHS should direct the Chief FOIA Officer to improve reporting of FOIA costs by including salaries, employee benefits, non-personnel direct costs, indirect costs, and costs for other offices.

Agency: Department of Homeland Security
Status: Open

Comments: As of August 2020, we have followed up with the department to request documentation but have not yet received evidence of DHS's planned actions to address this recommendation.

Recommendation: To improve the management of DHS FOIA requests, the Secretary of DHS should direct the Chief FOIA Officer to direct USCIS and Coast Guard to fully implement the recommended FOIA processing system capabilities and the section 508 requirement.

Agency: Department of Homeland Security
Status: Open

Comments: As of August 2020, we have followed up with the department to request documentation but have not yet received evidence of DHS's planned actions to address this recommendation.

Recommendation: To improve the management of DHS FOIA requests, the Secretary of DHS should direct the Chief FOIA Officer to determine the viability of re-establishing the service-level agreement between the U.S. Citizenship and Immigration Services (USCIS) and U.S. Immigration and Customs Enforcement to eliminate duplication in the processing of immigration files. If the benefits of doing so would exceed the costs, re-establish the agreement.

Agency: Department of Homeland Security
Status: Open

Comments: As of August 2020, we have followed up with the department to request documentation but have not yet received evidence of DHS's planned actions to address this recommendation.

Recommendation: To ensure the effective implementation of federal program inventory requirements and to make the inventories more useful, the Director of OMB should, to better present a more coherent picture of all federal programs, revise relevant guidance to direct agencies to collaborate with each other in defining and identifying programs that contribute to common outcomes.

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

Comments: As of October 2020, the Office of Management and Budget (OMB) had not taken any actions in response to our recommendations related to the federal program inventory. Although OMB published an initial inventory covering the programs of 24 federal agencies in May 2013, OMB decided to postpone further development of the inventory in order to coordinate with the implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act). In its June 2019 and July 2020 updates to Circular No. A-11, OMB provided a time frame for doing so. OMB's guidance states that beginning with the 2021 budget cycle, agencies' program activities will be used for the inventory's program-level reporting requirements. This will allow OMB and agencies to present program-level spending data, by leveraging what is reported on USASpending.gov as required by the DATA Act. However, OMB's guidance does not cover other inventory information reporting requirements, nor the actions we recommended. We will continue to monitor progress.

Recommendation: To ensure the effective implementation of federal program inventory requirements and to make the inventories more useful, the Director of OMB should, to better present a more coherent picture of all federal programs, revise relevant guidance to provide a time frame for what constitutes "persistent over time" that agencies can use as a decision rule for whether to include short-term efforts as programs.

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

Comments: As of October 2020, the Office of Management and Budget (OMB) had not taken any actions in response to our recommendations related to the federal program inventory. Although OMB published an initial inventory covering the programs of 24 federal agencies in May 2013, OMB decided to postpone further development of the inventory in order to coordinate with the implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act). In its June 2019 and July 2020 updates to Circular No. A-11, OMB provided a time frame for doing so. OMB's guidance states that beginning with the 2021 budget cycle, agencies' program activities will be used for the inventory's program-level reporting requirements. This will allow OMB and agencies to present program-level spending data, by leveraging what is reported on USASpending.gov as required by the DATA Act. However, OMB's guidance does not cover other inventory information reporting requirements, nor the actions we recommended. We will continue to monitor progress.

Recommendation: To ensure the effective implementation of federal program inventory requirements and to make the inventories more useful, the Director of OMB should, to better present a more coherent picture of all federal programs, define plans for when additional agencies will be required to develop program inventories.

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

Comments: As of October 2020, the Office of Management and Budget (OMB) had not taken any actions in response to our recommendations related to the federal program inventory. Although OMB published an initial inventory covering the programs of 24 federal agencies in May 2013, OMB decided to postpone further development of the inventory in order to coordinate with the implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act). In its June 2019 and July 2020 updates to Circular No. A-11, OMB provided a time frame for doing so. OMB's guidance states that beginning with the 2021 budget cycle, agencies' program activities will be used for the inventory's program-level reporting requirements. This will allow OMB and agencies to present program-level spending data, by leveraging what is reported on USASpending.gov as required by the DATA Act. However, OMB's guidance does not cover other inventory information reporting requirements, nor the actions we recommended. We will continue to monitor progress.

Recommendation: To ensure the effective implementation of federal program inventory requirements and to make the inventories more useful, the Director of OMB should, to better present a more coherent picture of all federal programs, include tax expenditures in the federal program inventory effort by designating tax expenditure as a program type in relevant guidance.

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

Comments: No executive action has been taken. As of October 2020, OMB had not taken action to include tax expenditures in the federal program inventory, as GAO recommended in October 2014. The GPRA Modernization Act of 2010 requires OMB to publish a list of all federal programs on a central, government-wide website. The federal program inventory is the primary tool for agencies to identify programs that contribute to their goals, according to OMB's guidance. Although OMB published an initial inventory covering the programs of 24 federal agencies in May 2013, OMB decided to postpone further development of the inventory in order to coordinate with the implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act). In June 2019 and July 2020, OMB issued guidance (Circular No. A-11) that states that beginning with the 2021 budget cycle, agencies' program activities will be used for the inventory's program-level reporting requirements. According to OMB, this will allow OMB and agencies to present program-level spending data, by leveraging what is reported on USASpending.gov as required by the DATA Act. However, OMB's guidance does not cover other inventory information reporting requirements nor the actions GAO recommended including designating tax expenditures as a program type. By including tax expenditures in the inventory, OMB could help ensure that agencies are properly identifying the contributions of tax expenditures to the achievement of their goals.

Recommendation: To ensure the effective implementation of federal program inventory requirements and to make the inventories more useful, the Director of OMB should, to better present a more coherent picture of all federal programs, include tax expenditures in the federal program inventory effort by developing, in coordination with the Secretary of the Treasury, a tax expenditure inventory that identifies each tax expenditure and provides a description of how the tax expenditure is defined, its purpose, and related performance and budget information.

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

Comments: No executive action has been taken. As of October 2020, OMB had not taken action to include tax expenditures in the federal program inventory, as GAO recommended in October 2014. The GPRA Modernization Act of 2010 requires OMB to publish a list of all federal programs on a central, government-wide website. The federal program inventory is the primary tool for agencies to identify programs that contribute to their goals, according to OMB's guidance. Although OMB published an initial inventory covering the programs of 24 federal agencies in May 2013, OMB decided to postpone further development of the inventory in order to coordinate with the implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act). In June 2019 and July 2020, OMB issued guidance (Circular No. A-11) that states that beginning with the 2021 budget cycle, agencies' program activities will be used for the inventory's program-level reporting requirements. According to OMB, this will allow OMB and agencies to present program-level spending data, by leveraging what is reported on USASpending.gov as required by the DATA Act. However, OMB's guidance does not cover other inventory information reporting requirements nor the actions GAO recommended including designating tax expenditures as a program type. By including tax expenditures in the inventory, OMB could help ensure that agencies are properly identifying the contributions of tax expenditures to the achievement of their goals.

Recommendation: To ensure the effective implementation of federal program inventory requirements and to make the inventories more useful, the Director of OMB should, to help ensure that the information agencies provide in their inventories is useful to federal decision makers and key stakeholders, and to provide greater transparency and ensure consistency in federal program funding and performance information, revise relevant guidance to direct agencies to consult with relevant congressional committees and stakeholders on their program definition approach and identified programs when developing or updating their inventories.

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

Comments: As of October 2020, the Office of Management and Budget (OMB) had not taken any actions in response to our recommendations related to the federal program inventory. Although OMB published an initial inventory covering the programs of 24 federal agencies in May 2013, OMB decided to postpone further development of the inventory in order to coordinate with the implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act). In its June 2019 and July 2020 updates to Circular No. A-11, OMB provided a time frame for doing so. OMB's guidance states that beginning with the 2021 budget cycle, agencies' program activities will be used for the inventory's program-level reporting requirements. This will allow OMB and agencies to present program-level spending data, by leveraging what is reported on USASpending.gov as required by the DATA Act. However, OMB's guidance does not cover other inventory information reporting requirements, nor the actions we recommended. We will continue to monitor progress.

Recommendation: To ensure the effective implementation of federal program inventory requirements and to make the inventories more useful, the Director of OMB should, to help ensure that the information agencies provide in their inventories is useful to federal decision makers and key stakeholders, and to provide greater transparency and ensure consistency in federal program funding and performance information, revise relevant guidance to direct agencies to identify in their inventories the performance goal(s) to which each program contributes.

