Recommendation: Congress should consider specifying in the IRC what services and activities it considers sufficient community benefit. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: When we determine what steps the Congress has taken, we will provide updated information.

Recommendation: The Commissioner of Internal Revenue should update Form 990, including Schedule H and instructions where appropriate to ensure that the information demonstrating the community benefits a hospital is providing is clear and can be easily identified by Congress and the public, including the community benefit factors. (Recommendation 1)

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

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

Recommendation: The Commissioner of Internal Revenue should assess the benefits and costs, including the tax law implications, of requiring tax-exempt hospital organizations to report community benefit expenses on Schedule H by individual facility rather than by collective organization and take action, as appropriate. (Recommendation 2)

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

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

Recommendation: The Commissioner of Internal Revenue should establish a well-documented process to identify hospitals at risk for noncompliance with the community benefit standard that would ensure hospitals' community benefit activities are being consistently reviewed. (Recommendation 3)

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

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

Recommendation: The Commissioner of Internal Revenue should establish specific audit codes for identifying potential noncompliance with the community benefit standard. (Recommendation 4)

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

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

Recommendation: The Director of OMB should ensure that CMS, FBI, IRS, and SSA are collaborating on their cybersecurity requirements pertaining to state agencies to the greatest extent possible and direct further coordination where needed. (Recommendation 1)

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

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

Recommendation: The Director of OMB should take steps to ensure that CMS, FBI, IRS, and SSA coordinate, where feasible, on assessments of state agencies' cybersecurity, which may include steps such as leveraging other agencies' security assessments or conducting assessments jointly. (Recommendation 2)

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

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

Recommendation: The Administrator of CMS should, in collaboration with OMB, solicit input from FBI, IRS, SSA, and state agency stakeholders on revisions to its security policy to ensure that cybersecurity requirements for state agencies are consistent with other federal agencies and NIST guidance to the greatest extent possible and document CMS's rationale for maintaining any requirements variances.(Recommendation 3)

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

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

Recommendation: The Administrator of CMS should revise its assessment policies to maximize coordination with other federal agencies to the greatest extent practicable. (Recommendation 4)

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

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

Recommendation: The FBI Director should, in collaboration with OMB, solicit input from CMS, IRS, SSA, and state agency stakeholders on revisions to its security policy to ensure that cybersecurity requirements for state agencies are consistent with other federal agencies and NIST guidance to the greatest extent possible. (Recommendation 5)

Agency: Department of Justice: Federal Bureau of Investigation
Status: Open

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

Recommendation: The FBI Director should fully develop policies for coordinating with state agencies on the use of prior findings from relevant cybersecurity assessments conducted by other organizations. (Recommendation 6)

Agency: Department of Justice: Federal Bureau of Investigation
Status: Open

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

Recommendation: The FBI Director should revise its assessment policies to maximize coordination with other federal agencies to the greatest extent practicable. (Recommendation 7)

Agency: Department of Justice: Federal Bureau of Investigation
Status: Open

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

Recommendation: The IRS Commissioner should, in collaboration with OMB, solicit input from CMS, FBI, SSA, and state agency stakeholders on revisions to its security policy to ensure that cybersecurity requirements for state agencies are consistent with other federal agencies and NIST guidance to the greatest extent possible. (Recommendation 8)

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

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

Recommendation: The IRS Commissioner should revise its assessment policies to maximize coordination with other federal agencies to the greatest extent practicable. (Recommendation 9)

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

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

Recommendation: The Commissioner of SSA should, in collaboration with OMB, solicit input from CMS, FBI, IRS, and state agency stakeholders on revisions to its security policy to ensure that cybersecurity requirements for state agencies are consistent with other federal agencies and NIST guidance to the greatest extent possible and document the SSA's rationale for maintaining any requirements variances. (Recommendation 10)

Agency: Social Security Administration
Status: Open

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

Recommendation: The Commissioner of SSA should fully develop policies for coordinating with state agencies on the use of prior findings from relevant cybersecurity assessments conducted by other organizations. (Recommendation 11)

Agency: Social Security Administration
Status: Open

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

Recommendation: The Commissioner of SSA should revise its assessment policies to maximize coordination with other federal agencies to the greatest extent practicable. (Recommendation 12)

Agency: Social Security Administration
Status: Open

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

Recommendation: The Administrator of CMS should expand its review of states' implementation of the provider screening and enrollment requirements to include states that have not made use of CMS's optional consultations. Similar to CMS's contractor site visits, such reviews should include any necessary steps to address areas of noncompliance for all types of enrolled providers, including those under contract with managed care organizations. (Recommendation 1)

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

Comments: CMS concurred with our recommendation. In February 2020, CMS told us that it plans to reach out to states that have not yet participated in its optional consultations to discuss their progress towards implementing provider screening and enrollment requirements, and outline steps that the states should take to come into full compliance with them. In order to fully address this recommendation CMS would need to review all states' implementation of the provider screening and enrollment requirements, including states that have not made use of CMS's optional consultations. As such, this recommendation remains open until CMS provides evidence that it has assessed the compliance of all states; we will continue to monitor CMS's progress.

Recommendation: The Administrator of CMS should annually monitor progress toward addressing any areas of noncompliance related to the provider screening and enrollment requirements for any state with one or more corrective action plans. (Recommendation 2)

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

Comments: As of February 2020, 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: 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 Defense should ensure that the CMO meets DOD's September 2019 deadline for review and approval of DOD's training curriculum for cross-functional team members and their supervisors. (Recommendation 3)

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

Recommendation: The EPA Administrator should direct EPA officials responsible for appointing advisory committee members to follow a key step in its appointment process—developing and including draft membership grids in appointment packets with staff rationales for proposed membership—for all committees. (Recommendation 1)

Agency: Environmental Protection Agency
Status: Open

Comments: In September 2019, EPA restated its reasons for disagreeing with this recommendation. (EPA's rationale for disagreeing was originally stated in a June 2019 letter included in an appendix in our report.) We will provide updated information regarding this recommendation when it becomes available.

Recommendation: EPA's Designated Agency Ethics Official should direct EPA's Ethics Office, as part of its periodic review of EPA's ethics program, to evaluate—for example, through audits or spot-checks—the quality of financial disclosure reviews for special government employees appointed to EPA advisory committees. (Recommendation 2)

Agency: Environmental Protection Agency
Status: Open

Comments: In August 2019, EPA notified GAO that it expects to launch an electronic financial disclosure reporting system for special government employees in January 2021. Once financial disclosure forms for these individuals are available electronically, EPA's Ethics Office will be better positioned to audit or review the forms, according to EPA officials. In addition, the electronic filing system should minimize errors (e.g. failing to record the date that the form was received) made by filers and reviewers, according to EPA officials.

Recommendation: The Secretary of the Navy should take steps to ensure that Navy and Marine Corps' installation personnel verify that private developers are identifying and evaluating privatized properties for historic significance, as appropriate. (Recommendation 1)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of the Army should take steps to ensure that Army installation personnel verify that private developers are identifying and evaluating privatized properties for historic significance, as appropriate. (Recommendation 2)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of the Air Force should take steps to ensure that Air Force installation personnel verify that private developers are identifying and evaluating privatized properties for historic significance, as appropriate. (Recommendation 3)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of the Navy should clarify the requirement for Navy and Marine Corps' installation personnel to conduct a physical inventory of historic properties every 3 years, including an assessment of each property's condition to ensure that facilities that have been identified and evaluated as historic are inventoried. (Recommendation 4)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of the Army should clarify the requirement for Army installation personnel to conduct a physical inventory of historic properties every 3 years, including an assessment of each property's condition to ensure that facilities that have been identified and evaluated as historic are inventoried. (Recommendation 5)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of the Air Force should clarify the requirement for Air Force installation personnel to conduct a physical inventory of historic properties every 3 years, including an assessment of each property's condition to ensure that facilities that have been identified and evaluated as historic are inventoried. (Recommendation 6)

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Acquisition and Sustainment, in collaboration with the military departments, develop and disseminate department-wide or service-wide guidance, on training related to historic preservation to installation personnel, including information on roles and responsibilities. (Recommendation 7)

Agency: Department of Defense
Status: Open

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

Recommendation: Congress should consider taking legislative action to resolve the long-standing issues between the Corps and the Advisory Council on Historic Preservation over the Corps Regulatory Program's procedures for implementing section 106 of the National Historic Preservation Act. (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: When we determine what steps the Congress has taken, we will provide updated information

Recommendation: The Secretary of Energy should develop a documented policy or clarify existing policy to implement the statutory requirement to consult with Alaska Native Corporations (ANC) on the same basis as Indian tribes under Executive Order 13175. (Recommendation 1)

Agency: Department of Energy
Status: Open

Comments: As of April 2020, the Department of Energy plans to clarify and consolidate its consultation policies and practices for consultation with Alaska Native Corporations by June 2021.