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

Comments: As of October 2020, the Office of Management and Budget (OMB) had not taken any actions in response to our recommendations related to the federal program inventory. Although OMB published an initial inventory covering the programs of 24 federal agencies in May 2013, OMB decided to postpone further development of the inventory in order to coordinate with the implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act). In its June 2019 and July 2020 updates to Circular No. A-11, OMB provided a time frame for doing so. OMB's guidance states that beginning with the 2021 budget cycle, agencies' program activities will be used for the inventory's program-level reporting requirements. This will allow OMB and agencies to present program-level spending data, by leveraging what is reported on USASpending.gov as required by the DATA Act. However, OMB's guidance does not cover other inventory information reporting requirements, nor the actions we recommended. We will continue to monitor progress.

Recommendation: To ensure the effective implementation of federal program inventory requirements and to make the inventories more useful, the Director of OMB should, to help ensure that the information agencies provide in their inventories is useful to federal decision makers and key stakeholders, and to provide greater transparency and ensure consistency in federal program funding and performance information, ensure, during OMB reviews of inventories, that agencies consistently identify, as applicable, the strategic goals, strategic objectives, agency priority goals, and cross-agency priority goals each program supports.

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

Comments: As of October 2020, the Office of Management and Budget (OMB) had not taken any actions in response to our recommendations related to the federal program inventory. Although OMB published an initial inventory covering the programs of 24 federal agencies in May 2013, OMB decided to postpone further development of the inventory in order to coordinate with the implementation of the Digital Accountability and Transparency Act of 2014 (DATA Act). In its June 2019 and July 2020 updates to Circular No. A-11, OMB provided a time frame for doing so. OMB's guidance states that beginning with the 2021 budget cycle, agencies' program activities will be used for the inventory's program-level reporting requirements. This will allow OMB and agencies to present program-level spending data, by leveraging what is reported on USASpending.gov as required by the DATA Act. However, OMB's guidance does not cover other inventory information reporting requirements, nor the actions we recommended. We will continue to monitor progress.

Recommendation: To help ensure that agencies report comparable and reliable data to Enterprise Human Resources Integration (EHRI), the Director of OPM, in coordination with agencies and payroll service providers, should develop guidance for agencies on which activities to enter, or not enter, as paid administrative leave in agency time and attendance systems.

Agency: Office of Personnel Management
Status: Open

Comments: To address agency use of paid administrative leave that may exceed reasonable amounts as well as discrepancies in recording and reporting paid administrative leave, in December 2016, Congress passed the "Administrative Leave Act of 2016." The act mandates new categories of paid leave, including "investigative leave," "notice leave," and "weather and safety leave" and sets limitations on the duration of paid administrative leave as well as the new categories of investigative and notice leave. The Act also requires OPM to establish regulations on (1) when to grant administrative leave and the other new categories of paid leave, and (2) the proper recording and reporting of these types of paid leave. In July 2017, OPM proposed new rules to regulate paid administrative leave, but has not finalized all these rules. In April 2018, OPM issued final regulations for "weather and safety leave" and announced that it would issue separate final regulations for "administrative leave," "investigative leave," and "notice leave" at a later date. In July 2019, OPM officials told us that they have not finalized the remaining regulations due to legal and practical concerns related to employees serving overseas. For example, the proposed rules could conflict with overseas personnel observing local holidays for security, diplomatic, and practical reasons. OPM also announced that it is reconvening its interagency working group for dismissal and closure procedures to update its "DC Dismissal and Closure Procedures" guidance to reflect the new "weather and safety leave" procedures. In addition, in response to our recommendation, in May 2015, OPM issued a fact sheet on administrative leave, which discusses the appropriate use of an agency's administrative leave authority, including a definition of administrative leave as well as applicable government-wide, individual agency, and emergency policies on the use of administrative leave. However, this fact sheet will need to be revised to reflect the newly issued regulations for "weather and safety leave" in addition to the regulations for the other categories of paid leave when they are in effect. Once all regulations are finalized, the proposed rules, along with updated fact sheet guidance, should help agencies and federal employees appropriately use, record, and report administrative leave. We will be contacting OPM to receive an update on the status of this recommendation once all the regulations are finalized and the fact sheet guidance is revised.

Recommendation: To help ensure that agencies report comparable and reliable data to EHRI, the Director of OPM, in coordination with agencies and payroll service providers, should provide updated and specific guidance to payroll service providers on which activities to report, or not report, to the paid administrative leave data element in EHRI.

Agency: Office of Personnel Management
Status: Open

Comments: To address agency use of paid administrative leave that may exceed reasonable amounts as well as discrepancies in recording and reporting paid administrative leave, in December 2016, Congress passed the "Administrative Leave Act of 2016." The act mandates new categories of paid leave, including "investigative leave," "notice leave," and "weather and safety leave" and sets limitations on the duration of paid administrative leave as well as the new categories of investigative and notice leave. The Act also requires OPM to establish regulations on (1) when to grant administrative leave and the other new categories of paid leave, and (2) the proper recording and reporting of these types of paid leave. In July 2017, OPM proposed new rules to regulate paid administrative leave, but has not finalized all these rules. In April 2018, OPM issued final regulations for "weather and safety leave" and announced that it would issue separate final regulations for "administrative leave," "investigative leave," and "notice leave" at a later date. To accompany the final regulations for "weather and safety leave," OPM issued two new data standards for agencies to report Paid Holiday Time Off and Weather and Safety Leave Hours Used that became effective in May 2018. Also, in November 2018, OPM released an update to its "DC Dismissal and Closure Procedures" guidance to reflect the new "weather and safety leave" procedures. Once all regulations are finalized, the proposed rules, along with updated guidance to payroll providers for reporting paid administrative leave and the new leave categories, should help agencies report comparable and reliable data to EHRI. We will be contacting OPM to receive an update on the status of this recommendation once the regulations are finalized and the guidance is revised.

Recommendation: To ensure that the Corps meets the statutory requirements related to deauthorization of projects, the Secretary of Defense should direct the Secretary of the Army to direct the Chief of Engineers and Commanding General of the U.S. Army Corps of Engineers to determine what projects are eligible for deauthorization, transmit the list to Congress, and publish projects that are deauthorized in the Federal Register once the new database includes all authorized projects.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation. The Corps developed a list of projects for deauthorization in accordance with the Water Resources Development Act (WRDA) of 1986, Section 1001, and provided the list to OMB for clearance on January 26, 2018. Additionally, on December 9, 2019, the Corps reported that it provided a list of projects eligible for deauthorization in FY 2020 to the Assistant Secretary of the Army for Civil Works for review. Upon approval, the list will be sent to OMB for clearance. After receiving OMB clearance, according to the Corps, the list will be provided to Congress and the public in accordance with WRDA. As of July 2020, we are continuing to monitor the Corps' progress in implementing the recommendation.

Recommendation: To ensure that the Corps meets the statutory requirements related to deauthorization of incomplete water resources studies, the Secretary of Defense should direct the Secretary of the Army to direct the Chief of Engineers and Commanding General of the U.S. Army Corps of Engineers to determine what studies are eligible for deauthorization and transmit the list to Congress.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and as of December 2016, a task order has been awarded for a contractor to prepare a comprehensive inventory of studies authorized by statute. The Corps reported that once the comprehensive inventory of studies is complete, the Corps will develop policies and procedures for the study deauthorization process and those policies and procedures will be used to carry out the process of deauthorizing studies. In March 2020, the Corps reported that it was working to develop a scheduled for providing us with a list of studies eligible for deathorization. As of July 2020, we are continuing to monitor the Corps' progress in implementing the recommendation.

Recommendation: To improve the completeness and accuracy of data submissions to the USASpending.gov website, the Director of the Office of Management and Budget, in collaboration with Treasury's Fiscal Service, should clarify guidance on (1) agency responsibilities for reporting awards funded by non-annual appropriations; (2) the applicability of USASpending.gov reporting requirements to non-classified awards associated with intelligence operations; (3) the requirement that award titles describe the award's purpose (consistent with our prior recommendation); and (4) agency maintenance of authoritative records adequate to verify the accuracy of required data reported for use by USASpending.gov.