Recommendation: The Administrator of the Environmental Protection Agency should develop a documented policy or clarify existing policy to implement the statutory requirement to consult with ANCs on the same basis as Indian tribes under Executive Order 13175. (Recommendation 2)

Agency: Environmental Protection Agency
Status: Open

Comments: In December 2019, EPA created a draft document, Guiding Principles for Consulting with Alaska Native Claims Settlement Act Corporations, and issued it for consultation with Alaska Native Corporations (ANCs). The draft guiding principles seek to clarify EPA's consultation and coordination practices with ANCs. Additionally, according to agency officials, an EPA working group is in the process of developing an internal, best practices implementation guide. As of April 2020, EPA expects to finalize these guidance documents in 2020

Recommendation: The Secretary of Housing and Urban Development should develop a documented policy or clarify existing policy to implement the statutory requirement to consult with ANCs on the same basis as Indian tribes under Executive Order 13175. (Recommendation 3)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Secretary of Homeland Security should establish a time frame for developing or updating policy to implement the statutory requirement to consult with ANCs on the same basis as Indian tribes under Executive Order 13175. (Recommendation 5)

Agency: Department of Homeland Security
Status: Open

Comments: In February 2019, the Department of Homeland Security provided GAO documentation supporting a planned time frame of March 2020 for developing and updating its consultation policy to implement the statutory requirement to consult with ANCs in response to this recommendation. We plan to close the recommendation after reviewing documentation that the policy has been updated.

Recommendation: The Assistant to the Secretary of Agriculture for Rural Development should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on proposed infrastructure projects. (Recommendation 6)

Agency: Department of Agriculture: Rural Development
Status: Open

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

Recommendation: The Director of Civil Works of the Corps should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on infrastructure projects. (Recommendation 7)

Agency: Department of Defense: Department of the Army: Corps of Engineers: Civil Works
Status: Open

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

Recommendation: The Director for the Bureau of Ocean Energy Management should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on infrastructure projects. (Recommendation 8)

Agency: Department of the Interior: Bureau of Ocean Energy Management
Status: Open

Comments: As of September 2019, Bureau of Ocean Energy Management (BOEM) plans to amend its tribal consultation policy with policies and procedures for communicating with tribes after consultation by December 2020.

Recommendation: The Secretary of Energy should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on infrastructure projects. (Recommendation 10)

Agency: Department of Energy
Status: Open

Comments: As of April 2020, the Department of Energy indicated that it plans to document policies for communicating about how input from tribal consultation was considered in agency decisions on infrastructure projects by June 2021.

Recommendation: The Administrator of the Federal Highway Administration should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on infrastructure projects. (Recommendation 14)

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

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

Recommendation: The Secretary of Homeland Security should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on infrastructure projects. (Recommendation 16)

Agency: Department of Homeland Security
Status: Open

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

Recommendation: The Secretary of Housing and Urban Development should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on infrastructure projects. (Recommendation 17)

Agency: Department of Housing and Urban Development
Status: Open

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

Recommendation: The Chairman of the Nuclear Regulatory Commission should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on infrastructure projects. (Recommendation 19)

Agency: Nuclear Regulatory Commission
Status: Open

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

Recommendation: The Secretary of Transportation should document in the agency's tribal consultation policy how agency officials are to communicate with tribes about how tribal input from consultation was considered in agency decisions on infrastructure projects. (Recommendation 20)

Agency: Department of Transportation
Status: Open

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

Recommendation: The SBA Administrator or her designee should (1) develop a process for periodically reviewing Federal Procurement Data System-Next Generation (FPDS-NG) data to determine the extent to which agencies are awarding WOSB program set-asides under ineligible North American Industry Classification System (NAICS) codes and (2) take steps to address any issues identified, such as providing targeted outreach or training to agencies making awards under ineligible codes. (Recommendation 1)

Agency: Small Business Administration
Status: Open

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

Recommendation: The SBA Administrator should establish a process that ensures documentation of states' compliance with the total match requirement before grant closeout. (Recommendation 1)

Agency: Small Business Administration
Status: Open
Priority recommendation

Comments: SBA generally agreed with GAO's findings and concurred with our recommendations. In response to our draft report, agency officials said SBA will establish a process that ensures documentation of state recipients' compliance with the total match requirement before grant closeout. In September 2019, officials told us this process will include assigning SBA program office responsibilities for ensuring recipient compliance related to the cost match. In March 2020, SBA officials said they were still working on implementing changes to address our recommendation. GAO will continue to monitor the agency's implementation of this process.

Recommendation: The SBA Administrator should develop a process to determine states' compliance with the cash match requirement. (Recommendation 2)

Agency: Small Business Administration
Status: Open
Priority recommendation

Comments: SBA generally agreed with our findings and concurred with our recommendations. In response to our draft report, agency officials said they would develop a process to determine state's compliance with the cash match requirement. In September 2019, officials told us the process will apply to both grants specialists and program officers, and ensure the cost match is appropriately applied. In March 2020, SBA officials said they were still working on implementing changes to address our recommendation. GAO will continue to monitor the agency's implementation of this process.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Director, CAPE, the Joint Staff Surgeon, and the secretaries of the military departments, establish joint planning assumptions for developing operational medical and dental personnel requirements, including a definition of what forces should and should not be identified as "operational." (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense concurred with this recommendation and said it would take steps to implement it. According to department officials, as of November 2019, they are drafting a report that will address this recommendation. We will continue to monitor DOD's efforts.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Director of Cost Assessment and Program Evaluation, the Joint Staff Surgeon, and the secretaries of the military departments, establish a method to assess options for achieving joint efficiencies in medical and dental personnel requirements and any associated risks. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense concurred with this recommendation and said it would take steps to implement it. According to department officials, as of November 2019, they are drafting a report that will address this recommendation. We will continue to monitor the department's efforts. .

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Director of Cost Assessment and Program Evaluation, the Joint Staff Surgeon, and the secretaries of the military departments, apply joint planning assumptions and a method for assessing efficiencies and risk, use these to determine operational medical and dental requirements, and report to Congress. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense concurred with this recommendation and said it would take steps to implement it. According to department officials, as of November 2019, they are drafting a report that will address this recommendation. We will continue to monitor DOD's efforts..

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Health Affairs, in coordination with the Surgeons General of the military departments, identify and mitigate limitations in the clinical readiness metric, such as data reliability, a lack of complete information on reserve component providers and patient care workload performed outside of medical treatment facilities (MTFs), and the lack of linkage between the metric and patient care and retention outcomes. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense concurred with this recommendation and said it would take steps to implement it. As of November 2019, DOD has not taken any actions to implement this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Health Affairs, in coordination with the Surgeons General of the military departments and the Director of the Defense Health Agency, determines which critical wartime specialties perform high-risk, high-acuity procedures and rely upon perishable skill sets and use this information to prioritize specialties to which the clinical readiness metric could be expanded (Recommendation 5).