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

Comments: OMB has taken several steps related to this recommendation as of December 2019, but have not fully addressed it. Specifically, working with the Department of the Treasury to implement the DATA Act, OMB took partial action on two aspects of the recommendation and are still considering actions on two others. 1) OMB staff said they continue to deliberate on agency responsibilities for reporting awards funded by non-annual appropriations. 2) OMB staff provided a Frequently Asked Question (FAQ) addressing the applicability of USASpending.gov reporting requirements for recipient information related to classified or sensitive information. GAO reviewed the FAQ and determined that additional guidance is still needed to ensure complete reporting of unclassified awards as required by FFATA. 3) OMB staff have agreed that it will be important to clarify guidance on how agencies can report on award titles that appropriately describes the awards' purposes and noted that they are working on providing additional guidance to agencies as part of their larger DATA Act implementation efforts. 4) OMB released policy guidance in May 2016 (MPM 2016-03) that identifies the authoritative sources for reporting procurement and award data. However, GAO's review of this policy guidance determined that it does not address the underlying source that can be used to verify the accuracy of non-financial procurement data or any source for data on assistance awards.

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

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

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

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

Recommendation: To improve subsequent joint reports to Congress on plans for sustaining and modernizing U.S nuclear weapons capabilities and to improve the transparency of the joint report's methodologies, thereby assisting Congress in understanding the basis for DOD's NC3 estimates in subsequent joint reports, the Secretary of Defense should direct the DOD Chief Information Officer to document in the report the methodological assumptions and limitations affecting the report's estimates for sustaining and modernizing the NC3 system.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. In the Fiscal Year 2019 Joint Report issued in November 2018, DOD had taken steps to update its methodology for estimating nuclear command, control, and communications (NC3) funding. For example, DOD provided more information on the methodologies used to develop budget estimates. However, the methodology reported for NC3 estimates is still not transparent and DOD should provide additional information beyond what the methodology in the joint report to clarify differences with the Future Year Defense Program. According to DOD officials, actions will be taken to incorporate a more robust methodology that takes into account these issues in the FY 2020 Joint Report. We will re-evaluate DOD's implementation of this recommendation when we review the FY 2020 joint report.

Recommendation: To improve IRS's enforcement and compliance efforts, decrease the administrative and financial burden of maintaining both electronic and paper-based form processing systems, and reduce plan reporting costs, Congress should consider providing the Department of the Treasury with the authority to require that the Form 5500 series be filed electronically.

Agency: Congress
Status: Open

Comments: As of 05/01/2019, Congress has taken no action.

Recommendation: To improve the usefulness, reliability, and comparability of Form 5500 data for all stakeholders while limiting the burden on the filing community, the Secretaries of DOL and Treasury, and the Director of PBGC should consider implementing the findings from our panel when modifying plan investment and service provider fee information, including: (1) revising Schedule H plan asset categories to better match current investment vehicles and provide more transparency into plan investments; (2) revising the Schedule of Assets attachments to create a standard searchable format; (3) developing a central repository for EIN and PN numbers for filers and service providers to improve the comparability of form data across filings; (4) clarifying Schedule C instructions for direct, eligible indirect, and reportable indirect compensation so plan fees are reported more consistently and, as we recommended in the past, better align with the 408(b)(2) fee disclosures; and (5) simplifying and clarify Schedule C service provider codes to increase reporting consistency.

Agency: Department of Labor
Status: Open

Comments: As August 2018, DOL continues to accept meetings with interested stakeholders on issues related to its 5500 Modernization Project. However, EBSA does not at this time have an expected next action date for this project. The decision was made in the development and clearance of its Spring 2018 regulatory agenda to classify this project as a long-term action.

Recommendation: To improve the usefulness, reliability, and comparability of Form 5500 data for all stakeholders while limiting the burden on the filing community, the Secretaries of DOL and Treasury, and the Director of PBGC should consider implementing the findings from our panel when modifying plan investment and service provider fee information, including: (1) revising Schedule H plan asset categories to better match current investment vehicles and provide more transparency into plan investments; (2) revising the Schedule of Assets attachments to create a standard searchable format; (3) developing a central repository for EIN and PN numbers for filers and service providers to improve the comparability of form data across filings; (4) clarifying Schedule C instructions for direct, eligible indirect, and reportable indirect compensation so plan fees are reported more consistently and, as we recommended in the past, better align with the 408(b)(2) fee disclosures; and (5) simplifying and clarify Schedule C service provider codes to increase reporting consistency.

Agency: Department of the Treasury
Status: Open

Comments: In 2016, DOL in coordination with IRS and PBGC has implemented cross-year edit checks into EFAST in an effort to improve the consistency in key identifying information, such as the EIN, Plan Number and Plan Name. These checks aim to verify identifying information submitted on the Form 5500 and to notify the filer and government agencies of inconsistencies, which affords filers the ability to review and modify crucial identifying information prior to submission. Additionally, if the filer chooses to submit data that may contain inconsistent information, the edit test indicators provide government users with the ability to more readily detect filings containing potential errors in the identifying information for further review and correction. IRS has also collaborated with DOL and PBGC in issuing proposed revisions to the Form 5500 Series in a Notice of Proposed Forms Revisions. The deadline for public comment ended December 5, 2016. The proposed revisions in the Notice reflect efforts of DOL, IRS, and PBGC to improve the Form 5500 reporting for filers, the public, and the agencies by among other things, (1) modernizing financial information filed by regarding plans; (2) updating fee and expense information on plan service providers with a focus on harmonizing annual reporting requirement with DOL's 408(b)(2); financial disclosure requirements; (3) enhancing the ability to mine data files on annual returns/reports; and (4) improving compliance with ERISA and the Code through selected new questions regarding plan operation, service provider relationships, and financial management of plans. Specifically, in the Notice the agencies propose that Schedule H report assets held and assets disposed of during the plan year to provide more transparency and a more complete report of plan's annual investments and that that the Schedule of Assets be revised to require reporting of assets held through direct filing entities. Additionally, the agencies are proposing revisions to the Schedule H, Schedule of Assets that require filers to complete standardized Schedules in a format enabling data to captured electronically. This requirement would enable importation of information from the Schedules of Assets into structured databases that DOL would make available to the public from each year's Form 5500 Series filing. The agencies are also proposing to add clarifying definitions and instructions to improve the consistency of Form 5000 responses. This includes clarification of conventions to identify filers by name and identifying numbers to help mitigate confusion about legal identities with which plans transact and improve comparability of form data across filings. In addition, the agencies also propose revisions to Schedule C to require reporting of indirect compensation for service provider subject to 408(b)(2) requirements and for all compensation that is required to be disclosed. Further, the Schedule C instructions would be clarified to track more closely with the language of the 408(b)(2) regulations. The agencies are also proposing to limit the codes for Schedule C and requiring the filer to more simply indicate all types of services for each provider identified. Additionally, they propose a requirement to indicate all the types of fees/compensation separately when reporting sources of compensation from parties other than plan and plan sponsor. The agencies are reviewing the public comments and expect the process to continue through 2017. While the Agencies have made considerable efforts to address our recommendation in the proposed revisions to the Form 5500, they have not made any decisions on whether to make changes to the forms or DOL regulations, and have not decided on a timeline for implementation of any changes to the form or DOL regulations that the Agencies ultimately may decide to adopt. We will close this recommendation once the revision is final.

Recommendation: To improve the usefulness, reliability, and comparability of Form 5500 data for all stakeholders while limiting the burden on the filing community, the Secretaries of DOL and Treasury, and the Director of PBGC should consider implementing the findings from our panel when modifying plan investment and service provider fee information, including: (1) revising Schedule H plan asset categories to better match current investment vehicles and provide more transparency into plan investments; (2) revising the Schedule of Assets attachments to create a standard searchable format; (3) developing a central repository for EIN and PN numbers for filers and service providers to improve the comparability of form data across filings; (4) clarifying Schedule C instructions for direct, eligible indirect, and reportable indirect compensation so plan fees are reported more consistently and, as we recommended in the past, better align with the 408(b)(2) fee disclosures; and (5) simplifying and clarify Schedule C service provider codes to increase reporting consistency.