Agency: Department of Defense
Status: Open

Comments: The Department of Defense concurred with this recommendation and said it would take steps to implement it. As of November 2019, DOD has not implemented this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Health Affairs, in coordination with each of the Surgeons General of the military departments and the Director of the Defense Health Agency, estimates the cost and benefits, by specialty, of implementing a clinical readiness metric and use that information to determine whether DODs approach should be revised. Costs to be considered should include those needed to provide additional training for medical personnel to achieve clinical readiness thresholds and to hire additional civilian personnel in MTFs to backfill military providers who leave to attend training. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: The Department of Defense concurred with this recommendation and said it would take steps to implement it. As of November 2019, DOD has not implemented this recommendation.

Recommendation: The Program Director for Financial Integration should collect and document requirements to define project scope and meet project objectives. These requirements should be updated periodically throughout the life of the project. (Recommendation 2)

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

Comments: As of August 2020, NNSA provided a project plan for tasks to be completed for common financial reporting through 2021. However, NNSA has not developed requirements that define specific or detailed requirements for successful implementation of common financial reporting, such as the types of information that program managers need.

Recommendation: The Program Director for Financial Integration should develop a detailed project schedule. The detailed schedule should be documented as part of the annual report to Congress required in the National Defense Authorization Act for Fiscal Year 2017. (Recommendation 3)

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

Comments: As of August 2020, NNSA established a detailed project schedule for the common financial reporting effort through fiscal year 2021. However, NNSA should communicate this detailed project schedule for the effort to Congress on an annual basis.

Recommendation: The Program Director for Financial Integration should develop a formal process to identify risks, document those risks, and plan how to minimize risk exposure. (Recommendation 6)

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

Comments: In June 2020, NNSA developed a risk management plan for common financial reporting which established a framework for identifying and managing risks. GAO will continue to monitor NNSA's efforts to implement the plan, including how NNSA identifies and documents risks and mitigates risk exposure using its management plan.

Recommendation: The Program Director for Financial Integration should develop an approach to effectively engage with all project stakeholders that incorporates their expectations into project decisions. (Recommendation 7)

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

Comments: As of September 2020, NNSA has continued to engage on a regular basis with its M&O contractors. However, similar efforts have not continued with stakeholders of the program offices.

Recommendation: The Secretary of Defense should ensure that the Chief Management Officer establishes a process for identifying and prioritizing available funding to develop and implement initiatives from the cross-functional reform teams. (Recommendation 1)

Agency: Department of Defense
Status: Open
Priority recommendation

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

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

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

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

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

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

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

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

Agency: Department of Defense
Status: Open

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

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

Agency: Department of Defense
Status: Open

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

Recommendation: The Secretary of the Army should direct the Army's Provost Marshal General to take actions to help ensure that physical security inspections at locations with Arms, Ammunition, and Explosives (AA&E) are conducted on time, as required by Army guidance. (Recommendation 1)

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

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

Recommendation: The Secretary of the Navy should direct the Chief of Naval Operations' Supply, Ordnance, and Logistics Operations Division to take actions to help ensure that physical security inspections at locations with AA&E are conducted on time, as required by Navy guidance. (Recommendation 2)

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

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

Recommendation: The Secretary of the Navy should direct the Marine Corps Deputy Commandant for Plans, Policies, and Operations to take actions to help ensure that physical security inspections at locations with AA&E are conducted on time, as required by Marine Corps guidance. (Recommendation 3)

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

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

Recommendation: The Secretary of the Air Force should direct the Air Force's Office of the Deputy Chief of Staff for Logistics, Engineering and Force Protection, Directorate of Security Forces, to take actions to help ensure that inspectors at locations with AA&E are consistently documenting in inspection reports that all minimum requirements for physical security were checked. (Recommendation 4)

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

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

Recommendation: The Secretary of Defense should direct the Under Secretary of Defense for Intelligence to revise DOD guidance to require that the military services establish a process to consistently document the resolution of all identified physical security deficiencies. (Recommendation 5)

Agency: Department of Defense
Status: Open

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

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

Agency: Small Business Administration
Status: Open

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

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

Agency: Small Business Administration
Status: Open

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

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

Agency: Department of Veterans Affairs
Status: Open

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

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

Agency: Department of Veterans Affairs
Status: Open

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

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

Agency: Department of Veterans Affairs
Status: Open

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

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should develop a timeline for issuing a comprehensive guidance and instructions document for PSLF servicing. This could involve developing a new servicing manual or expanding upon the PSLF servicer's existing processing handbook. (Recommendation 1)

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

Comments: Education agreed with this recommendation and reported in September 2019 that it was continuing its efforts to improve and streamline guidance for the PSLF servicer. While Education said it is working on developing its comprehensive PSLF servicing manual, it does not yet have a timeline for how it will complete this manual and has indicated that it intends to deliver completed chapters on an iterative basis based on servicing priorities. To implement this recommendation, Education needs to develop a timeline for completing the PSLF servicing manual and demonstrate that it will provide comprehensive guidance and instructions for PSLF servicing.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should provide additional information to the PSLF servicer and borrowers to enhance their ability to determine which employers qualify for PSLF. This could involve Education developing an authoritative list of qualifying employers or improving the PSLF servicer's existing database, and making this information available to borrowers. (Recommendation 2)

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

Comments: Education agreed with this recommendation, and in December 2018, the agency released a new online tool to help borrowers better understand the PSLF eligibility requirements. Education has indicated that this tool could eventually be expanded to incorporate additional qualifying employer information. Education has also indicated that implementation of the recommendation is tied to the rollout of a new loan servicing system, which it expects to be fully operational in October 2021. To implement this recommendation, Education needs to demonstrate that it is providing information that will help the PSLF servicer and borrowers determine whether employment with specific employers will qualify borrowers for the program.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should ensure that borrowers receive sufficiently detailed information from the PSLF servicer to be able to identify any errors in the servicer's counts of qualifying payments, including information on whether or not each payment qualified toward forgiveness. (Recommendation 4)

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

Comments: Education agreed with this recommendation, and in June 2020, reported that it is reviewing communications from the PSLF servicer to ensure that borrowers receive sufficiently detailed information regarding payment counts and payment history. Education also indicated that implementation of the recommendation is tied to the rollout of a new loan servicing system, which it expects to be fully operational in October 2021. We will close the recommendation once Education provides documentation of the changes in communications from the PSLF servicer that demonstrate borrowers are receiving sufficiently detailed information regarding payment counts and payment history.

Recommendation: The Secretary of DHS should ensure that the Commissioner of Customs and Border Protection through the Executive Assistant Commissioner for Operations Support updates the 2013 workforce assessment to account for the independent requirements organization's current workforce needs. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation. Customs and Border Protection provided an estimated completion date for their workforce assessment of September 30, 2020.

Recommendation: The Secretary of DHS should ensure that the Administrator of the Federal Emergency Management Agency establishes a policy for requirements development. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation. The Federal Emergency Management Agency plans to establish a policy for requirements development by September 30, 2020, about one year after it completes changes to its governance processes.

Recommendation: The Secretary of DHS should ensure that the Director of Immigration and Customs Enforcement establishes a policy for requirements development. (Recommendation 8)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation but has not yet taken action to implement it as of August 2020.

Recommendation: The Secretary of DHS should ensure that the Director of Immigration and Customs Enforcement establishes the planned independent requirements development organization within Immigration and Customs Enforcement. (Recommendation 9)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation but has not yet taken action to implement it as of August 2020.

Recommendation: The Secretary of DHS should ensure that the Director of Immigration and Customs Enforcement conducts a workforce assessment to account for an independent requirements organization's workforce needs. (Recommendation 10)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation but has not yet taken action to implement it as of August 2020.

Recommendation: The Secretary of DHS should ensure that the Director of Immigration and Customs Enforcement establishes component specific training for requirements development. (Recommendation 11)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation but has not yet taken action to implement it as of August 2020.

Recommendation: The Secretary of DHS should ensure that the Under Secretary of Homeland Security for the National Protection and Programs Directorate finalizes and promulgates the National Protection and Programs Directorate's draft policy for requirements development. (Recommendation 12)

Agency: Department of Homeland Security
Status: Open

Comments: The National Protection and Programs Directorate changed its name to the Cybersecurity and Infrastructure Security Agency in January 2018. DHS concurred with this recommendation. The Cybersecurity and Infrastructure Security Agency estimates that it will have a final policy by September 30, 2020.

Recommendation: The Secretary of DHS should ensure that the Under Secretary of Homeland Security for the National Protection and Programs Directorate establishes the planned independent requirements development organization within the National Protection and Programs Directorate. (Recommendation 13)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation. In January 2018, the National Protection and Programs Directorate changed its name to the Cybersecurity and Infrastructure Security Agency. The Cybersecurity and Infrastructure Security Agency estimates that it will establish an independent requirements organization by September 30, 2020.

Recommendation: The Secretary of DHS should ensure that the Under Secretary of Homeland Security for the National Protection and Programs Directorate conducts a workforce assessment to account for an independent requirements organization's workforce needs. (Recommendation 14)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation. In January 2018, the National Protection and Programs Directorate changed its name to the Cybersecurity and Infrastructure Security Agency. The Cybersecurity and Infrastructure Security Agency estimates it will complete an assessment to account for an independent requirements organization's workforce needs by September 30, 2020.

Recommendation: The Secretary of DHS should ensure that the Director of the U.S. Citizenship and Immigration Services establishes the planned independent requirements development organization within U.S. Citizenship and Immigration Services. (Recommendation 21)

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation. The U.S. Citizenship and Immigration Services estimates that it will establish an independent requirements development organization by September 30, 2020.

Recommendation: The Secretary of the American Battle Monuments Commission should designate a chief FOIA officer at the assistant secretary level or equivalent. (Recommendation 1)

Agency: American Battle Monuments Commission
Status: Open

Comments: American Battle Monument Commission (ABMC) officials stated they are working to implement GAO's recommendations by the end of fiscal year 2020.

Recommendation: The Secretary of the American Battle Monuments Commission should update and publish comprehensive FOIA regulations that include requirements established by law and Justice guidance. (Recommendation 2)

Agency: American Battle Monuments Commission
Status: Open

Comments: American Battle Monument Commission (ABMC) officials stated they are working to implement GAO's recommendations. On February 18, 2020, ABMC published proposed revised FOIA regulations which are pending final rule in the Federal Register.

Recommendation: The Chief Executive Officer and Director of the Broadcasting Board of Governors should update and publish comprehensive FOIA regulations that include requirements established by law and Justice guidance. (Recommendation 3)

Agency: U.S. Agency for Global Media
Status: Open

Comments: The U.S. Agency for Global Media (formally known as the Broadcasting Board of Governors) performed a comprehensive review of its FOIA regulations and updated its regulations in accordance with GAO's recommendation. The agency anticipates publishing proposed updates for notice and comment in spring 2020, followed by a final rule.

Recommendation: The Secretary of DHS should take steps to develop and document a plan that fully addresses best practices with regards to reduction of backlogged FOIA requests. (Recommendation 4)

Agency: Department of Homeland Security
Status: Open

Comments: In April 2018, the Department of Homeland Security initiated a department-wide compliance assessment and stated that it plans to use the results of the assessment to help guide the department in identifying best practices and areas of improvement. The department does not have an estimate for when the plan will be complete.

Recommendation: The Secretary of DOI should take steps to develop and document a plan that fully addresses best practices with regards to reduction of backlogged FOIA requests. (Recommendation 7)

Agency: Department of the Interior
Status: Open

Comments: In August 2018, the Department of Interior informed GAO that the department has created a preliminary backlog reduction plan that includes expanding the use of automation tools, expanding the use of interim responses, and closing the Department's 10 oldest requests. Currently, GAO is awaiting a copy of the Department's backlog reduction plan.

Recommendation: The Chair of EEOC should designate a chief FOIA officer at the assistant secretary level or equivalent. (Recommendation 8)

Agency: Equal Employment Opportunity Commission
Status: Open

Comments: GAO is currently awaiting the agency's response to GAO recommendations..

Recommendation: The Chair of EEOC should take steps to develop and document a plan that fully addresses best practices with regards to reduction of backlogged FOIA requests. (Recommendation 9)

Agency: Equal Employment Opportunity Commission
Status: Open

Comments: GAO is currently awaiting the agency's response to GAO recommendations.

Recommendation: The Attorney General of the United States should take steps to develop and document a plan that fully addresses best practices with regards to reduction of backlogged FOIA requests. (Recommendation 11)

Agency: Department of Justice
Status: Open

Comments: In August 2018, the Department of Justice acknowledged that it plans to reexamine its progress and take steps for continued improvement in reducing its backlog. Currently, GAO is awaiting a response from the Department on a publication date.

Recommendation: The Administrator of NASA should provide agency records of final opinions online. (Recommendation 14)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: In August 2018, NASA agreed to provide agency records of final opinions online. NASA noted that final opinions will be provided online as they are issued and released for public posting. To date, the Department has not posted any final opinions.

Recommendation: The Chairman of NTSB should take steps to develop and document a plan that fully addresses best practices with regards to reduction of backlogged FOIA requests. (Recommendation 16)

Agency: National Transportation Safety Board
Status: Open

Comments: In August 2018, NTSB provided a plan that laid out tasks for reducing its backlog. The plan did not, however provide milestones or dates for when these tasks would be completed. GAO is currently waiting for the finalized backlog FOIA plan.

Recommendation: The Director of OMB should designate a chief FOIA officer at the assistant secretary level or equivalent. (Recommendation 18)

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

Comments: GAO is currently awaiting the agency's response to GAO recommendations.

Recommendation: The Director of Pension Benefit Guaranty Corporation should designate a chief FOIA officer at the assistant secretary level or equivalent. (Recommendation 19)

Agency: Pension Benefit Guaranty Corporation
Status: Open

Comments: The Pension Benefit Guaranty Corporation stated that it has designated the deputy director as the chief FOIA officer. It also noted that the director is at the Senior Level. However, this position is not equivalent to the assistant secretary level identified by GAO.

Recommendation: The President of TVA should ensure its FOIA tracking system is compliant with section 508 requirements. (Recommendation 22)

Agency: Tennessee Valley Authority
Status: Open

Comments: In August 2018, TVA provided a response to GAO's recommendation to ensure their FOIA tracking systems is compliant with section 508 requirements. TVA is currently performing an in-depth assessment of their tracking system to identify where updates can be made to ensure 508 compliance. TVA expects the assessment to be completed by the end of January 2020.

Recommendation: The President of the U.S. African Development Foundation should update and publish comprehensive FOIA regulations that inform a requester of limited unusual circumstances fees. (Recommendation 24)

Agency: African Development Foundation
Status: Open

Comments: U.S. African Development Foundation officials have stated that their FOIA regulations are currently under review and expect them to be published in the first half of calendar year 2020.

Recommendation: The Secretary of Commerce should evaluate the level of preparedness for cybersecurity personnel not currently holding certifications to take certification exams, identify strategies for mitigating any gaps identified, and report this information to Congress. (Recommendation 1)

Agency: Department of Commerce
Status: Open

Comments: Department of Commerce (Commerce) officials concurred with our recommendation and planned to evaluate the level of preparedness for cybersecurity personnel not currently holding certifications to take certification exams, and to identify strategies for mitigating any gaps identified. As of August 2020, Commerce had not provided sufficient evidence that it had implemented the recommendation. We will continue to monitor the situation.