Agency: Pension Benefit Guaranty Corporation
Status: Open

Comments: In 2016, DOL in coordination with IRS and PBGC has implemented cross-year edit checks into EFAST in an effort to improve the consistency in key identifying information, such as the EIN, Plan Number and Plan Name. These checks aim to verify identifying information submitted on the Form 5500 and to notify the filer and government agencies of inconsistencies, which affords filers the ability to review and modify crucial identifying information prior to submission. Additionally, if the filer chooses to submit data that may contain inconsistent information, the edit test indicators provide government users with the ability to more readily detect filings containing potential errors in the identifying information for further review and correction. PBDC has also collaborated with DOL and IRS in issuing proposed revisions to the Form 5500 Series in a Notice of Proposed Forms Revisions. The deadline for public comment ended December 5, 2016. The proposed revisions in the Notice reflect efforts of DOL, IRS, and PBGC to improve the Form 5500 reporting for filers, the public, and the agencies by among other things, (1) modernizing financial information filed by regarding plans; (2) updating fee and expense information on plan service providers with a focus on harmonizing annual reporting requirement with DOL's 408(b)(2); financial disclosure requirements; (3) enhancing the ability to mine data files on annual returns/reports; and (4) improving compliance with ERISA and the Code through selected new questions regarding plan operation, service provider relationships, and financial management of plans. Specifically, in the Notice the agencies propose that Schedule H report assets held and assets disposed of during the plan year to provide more transparency and a more complete report of plan's annual investments and that that the Schedule of Assets be revised to require reporting of assets held through direct filing entities. Additionally, the agencies are proposing revisions to the Schedule H, Schedule of Assets that require filers to complete standardized Schedules in a format enabling data to captured electronically. This requirement would enable importation of information from the Schedules of Assets into structured databases that DOL would make available to the public from each year's Form 5500 Series filing. The agencies are also proposing to add clarifying definitions and instructions to improve the consistency of Form 5000 responses. This includes clarification of conventions to identify filers by name and identifying numbers to help mitigate confusion about legal identities with which plans transact and improve comparability of form data across filings. In addition, the agencies also propose revisions to Schedule C to require reporting of indirect compensation for service provider subject to 408(b)(2) requirements and for all compensation that is required to be disclosed. Further, the Schedule C instructions would be clarified to track more closely with the language of the 408(b)(2) regulations. The agencies are also proposing to limit the codes for Schedule C and requiring the filer to more simply indicate all types of services for each provider identified. Additionally, they propose a requirement to indicate all the types of fees/compensation separately when reporting sources of compensation from parties other than plan and plan sponsor. The agencies are reviewing the public comments and expect the process to continue through 2017. While the Agencies have made considerable efforts to address our recommendation in the proposed revisions to the Form 5500, they have not made any decisions on whether to make changes to the forms or DOL regulations, and have not decided on a timeline for implementation of any changes to the form or DOL regulations that the Agencies ultimately may decide to adopt. We will close this recommendation once any revision are made final.

Recommendation: To clarify the desired results of the correspondence audit program and its linkages to IRS-wide activities, the Commissioner of the Internal Revenue Service should establish formal program objectives.

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

Comments: IRS correspondence audit program officials planned a working group to develop formal program objectives. In November 2016, IRS officials provided documents intended to define the program objectives, but the objectives were unclear. As of December 2019, IRS officials provided draft program objectives to GAO for discussion and are responding to comments from GAO. We will update the status when IRS provides any further supporting documentation, as we requested in March 2020.

Recommendation: To clarify the desired results of the correspondence audit program and its linkages to IRS-wide activities, the Commissioner of the Internal Revenue Service should ensure that the program measures reflect those objectives.

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

Comments: IRS officials said that, among other actions, they plan to review and update program documentation and guidance as warranted to ensure a clear link between correspondence audit program objectives and related measures. IRS officials provided documentation in November 2016, but program measures could not be clearly linked to objectives because the objectives were not clear. As of December 2019, IRS officials provided draft measures for their draft program objectives to GAO and are responding to comments from GAO. We will update the status when IRS provides any further supporting documentation, as we requested in March 2020.

Recommendation: To clarify the desired results of the correspondence audit program and its linkages to IRS-wide activities, the Commissioner of the Internal Revenue Service should clearly link those measures with strategic IRS-wide goals on ensuring compliance in a cost-effective way while minimizing taxpayer burden.

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

Comments: IRS officials said that, among other actions, they plan to review and update program documentation and guidance as warranted to ensure that program measures clearly link to IRS strategic goals. IRS officials provided documentation in November 2016,but measures for the program could not be clearly linked to either the program objectives or IRS goals because the objectives were not clear. As of December 2019, IRS officials provided GAO with draft linkages to IRS's strategic goals for the draft measures and program objectives and are responding to comments from GAO on those linkages. We will update the status when IRS provides any further supporting documentation, as we requested in March 2020.

Recommendation: To strengthen federal oversight of facilities with ammonium nitrate, the Secretary of Labor and the Administrator of EPA should direct OSHA and EPA, respectively, to consider revising their related regulations to cover ammonium nitrate and jointly develop a plan to require high risk facilities with ammonium nitrate to assess the risks and implement safeguards to prevent accidents involving this chemical.

Agency: Department of Labor
Status: Open

Comments: On December 9, 2013, OSHA issued a Request for Information seeking, among other things, comments on potential revisions to its Process Safety Management standard and its Explosives and Blasting Agents Standard. The Request for Information specifically invited comments on safe work practices for storing, handling, and managing ammonium nitrate and on regulatory requirements to improve its approach to preventing the hazards associated with ammonium nitrate. As of July 2017, OSHA reports it has completed a Small Business Regulatory Flexibility Review Act panel to gather feedback from small businesses on updating its Process Safety Management (PSM) regulation. During the panel, the agency discussed the option of adding ammonium nitrate to the list of chemicals covered by PSM and collected comments. As of June 2018, the PSM rulemaking is on the regulatory agenda under Long Term Action. According to OSHA officials, the agency will continue to collect comments on the option of adding ammonium nitrate to the list of highly hazardous chemicals covered by the PSM regulations as dictated by the rulemaking process. We will close this recommendation when OSHA decides what action to take as a result of the rulemaking process.

Recommendation: To strengthen federal oversight of facilities with ammonium nitrate, the Secretary of Labor and the Administrator of EPA should direct OSHA and EPA, respectively, to consider revising their related regulations to cover ammonium nitrate and jointly develop a plan to require high risk facilities with ammonium nitrate to assess the risks and implement safeguards to prevent accidents involving this chemical.

Agency: Environmental Protection Agency
Status: Open

Comments: In January 2017, EPA issued a final rule to modify its Risk Management Program (RMP) regulations. The agency decided not to propose any revisions to the list of regulated substances and therefore, did not address ammonium nitrate in the revised regulations.

Recommendation: The Secretary of Labor should direct the Assistant Secretary for Occupational Safety and Health to consider updating regulations for the storage of ammonium nitrate taking into consideration, as appropriate, other related standards and current practices.

Agency: Department of Labor
Status: Open

Comments: OSHA previously (December 3, 2014) issued guidance to Regional Administrators to assist OSHA officials in enforcing the ammonium nitrate storage requirements in the Explosives and Blasting Agents Standard. In addition, on December 9, 2013, OSHA issued a Request for Information (RFI) seeking, among other things, comments on potential revisions to the Explosives and Blasting Agents Standard, which includes ammonium nitrate storage requirements. According to OSHA officials, the agency discussed the option of adding ammonium nitrate to the list of chemicals covered by the Process Safety Management (PSM) regulations and collected comments. As of June 2018, the PSM rulemaking is on the regulatory agenda under Long-Term Action. We will close this recommendation when the agency decides what action to take as a result of the rulemaking process.

Recommendation: While IRS works to improve the quality of its Schedule K-1 data, the Commissioner of Internal Revenue should develop a plan for conducting testing or other analysis to determine whether the improved Schedule K-1 data, perhaps combined with other IRS information about businesses and taxpayers, could be used more effectively to ensure compliance with the reporting of flow-through income.

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

Comments: IRS stated that it understands the objective of this recommendation and, at such time that resources are available to enhance capabilities, it would consider the proposed methodology of advanced testing. However, based on current and anticipated budget constraints, it does not expect its plans to change in the near future. As of September 2020, there has been no change. As such we will continue to monitor progress.

Recommendation: To improve the implementation of the act, the Secretary of Agriculture should develop and implement policies and procedures for cost-benefit analyses related to computer matching agreements to include key elements such as personnel and computer costs, as well as avoidance of future improper payments and recovery of improper payments and debts.

Agency: Department of Agriculture
Status: Open

Comments: Although department officials have stated that they plan to take actions to address this recommendation, as of July 2019 we have not yet received information to validate agency actions. Subsequent to the agency sending documentation, we plan to verify whether implementation has occurred.