Recommendation: The Secretary of Energy should evaluate the level of preparedness for cybersecurity personnel not currently holding certifications to take certification exams and report this information to Congress. (Recommendation 5)

Agency: Department of Energy
Status: Open

Comments: Department of Energy (DOE) officials concurred with our recommendation and planned to evaluate the level of preparedness for cybersecurity personnel not currently holding certifications to take certification exams using the National Initiative for Cybersecurity Education (NICE) certification mapping that is due for release in November 2018. DOE officials plan to develop criteria to identify personnel who are prepared to take certification exams and will perform a department-wide evaluation, after which they plan to report to Congress by a target date of September 30, 2019. As of August 2020, DOE had not provided evidence that it had implemented this recommendation. We will continue to monitor the situation.

Recommendation: The Secretary of the Interior should evaluate the level of preparedness for cybersecurity personnel not currently holding certifications to take certification exams and report this information to Congress. (Recommendation 11)

Agency: Department of the Interior
Status: Open

Comments: Department of the Interior (Interior) concurred with our recommendation. Officials from the department stated they were developing a plan to assess the workforce's preparedness to complete and maintain certifications. Interior officials stated that they were planning to leverage its learning and performance management system for assessing the level of preparedness of cybersecurity personnel to take certification exams and planned to report to Congress by March 2021. As of August 2020, HUD had not provided evidence that it had implemented this recommendation. We will continue to monitor the situation.

Recommendation: The Administrator of the National Aeronautics and Space Administration should evaluate the level of preparedness for cybersecurity personnel not currently holding certifications to take certification exams and report this information to Congress. (Recommendation 16)

Agency: National Aeronautics and Space Administration
Status: Open

Comments: National Aeronautics and Space Administration (NASA) did not concur with our recommendation and has not yet provided evidence that it has implemented the recommendation as of August 2020. We will continue to monitor the situation.

Recommendation: The Administrator of the Small Business Administration should conduct a baseline assessment of the department's cybersecurity workforce that includes (1) the percentage of personnel with IT, cybersecurity, or other cyber-related job functions who hold certifications; (2) the level of preparedness of other cyber personnel without existing credentials to take certification exams; and (3) a strategy for mitigating any gaps identified with appropriate training and certification for existing personnel. (Recommendation 25)

Agency: Small Business Administration
Status: Open

Comments: Small Business Administration (SBA) officials concurred with our recommendation. SBA officials stated that they have made significant progress in the workforce assessment area, and have recently completed an assessment of the SBA's IT workforce and reported on existing skills gaps. SBA officials stated that they plan to execute against the IT workforce plan to include addressing requirements within the Federal Cybersecurity Workforce Assessment Act of 2015. As of August 2020, SBA had not provided evidence that it had implemented the recommendation. We will continue to monitor the situation.

Recommendation: The Administrator of the Small Business Administration should submit a report of its baseline assessment of its existing cybersecurity workforce to the appropriate congressional committees of jurisdiction. (Recommendation 26)

Agency: Small Business Administration
Status: Open

Comments: Small Business Administration (SBA) officials concurred with our recommendation. SBA officials stated that they have made significant progress in the workforce assessment area, and have recently completed an assessment of the SBA's IT workforce and reported on existing skills gaps. SBA officials stated that they plan to execute against the IT workforce plan to include addressing requirements within the Federal Cybersecurity Workforce Assessment Act of 2015. As of August 2020, SBA had not provided evidence that it had implemented the recommendation. We will continue to monitor the situation.

Recommendation: The Secretary of Defense should ensure that the DOD Chief Information Officer (CIO) develops an IT enterprise architecture which includes a transition plan that provides a road map for improving the department's IT and computing infrastructure, including for each of its business processes. (Recommendation 5)

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

Comments: In October 2019, the DOD CIO developed a report on the first increment of version 3 of the department's information enterprise architecture (IEA). The report includes high-level descriptions of the current and target architectures, and high-level plans and schedules for transitioning from the current to the target architecture. The report states that because of the incremental approach to developing the architecture, the plans and schedules are notional and depend on several factors over which the DOD CIO has limited or no control, such as funding and changing world events, priorities, and technology. The report also describes plans to integrate the IEA with the department's business enterprise architecture. However, the report did not define a specific time frame for integrating the architectures. According to the report, for the next increment of the architecture, the department plans to develop compliance criteria and plans for developing an ontology, database, and tool suite. The department did not provide a time frame for completing the next increment. We will continue to monitor the department's efforts to implement the recommendation.

Recommendation: The Secretary of Defense should ensure that the DOD CIO and Chief Management Officer work together to define a specific time frame for when the department plans to integrate its business and IT architectures and ensure that the architectures are integrated. (Recommendation 6)

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

Comments: In October 2019, the DOD CIO developed a report on the first increment of version 3 of its information enterprise architecture (IEA). The report described planned efforts related to integrating the IEA and the business enterprise architecture. However, the report did not define a specific time frame for when the department plans to integrate the architectures.

Recommendation: The Secretary of the Air Force should ensure that the Director of Operations and the Air Force Manpower Analysis Agency reevaluate fighter pilot squadron requirements, to include updating current assumptions of fighter pilot workload, and assessing the impact of future incorporation of UAS platforms into combat aviation. (Recommendation 1)

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

Comments: DOD concurred with this recommendation. In its initial response, DOD noted that across the Air Force, many organizations and offices, in addition to the Director of Operations and Air Force Manpower Analysis Agency will play integral roles in determining the future size and mix of manpower requirements for fighter pilot squadrons. DOD also noted that the Air Force will review fighter wing manpower determinants to accurately account for fighter pilot workloads and analyze support organization manning to ensure adequate support to operational units. In December 2018, the Air Force provided a report to Congress on the efforts to implement GAO's recommendation, among other things. The report noted that an Air Force reevaluation of pilot staff requirements resulted in a reduction to requirements of 106 positions (4 percent). In addition, the report discussed how fighter pilot workload is impacted by UAS platforms, specifically that the growth of UAS platforms has allowed the Air Force to reduce the need for fighter aircraft operations in uncontested environments, and that the growth of the UAS pilot community has allowed that community to begin filling staff positions that would formerly have been filled by fighter pilots. Further, the report stated that the Air Force Manpower Analysis Agency - in coordination with other Air Force offices - was conducting a study of fighter squadron workloads, anticipated to be completed in mid-2019. We requested a copy of the Air For Manpower Analysis Agency study in March 2020, and again in August 2020 - but as of September 2020 a copy has not been provided. Once we have an opportunity to review the study we will update the status of this recommendation as appropriate.

Recommendation: The Secretary of the Navy should ensure that the Chief of Naval Operations reevaluate fighter pilot squadron requirements, to include updating current assumptions of fighter pilot workload, and assessing the impact of future incorporation of UAS platforms into combat aviation. (Recommendation 2)

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

Comments: DOD concurred with this recommendation. In its initial response, DOD noted that across the Navy, many organizations and offices including the resource sponsor (Naval Air Forces) will play integral roles in determining the future size and mix of manpower requirements for fighter pilot squadrons. As of August 2020, DOD officials told us that the Navy has updated most of the fighter pilot requirements for most squadrons, is taking action to update requirements for the remaining squadrons, and will provide us with documentation when the process is complete. When we obtain documentation of the updates to fighter pilot squadron requirements we will update the recommendation status as appropriate.

Recommendation: The Secretary of the Navy should ensure that the Commandant of the Marine Corps and the Deputy Commandant for Aviation reevaluate fighter pilot squadron requirements. (Recommendation 3)

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

Comments: DOD concurred with this recommendation. In its initial response, DOD noted that across the Marine Corps, many organizations and offices in addition to the Deputy Commandant for Aviation play integral roles in the continuous evaluation and determination regarding current and future size and mix of manpower requirements for fighter and attack squadrons. As of August 2020 DOD has not taken actions in response to this recommendation.

Recommendation: The Director of OMB should ensure that OMB's Office of Information and Regulatory Affairs staff, as part of the regulatory review process, examine the planned timeframes for implementing economically significant regulations or major rules and identify regulations that appear at potential risk of not complying with the Congressional Review Act's delay requirements and then work with the agencies to ensure compliance with these requirements (Recommendation 1).

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

Comments: In March 2020, OMB staff stated that they believe they have addressed the recommendation. They reiterated a statement made shortly before we issued our report that they already take steps to check agencies' compliance with the Congressional Review Act (CRA) during the regulatory review process. We published this statement in our report, but noted that OMB staff did not provide supporting documentation. Nor does the update we received in March 2020 provide supporting documentation and, thus, we cannot verify it. The update from OMB staff in March 2020 also refers to an April 2019 memorandum the Acting Director of OMB issued to the heads of executive agencies outlining updated guidance for complying with CRA. While the memorandum reminds agencies of the CRA requirement that they delay the effective date of a major rule to allow time for congressional review and following publication in the Federal Register, unless there is good cause to not delay the effective date, the Acting Director does not explain whether his office has made changes to the regulatory review process as we recommended. We will continue to monitor OMB's efforts to address our recommendation.

Recommendation: The Administrator of NNSA should require an independent entity to validate that contractor EVM systems used for LEPs meet the EVM national standard. (Recommendation 1)

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

Comments: In October 2018, NNSA stated that the integrated baseline reviews, internal reviews of earned value management (EVM) systems used by life extension programs (LEP), and other controls over data integration provide a practical and cost-beneficial approach to the validation of contractor EVM systems. However, in early 2019, NNSA conducted a lessons learned study to more fully assess the cost, benefit, mission impacts, and feasibility of implementing our recommendation for possible application to future LEPs. According to NNSA documentation, based on the results of the lessons learned study, NNSA concluded that the effort and expense needed to validate contractor EVM systems against the EVM national standard could be better used providing resources to improve the agency's ability to establish work breakdown structures, schedules, and integration of scope, cost, and schedule. As a result, as of September 2019, NNSA stated that its actions meet the intent of our recommendation. We disagree. As we stated in our report, without requiring an independent entity to validate that contractor EVM systems meet the EVM national standard, NNSA may not have assurance that its LEPs are obtaining reliable EVM data for managing their programs and reporting their status. We will continue to monitor NNSA's activities to address this recommendation.

Recommendation: The Administrator of NNSA should require an independent entity to conduct surveillance reviews of contractor EVM systems used for LEPs to ensure that they maintain compliance with the EVM national standard through program completion. (Recommendation 2)

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

Comments: In October 2018, NNSA stated that it conducts ongoing surveillance through integrated baseline reviews, internal reviews of EVM systems used by LEPs, and other assessments, which consider national standards. However, in early 2019, NNSA conducted a lessons learned study to more fully assess the cost, benefit, mission impacts, and feasibility of implementing our recommendation for possible application to future LEPs. According to NNSA documentation, based on the results of the lessons learned study, NNSA concluded that the effort and expense needed to conduct surveillance reviews of contractor EVM systems to ensure compliance with the EVM national standard could be better used providing resources to improve the agency's ability to establish work breakdown structures, schedules, and integration of scope, cost, and schedule. As a result, as of September 2019, NNSA stated that its actions meet the intent of our recommendation. We disagree. As we stated in our report, without requiring an independent entity to conduct surveillance reviews of contractor EVM systems through program completion, NNSA may not have assurance that its LEPs are obtaining reliable EVM data for managing their programs and reporting their status. We will continue to monitor NNSA's activities to address this recommendation.

Recommendation: The Administrator of NNSA should require its programs to ensure that LEP critical technologies meet specific technology readiness level benchmarks at decision points, or otherwise document with program executive approval their rationale for not meeting these benchmarks. (Recommendation 3)

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

Comments: In October 2018, NNSA stated that it has already incorporated specific benchmarks for technology readiness levels at decision points. As an example, it stated that it recommends a technology readiness level of 5 at the beginning of phase 6.3 for an LEP. As a result, NNSA stated that its actions meet the intent of our recommendation. We disagree. As we stated in our report, it is important for NNSA to establish a requirement, not just a recommendation, that LEP critical technologies meet specific technology readiness level benchmarks at decision points. We will continue to monitor NNSA's activities to address this recommendation.

Recommendation: The FAA Administrator should fulfill the CSLCA mandate to include ensuring a balance of risk between the federal government and launch companies as part of FAA's MPL methodology evaluation by reexamining the current probability thresholds. (Recommendation 1)

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

Comments: In March 2020 Department of Transportation (DOT) officials stated that FAA had not yet finished reexamining the current maximum probable loss (MPL) probability thresholds or completed a subsequent rulemaking to address the probability thresholds. The officials also stated that FAA's focus for the prior two years has been on streamlining the launch and reentry license regulations (SLR2) rulemaking in response to the President's Space Policy Directive 2, which contains the National Space Council's recommendations for commercial space regulatory reform. According to the officials, this effort will continue through 2020, and that after it is completed, FAA will evaluate whether to begin a new rulemaking to address MPL analyses.

Recommendation: The FAA Administrator should fulfill the CSLCA mandate to analyze the cost impact of implementing its revised MPL methodology by evaluating the impact on the direct costs of launch companies and the federal government. (Recommendation 2)

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

Comments: In March 2020, Department of Transportation (DOT) officials stated that FAA had not yet finished reexamining the current maximum probable loss (MPL) probability thresholds or completed a subsequent rulemaking to address the probability thresholds. The officials also stated that FAA's focus for the prior two years has been on streamlining the launch and reentry license regulations (SLR2) rulemaking in response to the President's Space Policy Directive 2, which contains the National Space Council's recommendations for commercial space regulatory reform. According to the officials, this effort will continue through 2020, and that after it is completed, FAA will evaluate whether to begin a new rulemaking to address MPL analyses.

Recommendation: The FAA Administrator should fulfill the CSLCA mandate to evaluate its MPL methodology in consultation with the commercial space sector and insurance providers by consulting with those entities on the cost impact of its revised MPL methodology, including an updated cost-of-casualty amount, on the launch industry and the federal government. (Recommendation 3)

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

Comments: In March 2020, Department of Transportation (DOT) officials stated that FAA had not yet finished reexamining the current maximum probable loss (MPL) probability thresholds or completed a subsequent rulemaking to address the probability thresholds. The officials also stated that FAA's focus for the prior two years has been on streamlining the launch and reentry license regulations (SLR2) rulemaking in response to the President's Space Policy Directive 2, which contains the National Space Council's recommendations for commercial space regulatory reform. According to the officials, this effort will continue through 2020, and that after it is completed, FAA will evaluate whether to begin a new rulemaking to address MPL analyses.

Recommendation: The FAA Administrator should establish an estimated completion date for developing and implementing a plan to establish guidance on the most appropriate MPL methodologies and tools to use for each launch. (Recommendation 4)

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

Comments: In March 2020, Department of Transportation (DOT) officials stated that FAA had not yet finished reexamining the current maximum probable loss (MPL) probability thresholds or completed a subsequent rulemaking to address the probability thresholds. The officials also stated that FAA's focus for the prior two years has been on streamlining the launch and reentry license regulations (SLR2) rulemaking in response to the President's Space Policy Directive 2, which contains the National Space Council's recommendations for commercial space regulatory reform. According to the officials, this effort will continue through 2020, and that after it is completed, FAA will evaluate whether to begin a new rulemaking to address MPL analyses.