Recommendation: To improve the implementation of the act, the Secretary of Labor should develop and implement policies and procedures for cost-benefit analyses related to computer matching agreements to include key elements such as personnel and computer costs, as well as avoidance of future improper payments and recovery of improper payments and debts.

Agency: Department of Labor
Status: Open

Comments: Although department officials have stated that they are taking actions to address this recommendation, as of August 2020, we have not yet received information to validate agency actions. Subsequent to the agency sending documentation, we plan to verify whether implementation has occurred.

Recommendation: To improve the implementation of the act, the Secretary of Labor should ensure the DIB reviews cost-benefit analyses to make certain cost savings information for the computer matching program is included before approving CMAs.

Agency: Department of Labor
Status: Open

Comments: Although department officials have stated that they are taking actions to address this recommendation, as of August 2020, we have not yet received information to validate agency actions. Subsequent to the agency sending documentation, we plan to verify whether implementation has occurred.

Recommendation: To improve the implementation of the act, the Secretary of Labor should ensure the DIB performs annual reviews and submits annual reports on agency computer matching activities, as required by the act.

Agency: Department of Labor
Status: Open

Comments: Although department officials have stated that they are taking actions to address this recommendation, as of August 2020, we have not yet received information to validate agency actions. Subsequent to the agency sending documentation, we plan to verify whether implementation has occurred

Recommendation: To help ensure that qualified CDRs promote improved quality and efficiency of physician care for Medicare beneficiaries, the Secretary of Health and Human Services should direct CMS to establish a requirement for qualified CDRs to demonstrate improvement on key measures of quality and efficiency for their target populations.

Agency: Department of Health and Human Services
Status: Open

Comments: As of April 2019, HHS officials reported that they were implementing new requirements for qualified CDRs, but these requirements were not related to demonstrating improvement on the measures of quality and efficiency, as GAO recommended. We will update the status of this recommendation when we receive additional information.

Recommendation: To help ensure that qualified CDRs promote improved quality and efficiency of physician care for Medicare beneficiaries, the Secretary of Health and Human Services should direct CMS to establish a process for monitoring compliance with requirements for qualified CDRs that draws on relevant expert judgment. This process should assess CDR performance on each requirement in a way that takes into account the varying circumstances of CDRs and their available opportunities to promote quality and efficiency improvement for their target populations.

Agency: Department of Health and Human Services
Status: Open

Comments: As of April 2019, HHS officials have not informed us of any actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.

Recommendation: To help ensure that qualified CDRs promote improved quality and efficiency of physician care for Medicare beneficiaries, the Secretary of Health and Human Services should determine and implement actions to reduce barriers to the development of qualified CDRs, such as (1) developing guidance that clarifies Health Insurance Portability and Accountability Act requirements to promote participation in qualified CDRs; (2) working with private sector entities to make relevant multipayer cost data available to qualified CDRs; (3) testing one or more models of shared savings between Medicare and qualified CDRs that achieve reduced Medicare expenditures with improved quality of care, and (4) providing technical assistance to qualified CDRs.

Agency: Department of Health and Human Services
Status: Open

Comments: As of April 2019, HHS officials have not informed us of any actions taken to implement this recommendation beyond providing limited technical assistance to qualified CDRs through monthly support calls and an annual kick-off meeting. We will update the status of this recommendation when we receive additional information.

Recommendation: To help ensure that qualified CDRs promote improved quality and efficiency of physician care for Medicare beneficiaries, the Secretary of Health and Human Services should determine key data elements needed by qualified CDRs--such as those relevant for a required core set of measures--and direct Office of the National Coordinator for Health Information Technology and CMS to include these data elements, if feasible, in the requirements for certification of EHRs under the EHR incentive programs.

Agency: Department of Health and Human Services
Status: Open

Comments: As of April 2019, HHS officials have not informed us of any actions taken to implement this recommendation. We will update the status of this recommendation when we receive additional information.

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

Agency: National Mediation Board
Status: Open

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

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

Agency: National Mediation Board
Status: Open

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

Recommendation: To proactively prepare for oversight of future disaster relief funding, the Director of OMB should develop standard guidance for federal agencies to use in designing internal control plans for disaster relief funding. Such guidance could leverage existing internal control review processes and should include, at a minimum, the following elements: (1) robust criteria for identifying and documenting incremental risks and mitigating controls related to the funding and (2) requirements for documenting the linkage between the incremental risks related to disaster funding and efforts to address known internal control risks.

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

Comments: To address the recommendation, OMB should issue guidance on internal control for disaster relief funding, including criteria for identifying additional risks and mitigating controls related to the funding and a requirement to link these incremental risks to ongoing efforts to address known internal control risks. On July 15, 2016, OMB issued the revised Circular No. A-123, Management's Responsibility for Enterprise Risk Management and Internal Control. The Circular requires agencies to implement enterprise risk management, which includes the development of a risk profile that analyzes the risks faced in achieving strategic objectives and identifies options for addressing them. In April 2017, OMB staff stated that they believe that the implementation of enterprise risk management through Circular No. A-123 satisfies the intent our recommendation. Because the responsibility for implementing enterprise risk management lies with agency management, Circular No. A-123 does not include specific guidance for identifying risks related to disaster funding. Further discussion and documentation to support OMB's position that the revised Circular addresses our recommendation will be necessary. The Bipartisan Budget Act of 2018, Sec. 21208(c) requires OMB to issue standard guidance for Federal agencies to use in designing internal control plans for disaster relief funding in order to proactively prepare for oversight of future disaster relief funds. The Act states this guidance shall leverage existing internal control review processes and shall include, at a minimum, (1) robust criteria for identifying and documenting incremental risks and mitigating controls related to the funding, and (2) guidance for documenting the linkage between the incremental risks related to disaster funding and efforts to address known internal control risks. GAO reviewed OMB's actions to implement the law. On June 28, 2019, GAO, 2017 Disaster Relief Oversight: Strategy Needed to Ensure Agencies' Internal Control Plans Provide Sufficient Information, GAO-19-479 (Washington, D.C.: Jun 28, 2019) reported the 2013 recommendation remains open and that we plan to continue monitoring OMB's progress in implementing this priority recommendation. Further, the report stated that OMB did not have an effective strategy to ensure that agencies timely submitted internal control plans; and OMB's Memorandum M-18-14, Implementation of Internal Controls and Grant Expenditures for the Disaster-Related Appropriations lacked specific instructions to agencies on what to include in their internal control plans. As such, a new recommendation was warranted. As of February 2020, OMB has not provided any new status updates for this recommendation.

Recommendation: In order to reduce the administrative costs associated with a fragmented MAI grant structure that diminishes the effective use of HHS's limited HIV/AIDS funding, and to enhance services to minority populations, HHS should consolidate disparate MAI funding streams into core HIV/AIDS funding during its budget request and allocation process.

Agency: Department of Health and Human Services
Status: Open

Comments: HHS stated that it does not support the consolidation of Minority AIDS Initiative (MAI) funds into core funding. As of January 2020, HHS had not changed its position. We will update the status of this recommendation when we receive additional information.

Recommendation: In order to reduce the administrative costs associated with a fragmented MAI grant structure that diminishes the effective use of HHS's limited HIV/AIDS funding, and to enhance services to minority populations, HHS should seek legislation to amend the Ryan White Comprehensive AIDS Resources Emergency Act of 1990 or other provisions of law, as necessary, to achieve a consolidated approach.

Agency: Department of Health and Human Services
Status: Open

Comments: HHS stated that it does not support the consolidation of Minority AIDS Initiative (MAI) funds into core funding. As of January 2020, HHS had not changed its position. We will update the status of this recommendation when we receive additional information.

Recommendation: To facilitate oversight of the size of DOD's reserve-component headquarters and ensure that they have the minimum personnel needed to complete their assigned missions, and to minimize the potential for gaps or overlaps at the National Guard's state Joint Force headquarters, the Secretary of Defense should direct the Chief of the National Guard Bureau to assess and validate all personnel requirements at the state Joint Force headquarters to include the Army staff element and Air staff element.

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation. In DOD's response, the department detailed ongoing efforts to validate personnel requirements and stated that revising the scope of the National Guard Bureau's study would eliminate the ability of the Army National Guard and Air National Guard to identify their own personnel requirements. The department further stated that when shared functions are being studied, coordination should be increased between the staff elements to ensure that the correct workload is captured, requirements are not duplicated, and process efficiencies are maximized. However, we found minimal coordination on studies examining the five functions that the National Guard identified as being staffed with both Army National Guard and Air National Guard personnel. As of July 2020, the National Guard Bureau (NGB) had not assessed and validated personnel requirements at the state Joint Force headquarters.

Recommendation: To strengthen FHA accountability for complying with the Fund's statutory capital requirement, Congress should consider requiring that FHA submit a capital restoration plan and regular updates on plan implementation whenever the capital ratio falls below 2 percent as calculated in the annual actuarial review of the Fund, or the Fund's financial condition does not meet other congressionally-defined requirements.

Agency: Congress
Status: Open

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

Recommendation: To provide additional perspective on the Fund's financial status, FHA should disclose estimates of the individual cash flows associated with the liability for loan guarantees (premiums, claims, and recoveries), including their value for each year of the 30-year estimation period.

Agency: Department of Housing and Urban Development: Federal Housing Administration
Status: Open

Comments: As of October 2019, HUD had not yet acted on this recommendation.

Recommendation: To improve DOD's corrosion-prevention and control program, and to enhance DOD in its oversight of the status and potential benefits of its equipment-related corrosion projects, the Under Secretary of Defense for Acquisition, Technology and Logistics should require the Director, Corrosion Policy and Oversight Office, to revise the DOD Corrosion Prevention and Mitigation Strategic Plan or other guidance to require that the military departments include in all follow-on reports the details of measures of achievement other than ROI, such as the features, results, and potential benefits of the project.

Agency: Department of Defense: Office of the Under Secretary of Defense for Acquisition, Technology and Logistics
Status: Open

Comments: DOD did not concur with this recommendation. As of March 2016, DOD had not implemented this recommendation and stated that the DoD Corrosion Prevention and Mitigation Strategic Plan currently provide sufficient guidance in this regard. As of March 2019, DOD has decided to take action to implement this recommendation. According to DOD Corrosion Office officials, they plan to list measures of achievement for the military departments to follow on the departments' corrosion project in a new DOD manual on corrosion. The Office's goal is to create this new manual by the end of calendar year 2020. We will monitor the extent to which DOD implements this recommendation.

Recommendation: To increase beneficiaries' awareness of providers' financial interest in a particular treatment, Congress should consider directing the Secretary of Health and Human Services to require providers who self-refer IMRT services to disclose to their patients that they have a financial interest in the service.

Agency: Congress
Status: Open

Comments: In August 2013, to increase beneficiaries' awareness of providers' financial interest in a particular treatment, we suggested that Congress should consider directing the Secretary of Health and Human Services to require providers who self-refer IMRT services to disclose to their patients that they have a financial interest in the service. As of June 2020, Congress has not implemented this suggestion.

Recommendation: The Administrator of CMS should insert a self-referral flag on its Medicare Part B claims form, require providers to indicate whether the IMRT service for which a provider bills Medicare is self-referred, and monitor the effects that self-referral has on costs and beneficiary treatment selection.

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

Comments: In August 2013, we recommended that the Administrator of the Centers for Medicare & Medicaid Services (CMS) insert a self-referral flag on its Medicare Part B claims form, require providers to indicate whether the intensity-modulated radiation therapy (IMRT) service for which a provider bills Medicare is self-referred, and monitor the effects that self-referral has on costs and beneficiary treatment selection. The Department of Health and Human Services (HHS) did not concur with this recommendation, noting that CMS does not believe that this recommendation will address overutilization that occurs as a result of self-referral, would be complex to administer, and may have unintended consequences. We continue to believe that such a flag on Part B claims would likely be the easiest and most cost-effective way for CMS to identify self-referred IMRT services and monitor the effects of self-referral. As of June 2020, CMS has not provided any additional information about actions it has taken to address this recommendation.

Recommendation: To help SEC address identified personnel management challenges, and to help enhance the credibility of its performance management system, the Chairman of SEC should direct the COO and OHR to conduct periodic validations (with staff input) of the performance management system and make changes, as appropriate, based on these validations.

Agency: United States Securities and Exchange Commission
Status: Open
Priority recommendation

Comments: SEC management and the union agreed in November 2018 to implement a new performance management system and a new incentive bonus program in 2020. According to SEC officials, SEC plans to work with OPM to validate the new performance management system by conducting focus groups with staff at the midpoint of the 2020 appraisal period and surveying staff on the new system at the conclusion of the 2020 appraisal period. These plans are consistent with our 2013 recommendation that SEC should conduct periodic validations of its performance management system. In August 2020, SEC reported that it began implementation of the new 2-tier performance management program and will complete the annual rating cycle in December 2020, with feedback and appraisal closeout activities occurring in early calendar year 2021. According to SEC, OPM will assess the new program after calendar year 2020 performance cycle activities are completed. We will continue to monitor SEC's progress in validating the new performance management system.

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

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

Agency: Department of the Treasury
Status: Open
Priority recommendation

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

Recommendation: In order to improve CMS's ability to identify self-referred anatomic pathology services and help CMS avoid unnecessary increases in these services, the Administrator of CMS should insert a self-referral flag on Medicare Part B claim forms and require providers to indicate whether the anatomic pathology services for which the provider bills Medicare are self-referred or not.

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

Comments: In June 2013, we recommended that the Administrator of the Centers for Medicare & Medicaid Services (CMS) insert a self-referral flag on Medicare Part B claim forms and require providers to indicate whether the anatomic pathology services for which the provider bills Medicare are self-referred or not. The Department of Health and Human Services (HHS) did not concur with this recommendation, noting that CMS does not believe that this recommendation will address overutilization that occurs as a result of self-referral. Although CMS has taken initial steps relevant to self-referral, the steps do not require a provider to indicate whether anatomic pathology services billed to Medicare are self-referred or not. Specifically, CMS has noted that Section 6409(a) of the Patient Protection and Affordable Care Act required the Secretary of the Department of Health and Human Services, in cooperation with the Inspector General of the Department of Health and Human Services, to establish a Medicare self-referral disclosure protocol that sets forth a process to enable providers of services and suppliers to self-disclose actual or potential violations of the physician self-referral statute. However, the protocol is voluntary and specific to actual or potential violations regarding self-referral, which is not relevant to our recommendation. As of January 2020, CMS has not provided any additional information about actions it has taken to address our recommendation. We continue to believe that inserting a flag on Part B claims to indicate whether an anatomic pathology service is self-referred would improve CMS's ability to monitor self-referred services, which in turn may help them take action to avoid unnecessary increases in these services.

Recommendation: In order to improve CMS's ability to identify self-referred anatomic pathology services and help CMS avoid unnecessary increases in these services, the Administrator of CMS should determine and implement an approach to ensure the appropriateness of biopsy procedures performed by self-referring providers.

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

Comments: In June 2013, we recommended that the Administrator of the Centers for Medicare & Medicaid Services (CMS) implement an approach to ensure the appropriateness of biopsy procedures performed by self-referring providers. The Department of Health and Human Services (HHS) did not concur with this recommendation and does not believe it would address overutilization that occurs as a result of self-referral. In November 2017, CMS officials noted that the agency does not have the ability to identify self-referred anatomic pathology services during medical reviews. As of January 2020, CMS has not provided any additional information about actions it has taken to address the recommendation. We continue to believe that it is important for CMS to monitor the self-referral of anatomic pathology services on an ongoing basis and determine if those services are inappropriate or unnecessary.

Recommendation: In order to improve CMS's ability to identify self-referred anatomic pathology services and help CMS avoid unnecessary increases in these services, the Administrator of CMS should develop and implement a payment approach for anatomic pathology services that would limit the financial incentives associated with referring a higher number of specimens--or anatomic pathology services--per biopsy procedure.

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

Comments: In June 2013, we recommended that the Administrator of the Centers for Medicare & Medicaid Services (CMS) develop and implement a payment approach for anatomic pathology services under the Physician Fee Schedule that would limit the financial incentives associated with referring a higher number of specimens--anatomic pathology services--per biopsy procedure. Although health care providers have discretion in determining the number of tissue samples from biopsy procedures that become specimens (anatomic pathology services), CMS's current payment system under the Physician Fee Schedule provides a financial incentive for providers to refer more specimens per biopsy procedure. Specifically, CMS pays for each specimen that a provider submits to be analyzed. HHS indicated that it concurred with our recommendation and that it had addressed this recommendation by reducing payment for the most commonly furnished anatomic pathology service (Current Procedural Terminology [CPT] code 88305) by approximately 30 percent in calendar year 2013. However, CMS's payment reduction did not change the financial incentive providers have to refer more specimens per biopsy procedure because they will still be paid separately for each specimen submitted. As of January 2020, CMS has not provided any additional information about actions it has taken to limit the financial incentives associated with referring a higher number of specimens. We continue to believe that CMS should develop a payment approach that addresses this incentive.