Recommendation: Once reliable data are available, the Coast Guard, or another agency identified by the working group, should assess the rates of commercial fishing vessel accidents, injuries, and fatalities to determine whether certain factors--including vessel length and region of operation, among other things--affect these rates. (Recommendation 3)

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

Comments: The Department of Homeland Security (DHS) did not concur with our recommendation that the Coast Guard assess the rates of commercial fishing vessel accidents, injuries, and fatalities to determine whether certain factors-such as vessel length and region of operation-affect these rates. DHS officials stated that the Coast Guard has limited resources and capabilities to conduct such assessments and noted that the National Institute for Occupational Safety and Health (NIOSH) studies marine incidents to identify causal factors in fishing vessel casualties, which could more effectively determine casualty rates. The Coast Guard uses this information to update and develop commercial fishing vessel safety standards and policy, as appropriate. GAO agrees that NIOSH plays an important role in identifying commercial fishing fatalities and regional risk factors, but such assessments typically focus on fatalities in specific fisheries, and generally did not consider such factors as vessel length or whether the vessel has been classed. As of July 2020, Coast Guard officials stated the Coast Guard continues to work with other Federal partners on data collection strategies through the established work group to determine the best reliable data in order to establish credible rates of casualties, injuries, and fatalities in the commercial fishing vessel industry. This recommendation will remain open pending a decision by the working group on the appropriate agency to conduct these assessments.

Recommendation: The Coast Guard should issue regulations or guidance to clarify and implement the alternative-to-class approach. (Recommendation 4)

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

Comments: The Department of Homeland Security concurred with our recommendation that the Coast Guard issue regulations or guidance to clarify and implement the alternative-to-class approach. As of November 2018, the Coast Guard made a presentation to the commercial fishing industry clarifying the alternative-to-class approach as it relates to commercial fishing vessels including discussion topics such as understanding the language of 46 USC 4503 and State Licensed Naval Architect and Marine Engineers' scope of responsibilities when incorporating standards equivalent to those prescribed by a classification society. As of June 2020, Coast Guard officials stated they have formalized work instruction guidance regarding implementation of the alternative-to-class approach. This guidance is expected to be released by the end of 2020.

Recommendation: The Director of National Intelligence should develop a plan for monitoring continuous evaluation performance, to include assessing continuous evaluation at various phases of implementation. (Recommendation 3)

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

Comments: ODNI generally concurred with this recommendation. As of November 2019, ODNI has provided information that may allow us to close this recommendation. We are currently evaluating that information and will update this recommendation once that evaluation is complete.

Recommendation: The Director of National Intelligence should develop performance measures for continuous evaluation that agencies must track and determine a process and schedule for agencies to regularly report those measures to ODNI. At minimum, these performance measures should be clear, quantifiable, objective, and linked to measurable goals. (Recommendation 4)

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

Comments: ODNI generally concurred with this recommendation. As of November 2019, ODNI provided information that may allow us to close this recommendation. We are currently evaluating this information and once that evaluation is complete, we will update the status.

Recommendation: The Director of National Intelligence should, in coordination with the Deputy Director for Management of the Office of Management and Budget in the capacity as Chair of the Security, Suitability, and Credentialing Performance Accountability Council, conduct an evidence-based review of the timeliness goal of 195 days for completing the fastest 90 percent of periodic reinvestigations and the associated goals for the different phases of periodic reinvestigations, and adjust the goal if appropriate, taking into consideration available resources, the additional workload of continuous evaluation, and the risks associated with individuals retaining access to classified information without determining their continued eligibility. (Recommendation 5)

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

Comments: ODNI generally concurred with this recommendation. As of November 2019, ODNI stated that with the advent of Trusted Workforce 2.0, discussions are being held about timeliness goals and the periodic reinvestigation model writ large. Once we confirm what actions have been taken, we will update the status of this recommendation.

Recommendation: The Director of National Intelligence should, once ODNI has further defined the continuous evaluation program, to include issuing a Security Executive Agent Directive and developing an implementation plan, in coordination with the Deputy Director for Management of the Office of Management and Budget in the capacity as Chair of the Security, Suitability, and Credentialing Performance Accountability Council, assess the potential effects of continuous evaluation on agency resources and develop a plan, in consultation with implementing agencies, to address those effects, such as modifying the scope of periodic reinvestigations, changing the frequency of periodic reinvestigations, or replacing periodic reinvestigations for certain clearance holders. (Recommendation 6)

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

Comments: ODNI generally concurred with this recommendation. As of November 2019, ODNI provided information that may allow us to close this recommendation. We are currently evaluating that information and once that evaluation is complete, we will update the status of this recommendation.

Recommendation: The Chair of the EEOC should develop a timeline to complete the planned effort to clean Integrated Mission System data for a one-year period and add missing industry code data. (Recommendation 1)

Agency: Equal Employment Opportunity Commission
Status: Open

Comments: As part of an effort to overhaul its IMS data system, EEOC has begun developing an Employer Master List that will provide a source of employer information, including industry codes, but EEOC told us that it has not yet completed this effort. It anticipates this system will be more fully developed by spring 2020. It is important for EEOC to collect sufficient information through its Employer Master List and use it to analyze charge data by industry.

Recommendation: The Director of OFCCP should analyze internal process data from closed evaluations to better understand the cause of delays that occur during compliance evaluations and make changes accordingly. (Recommendation 2)

Agency: Department of Labor: Office of Federal Contract Compliance Programs
Status: Open

Comments: In June 2019, OFCCP officials reported that OFCCP's procedures outlined in the Active Case Enforcement Directive (DIR 2011-01) caused delays in case closures, but OFCCP did not indicate that this conclusion resulted from the recommended analysis of internal process data from closed evaluations. OFCCP officials reported that the agency's aged case rate-defined as a case which is open for more than 730 days and has not been referred for further enforcement-has dropped from 27.7 percent in fiscal year 2017 to 20.9 percent in fiscal year 2019. However, it did not report on changes in case outcomes. In September 2019, OFCCP officials told us they continue to look for ways to address delays with effective policies that make the agency more efficient. We maintain that OFCCP should determine the root causes of delays based on data analysis of actual evaluations to demonstrate that its policy changes are accurately targeting the causes of these delays.

Recommendation: The Director of OFCCP should assess the quality of the methods used by OFCCP to incorporate consideration of disparities by industry into its process for selecting contractor establishments for compliance evaluation. It should use the results of this assessment in finalizing its procedures for identifying contractor establishments at greatest risk of noncompliance. (Recommendation 4)

Agency: Department of Labor: Office of Federal Contract Compliance Programs
Status: Open

Comments: In its agency response to our November 2017 report, OFCCP officials reported that the agency was exploring the use of U.S. Census Bureau and administrative data to refine its selection process to focus on industries with a greater likelihood of noncompliance. In January 2019, DOL officials reported that DOL had revised its scheduling methodology to include industries with the highest rates of violations. OFCCP published the scheduling list in March 2019 and its field offices started scheduling cases in May 2019. OFCCP stated it will continue to monitor results from this revised scheduling methodology to determine its effectiveness. It will be important for OFCCP to refine these methods based on its experiences with them. This new process is a step toward focusing efforts on industries at greater risk of potential noncompliance with nondiscrimination or affirmative action requirements. We will consider closing this recommendation when these efforts are complete.

Recommendation: The Director of OFCCP should evaluate the current approach used for identifying entities for compliance review and determine whether modifications are needed to reflect current workplace structures and locations or to ensure that subcontractors are included. (Recommendation 5)

Agency: Department of Labor: Office of Federal Contract Compliance Programs
Status: Open

Comments: In fiscal year 2019, OFCCP evaluated its current approach for identifying subcontractors for review. OFCCP stated that the current approach does not reliably include subcontractors in the pool from which contractors are scheduled because there is no government or public database that captures the complete universe of subcontractors and other important data. In June 2019, OFCCP submitted revisions to its process to the Office of Management and Budget (OMB) for approval. We will consider closing this recommendation when these efforts are complete.

Recommendation: The Director of OFCCP should evaluate the Functional Affirmative Action Program to assess its usefulness as an effective alternative to an establishment-based program, and determine what improvements, if any, could be made to better encourage contractor participation. (Recommendation 6)

Agency: Department of Labor: Office of Federal Contract Compliance Programs
Status: Open

Comments: OFCCP has taken steps to encourage contractors to use the FAAP program without fully evaluating it as an alternative to the establishment-based program. Evaluating the FAAP could help OFCCP improve its ability to achieve its objectives and may provide broader insight for OFCCP's overall enforcement approach. We will consider closing this recommendation when these efforts are complete.