Recommendation: Further, to provide greater assurance that the military departments will meet reporting milestones for future projects, the Under Secretary of Defense for Acquisition, Technology, and Logistics--in coordination with the Director of the Office of Corrosion Policy and Oversight-- should revise corrosion-related guidance to clearly define a role for the military departments' Corrosion Control and Prevention Executives to assist the Office of Corrosion Policy and Oversight in holding their departments' project management offices accountable for submitting infrastructure-related reports in accordance with the DOD Corrosion Prevention and Mitigation Strategic Plan.

Agency: Department of Defense: Office of the Secretary of Defense: Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics
Status: Open

Comments: On July 24, 2013, DOD reported that it non-concurred with our recommendation. DOD reported that the Military Department Corrosion Control and Prevention Executives are given the freedom to manage their programs in the most efficient and effective manner for their respective departments. Additionally, DOD reported that the Corrosion Control and Prevention Executives know the reporting requirements and are working closely with the Corrosion Policy and Oversight Office and the project managers to ensure reports are submitted in accordance with the DoD Corrosion Prevention and Mitigation Strategic Plan. Therefore, DOD reported that further guidance is not necessary as the requirements are already clearly stated in the DoD Corrosion Prevention and Mitigation Strategic Plan. Our audit work showed that DOD's strategic plan and guidance do not define a role for the Corrosion Executives in assisting the Corrosion Office in the project reporting process. Our recommendation was intended to fortify the role of Corrosion Executives in ensuring that project management offices within the Corrosion Executives' respective military departments submit project reports as required in the strategic plan. We continue to believe that the Corrosion Executives could provide the additional management oversight necessary to strengthen corrosion project reporting. In May 2016, the Senate Armed Services Committee informed us that it have included language in its National Defense Authorization Act Bill for fiscal year 2017. Specifically, the language reads: SEC. 312. REVISION OF GUIDANCE RELATED TO CORROSION CONTROL AND PREVENTION EXECUTIVES. Not later than 90 days after the date of the enactment of this Act, the Under Secretary of Defense for Acquisition, Technology, and Logistics, in coordination with the Director of Corrosion Policy and Oversight, shall revise corrosion-related guidance to clearly define the role of the corrosion control and prevention executives of the military departments in assisting the Office of Corrosion Policy and Oversight in holding the appropriate project management office in each military department accountable for submitting the report required under section 903(b)(5) of the Duncan Hunter National Defense Authorization Act for Fiscal Year 2009 (Public Law 110-417; 10 U.S.C. 2228 note) with an expanded emphasis on infrastructure, as required in the long-term strategy of the Department of Defense under section 2228(d) of title 10, United States Code. As of October 2016, legislation was not passed. As of March 2019, DOD has since decided to take action to implement this recommendation. According to Corrosion Office officials, they will include a definition of the military departments' Corrosion Executives' role in: an update to DOD Instruction 5000.67 (Prevention and Mitigation of Corrosion on DOD Military Equipment and Infrastructure), a new DOD manual on corrosion, an update to the DOD Corrosion Prevention and Mitigation Strategic Plan, and an update to the Corrosion Prevention Control Integrated Product Team charter. The Corrosion Office's goal is to complete these updates and create the new manual by the end of calendar year 2020. We will monitor the extent to which DOD implements this recommendation.

Recommendation: To help ensure that ADI suppliers provide consistent, safe, and high-quality imaging to Medicare beneficiaries, the Administrator of CMS should determine the content of and publish minimum national standards for the accreditation of ADI suppliers, which could include specific qualifications for supplier personnel and requiring accrediting organization review of clinical images.

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

Comments: In June 2019, HHS officials informed us that they plan to implement this recommendation in March 2020. We will update the status of this recommendation when we receive additional information.

Recommendation: To help ensure that ADI suppliers provide consistent, safe, and high-quality imaging to Medicare beneficiaries, the Administrator of CMS should develop an oversight framework for evaluating accrediting organization performance, which could include collecting and analyzing information on accreditation results and conducting validation audits.

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

Comments: In June 2019, HHS officials informed us that they plan to implement this recommendation in March 2020. We will update the status of this recommendation when we receive additional information.

Recommendation: To help ensure that ADI suppliers provide consistent, safe, and high-quality imaging to Medicare beneficiaries, the Administrator of CMS should develop more specific requirements for accrediting organization mid-cycle audit procedures and clarify guidance on immediate-jeopardy deficiencies to ensure consistent identification and timely correction of serious care problems for the duration of accreditation.

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

Comments: In June 2019, HHS officials informed us that they plan to implement this recommendation in March 2020. 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: Congress should consider granting Labor the additional authority it is seeking to access wage data to help verify claimants' reported income and help ensure the proper payment of benefits.

Agency: Congress
Status: Open

Comments: No legislation introduced as of March 20120. The Workers' Compensation Reform Act of 2015 (S. 2051, title V) was introduced in the 114th Congress. It would have allowed DOL to access wage data, as GAO suggested in April 2013, from the National Directory of New Hires to improve the integrity of the Federal Employees' Compensation Act program, among other actions. If similar legislation were introduced in the 116th Congress and enacted, this legislation could help to prevent and detect improper payments in the Federal Employees' Compensation Act program.

Recommendation: In light of the agency's declining revenue associated with its basic statutory function and the charging for information that is often freely available elsewhere, Congress should consider examining the appropriateness and viability of the fee-based model under which NTIS currently operates for disseminating technical information to determine whether the use of this model should be continued.

Agency: Congress
Status: Open

Comments: Congress had taken a number of actions that affect the NTIS fee-based model for disseminating technical information. Specifically, for the past 5 fiscal years and in the current Consolidated Appropriations Act, 2020, NTIS is prohibited from charging customers for reports generated by legislative branch offices unless the agency tells the customer how an electronic copy of the report can be accessed or downloaded for free online. The act further states that, if a customer still requires such a report from NTIS, the agency should not charge more than what is needed to recover the cost of processing, reproducing, and delivering the document requested. It remains to be seen whether these requirements will be continued under the yet to be introduced House and Senate bills making appropriations for the Department of Commerce (Commerce) for fiscal year 2021. Congress again has the opportunity to consider legislation that would ensure the assessment of the appropriateness or viability of NTIS functions.

Recommendation: To help ensure that EM more effectively manages all its projects, the Secretary of Energy should direct the Senior Advisor for Environmental Management and the Director of the Office of Management, as appropriate, to provide the Office of Acquisition and Project Management with information on EM's project classification decisions to ensure that all capital asset projects have been appropriately classified and are managed in accordance with DOE Order 413.3B.

Agency: Department of Energy
Status: Open

Comments: DOE agreed with our recommendation. EM is working with DOE's Office of Project Management to draft a Cleanup Project Management Policy (expected to be completed in fall 2020) to address the Decommissioning and Deactivation phase of cleanup. This policy will become an appendix in DOE's Order 413.3B. EM officials further stated that EM plans to develop an additional Cleanup Program Management Policy that would classify the remaining types of activities not covered by the Cleanup Project Management Policy, including what EM currently classifies as operations activities. EM plans to implement this policy by the end of fiscal year 2020.

Recommendation: To improve DOD's ability to identify how many headquarters personnel it has, including military, civilian and contractor personnel, and improve the information Congress and DOD need to ensure that headquarters organizations are appropriately sized and overhead positions are reduced to the extent possible, the Secretary of Defense should direct the Director of Administration and Management, in consultation with the Under Secretary of Defense for Personnel and Readiness, to revise DOD Instruction 5100.73, Major DOD Headquarters Activities, to (1) include all major DOD headquarters activity organizations, (2) specify how contractors performing major DOD headquarters activity functions will be identified and included in headquarters reporting, (3) clarify how components are to compile the major DOD headquarters activities information needed to respond to the reporting requirements in section 1109 of the fiscal year 2010 National Defense Authorization Act, and (4) establish time frames for implementing the actions above to improve tracking and reporting headquarters resources.

Agency: Department of Defense
Status: Open

Comments: The department partially concurred with this recommendation, stating that while it supports the refinement and update of DOD Instruction 5100.73, it uses the major headquarters activity designation to identify and manage the size of organizations in order to comply with statutory limits on headquarters personnel, not as tool to manage the organizational efficiency of the department or its components. With regard to the element of the recommendation concerning contractors, the department stated that in November of 2011 it had submitted a plan to the congressional defense committees for its Inventory of Contracts for Services that establishes both near and long term actions to improve visibility over all contracted services. This plan, and subsequent guidance issued in December 2011, describes the steps being taken to account for the level of effort of contracted support, based on the activity requiring the service. With regard to the element of the recommendation to meet reporting requirements for major headquarters activities, the department stated it had incorporated this requirement into the Defense Manpower Requirements Report in fiscal year 2012 and 2013. However, as of March 2020, DOD has not completed actions to address three of the four parts of this recommendation. In September 2017, DOD completed a revised framework for major DOD headquarters activities tied to funding, but as of March 2020 has not yet updated DOD Instruction 5100.73 to reflect all major DOD headquarters activity organizations included in the revised framework. DOD has also not identified an approach to include contractor personnel as part of its headquarters reporting. For fiscal year 2020 reporting, DOD intends to rely on the Federal Procurement Data System-Next Generation (FPDS-NG) as the basis for collecting information on contracted services. GAO has previously reported that FPDS-NG has certain limitations, including not being able to (a) identify and record more than one type of service purchased for each contracting action entered into the system, (b) identify the requiring activity specifically, and (c) determine the number of contractor full-time equivalents used to perform each service. Consequently, it is unclear the extent to which using FPDS-NG will enable DOD to determine the number of contractors and the functions they are performing in support of headquarters activities. DOD did clarify how it would respond to section 1109 of the fiscal year 2010 National Defense Authorization Act to satisfy this part of the recommendation. Lastly, DOD has also not yet established time frames for updating DOD Instruction 5100.73 or for determining how contractor personnel are to be included in major DOD headquarters activity reporting.

Recommendation: To improve leadership's commitment to preventing and responding to incidents of sexual harassment, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness to develop a strategy for holding individuals in positions of leadership accountable for promoting, supporting, and enforcing the department's sexual harassment policies and programs.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with our recommendation and stated that leadership accountability is essential to the success of the department's efforts to prevent sexual harassment. In February 2018, DOD took action toward addressing this recommendation and released an update to DOD Instruction 1020.03, Harassment Prevention and Response in the Armed Forces, that directs the Director, Office of Diversity Management and Equal Opportunity (ODMEO), to ensure that DOD components' harassment prevention and response programs incorporate, at a minimum, compliance standards for promoting, supporting, and enforcing polices, plans, and programs. The updated instruction also directs the Commandant, Defense Equal Opportunity Management Institute (DEOMI), to tailor training materials to servicemember professional development levels and associated leadership duties and responsibilities. As of February 2020, DOD had not completed development of the compliance standards or training materials. We will monitor DOD actions on this issue.

Recommendation: To improve implementation of the department's sexual harassment policies and programs, the Secretary of Defense should direct the service secretaries to verify or track military commanders' compliance with existing requirements that commanders periodically determine their organizational health and functioning effectiveness by periodically assessing their equal opportunity climate through "command climate" assessments.

Agency: Department of Defense
Status: Open

Comments: DOD has updated its guidance on sexual harassment, including a requirement for sharing the results of command climate assessments with the next higher level of command, but has not yet implemented an oversight mechanism to verify and track commanders' compliance with requirements to conduct such assessments. DOD concurred with this recommendation and stated that it would implement the recommendation through revisions to its guidance. According to DOD, a 2013 memorandum from the Secretary of Defense on sexual assault prevention and response outlined requirements addressing leadership accountability for preventing sexual harassment. The memorandum included a requirement that the results of command climate surveys be provided to the next level up in the chain of command, and it directed service chiefs, through their respective military department secretaries, to develop methods to assess the performance of commanders in establishing command climates of dignity and respect. The Secretary of Defense also issued a memorandum addressing prevention and response of sexual harassment in 2014, and DOD updated its guidance on sexual harassment in 2015. In 2016, DOD stated that further revisions to guidance were forthcoming to provide a framework for oversight of sexual harassment. This framework, among other things, would address standards for holding leaders accountable for promoting, supporting, and enforcing sexual harassment policies. DOD issued a new DOD Instruction 1020.03, Harassment Prevention and Response in the Armed Forces, in February 2018 but has not implemented an oversight framework as of February 2020. We will continue to monitor DOD's actions.

Recommendation: To enhance oversight of the department's program to help prevent and to address incidents of sexual harassment involving servicemembers, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness to ensure that the Office of Diversity Management and Equal Opportunity develops and aggressively implements an oversight framework to help guide the department's efforts. At a minimum, such a framework should contain long-term goals, objectives, and milestones; strategies to accomplish goals; criteria for measuring progress; and results-oriented performance measures to assess the effectiveness of the department's sexual harassment policies and programs. Such a framework should also identify and include a plan for ensuring that adequate resources are available to carry out the office's oversight responsibilities.

Agency: Department of Defense
Status: Open
Priority recommendation

Comments: DOD concurred with our recommendation and stated that as part of its revised guidance it proposed to strengthen and institutionalize the responsibilities and authorities needed for successful implementation of the department's sexual harassment policies. In February 2018, DOD took action toward addressing this recommendation and issued an update to DOD Instruction 1020.03, Harassment Prevention and Response in the Armed Forces, that directs the Director, Office of Diversity Management and Equal Opportunity, to ensure that DOD components' harassment prevention and response programs incorporate , at a minimum, (1) long-term goals, objectives, and milestones; (2) results-oriented performance measures to assess effectiveness; and (3) compliance standards for promoting, supporting, and enforcing policies, plans, and programs. As of February 2020, DOD has not developed and aggressively implemented an oversight framework, as we recommended. We will continue to monitor DOD's actions.

Recommendation: To better ensure that economically similar outcomes are taxed similarly and minimize opportunities for abuse, the Secretary of the Treasury should undertake a study that compares the current approach to alternative approaches for the taxation of financial derivatives. To determine if changes would be beneficial, such a study should weigh the tradeoffs to IRS and taxpayers that each alternative presents, including simplicity, administrability, and economic efficiency.

Agency: Department of the Treasury
Status: Open

Comments: Treasury disagreed with this recommendation based on the fact that many outside studies already exist and IRS did not comment. The Tax Cuts and Jobs Act enacted in December 2017 did not include any requirements that Treasury study alternative approaches for the taxation of financial derivatives. However members of Congress have released proposals for a mark-to-market tax system, which would include financial derivatives. GAO continues to maintain that further study is needed in coordination with IRS and will continue to monitor the climate for such a study.

Recommendation: Congress may wish to consider instituting a penalty on non-material advisor promoters for failing to provide investor lists to IRS within a specified time period when requested, comparable to the 20-business-day requirement for material advisors.

Agency: Congress
Status: Open

Comments: As of February 2020, we have not identified legislative action in the 114th or 115th Congress or any enacted legislation since 2011 amending section 6111 (disclosure of reportable transactions including the definition of a material advisor), section 6112 (requirement to keep lists of investors) or section 6708 (imposing the penalty for failure to maintain and provide lists to IRS).

Recommendation: To improve reporting on the results of examinations on ATAT issues, the Commissioner of Internal Revenue should separately track the tax amounts recommended, assessed, and collected between ATAT issues and non-ATAT issues.

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

Comments: As of December 2019, IRS did not plan on taking any further actions to track examination results for ATAT versus non-ATAT issues, as GAO recommended in May 2011. In July 2012, IRS told GAO that although it agreed with GAO's May 2011 recommendation, resource and capability constraints preclude it from capturing information in this way. GAO maintains that tracking examination results for ATAT versus non-ATAT issues would provide IRS management with the data needed to make informed judgments about program effectiveness and resource allocations. IRS has taken steps to check whether taxpayers file all required ATAT-related disclosure obligations. In February 2013, IRS implemented a new indicator and matching process to regularly review whether taxpayers are meeting their ATAT-related filing obligations. Additionally, IRS developed a procedure to evaluate the completeness of ATAT-related disclosure forms and follow up on incomplete forms as necessary and updated the Internal Revenue Manual to reflect these changes. Developing and implementing these new processes and procedures will provide IRS with additional information for determining whether the disclosures are made as required and are complete.