Recommendation: The FEMA Assistant Administrator for Recovery, in coordination with the Associate Administrator of the Federal Insurance and Mitigation Administration, should develop performance measures and associated objectives for the new delivery model to better align with FEMA's strategic goal for hazard mitigation in the recovery process. (Recommendation 5)

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency: Office of Response and Recovery: Assistant Administrator for Recovery
Status: Open

Comments: FEMA concurred with this recommendation and said it would take steps to implement it. As of September 2018, officials reported completing activities to develop disaster-specific mitigation performance measures that align with strategic goals and analyzed available data to identify the drivers of mitigation in events of various sizes. Due to hiring delays associated with the establishment of the 406 Mitigation Branch, officials have extended the expected completion date for all actions, including proposing refined performance measures to FEMA senior leadership, to the end of January 2019. As of December 2019, GAO is awaiting a response from FEMA on their progress completing these actions.

Recommendation: The Chief Investment Officer of the Federal Retirement Thrift Investment Board should use key practices as appropriate to increase opportunities for MWO asset managers if and when implementing its mutual fund window platform. Specifically, the Chief Investment Officer should take actions to demonstrate top leadership commitment, remove potential barriers, conduct outreach to MWO firms, and communicate its priorities and expectations for an inclusive selection process to its staff and consultants if and when it begins to search for a mutual fund window platform. (Recommendation 2)

Agency: Federal Retirement Thrift Investment Board
Status: Open

Comments: The Federal Retirement Thrift Investment Board (FRTIB) did not concur with this recommendation. In July 2020, FRTIB officials told us they expect to award the mutual fund window contract in the last quarter of 2020 and that one of the goals in offering the mutual fund window is to ensure that Thrift Savings Plan participants have a variety of funds from which to choose. However, FRTIB has not changed its position on the recommendation. We continue to believe that the recommendation is valid and will monitor FRTIB's efforts to address it.

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Director of the Defense Logistics Agency should comply with sections 15(k)(2), (k)(7), (k)(11), and (k)(17) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Department of Defense: Defense Logistics Agency
Status: Open

Comments: For section 15(k)(2), related to the compensation and seniority of the person heading the OSDBU office, DOD concurred with this part of the recommendation. Agency officials stated that the agency requested that DOD seek Congressional approval to authorize a new Senior Executive Service position for the OSDBU director, and the agency has been waiting for this authorization to make this change. An agency official said that DLA recently hired a new Office of Small Business Programs director at the GS-15 equivalent level. This hire is not consistent with the requirements of section 15(k)(2). We will continue to monitor DOD's efforts to address this recommendation. For section 15(k)(7), related to supervisory duties, DOD did not concur with this part of the recommendation. An agency official said that the management structure of DLA and its subordinate elements precludes assigning supervisory authority by the DLA OSBP over all agency personnel involved in small business functions. The official said that DOD OSDP is working to submit legislative proposals for the fiscal year 2020 National Defense Authorization Act. These proposals may address DLA's compliance with section 15(k)(7). For section 15(k)(11), related to advise on insourcing, DOD concurred with this part of the recommendation and said that future insourcing actions will be coordinated with the DLA OSBP as required. The agency official said that as of August 10, 2018, there have not been any insourcing actions. DOD provided a memo documenting that a future update of DOD policy will include language about complying with section 15(k)(11) requirement. The information provided is sufficient to close this part of the recommendation. For section 15(k)(17), related to responding to undue restrictions on the ability of small businesses to compete, DOD concurred with this part of the recommendation. DOD provided a memo that includes information on how the agency will comply with the section 15(k)(17) requirements and that these procedures will be included in a future DOD policy update. The information provided is sufficient to close this part of the recommendation as implemented.

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Secretary of Agriculture should comply with sections 15(k)(2), (k)(15), and (k)(17) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Department of Agriculture
Status: Open

Comments: For section 15(k)(2), related to the compensation and seniority of the person heading the OSDBU office, and for section 15(k)(15), related to collateral duties, on September 13, 2018, an agency official stated that the agency currently does not have an OSDBU director. The official stated that the agency does not have an estimate for when this would occur because the director is appointed by the White House. We will continue to monitor USDA's efforts to address this part of the recommendation. For section 15(k)(17), related to undue restriction on the ability of small businesses to compete, an agency official stated that the OSDBU is working on an internal policy which will include guidelines for action. The official stated that the estimated completion date is January 2019. We will continue to monitor USDA's efforts to address this part of the recommendation.

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Secretary of the Army should comply with section 15(k)(8) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

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

Comments: DOD did not concur with this recommendation, related to assigning small business technical advisors, because it said that the Defense Federal Acquisition Regulation Supplement delegates the authority to appoint small business technical advisers to the head of the contracting activity. We continue to believe that the recommendation is valid because when a statutory provision such as section 15(k) and regulations such as the acquisition regulation conflict, the statute controls. An agency official said that the DOD OSBP recommended, as part of the legislative proposal process, changes to the National Defense Authorization Act to align with the DOD OSBP's interpretation of the statute, but it did not make it out of DOD. We will continue to monitor DOD's efforts to address this recommendation.

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Secretary of Defense should comply with sections 15(k)(5) and (k)(8) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Department of Defense
Status: Open

Comments: For section 15(k)(5), related to identifying and addressing bundling of contract requirements, DOD did not concur with this part of the recommendation because it said that no contracting or bundling occurs at the level of the Office of the Secretary of Defense. We continue to believe that the recommendation is valid because if DOD believes that the situation of this office supports that it is in compliance with section 15(k)(5), the agency should report to Congress on how it believes it is in compliance, and seek any statutory flexibilities or exceptions believed appropriate. We will continue to monitor DOD's efforts to address this part of the recommendation. For section 15(k)(8), related to assigning small business technical advisors, DOD did not concur with this part of the recommendation because it said that the Defense Federal Acquisition Regulation Supplement delegates the authority to appoint small business technical advisers to the head of the contracting activity. We continue to believe that the recommendation is valid because when a statutory provision such as section 15(k) and regulations such as the acquisition regulation conflict, the statute controls. An agency official said that the DOD OSBP recommended, as part of the legislative proposal process, changes to the National Defense Authorization Act to align with the DOD OSBP's interpretation of the statute, but it did not make it out of DOD. We will continue to monitor DOD's efforts to address this part of the recommendation.

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Secretary of Education should comply with sections 15(k)(3) and (k)(11) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Department of Education
Status: Open

Comments: For section 15(k)(3), related to reporting to the agency head or deputy head, an agency official stated that a deputy secretary was confirmed in May 2018 but that the previous OSDBU director was no longer with the agency and a new director would be appointed to the OSDBU director position. The agency official also said that once a new OSDBU director is assigned, the deputy secretary will provide oversight to the OSDBU director including signing the director's performance appraisal. We will continue to monitor the Department of Education's efforts to address this part of the recommendation. For section 15(k)(11), related to advise on insourcing, on July 20, 2018, an agency official provided guidance on insourcing which states that the OSDBU will review and advise on any decision to convert an activity performed by a small business concern to an activity performed by a federal employee. The information provided is sufficient to close as implemented this part of the recommendation.

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Secretary of Energy should comply with sections 15(k)(3), (k)(8), and (k)(17) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Department of Energy
Status: Open

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

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Secretary of the Interior should comply with sections 15(k)(11) and (k)(17) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Department of the Interior
Status: Open

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

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Secretary of the Navy should comply with section 15(k)(8) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

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

Comments: DOD did not concur with this recommendation, related to assigning small business technical advisors, because it said that the Defense Federal Acquisition Regulation Supplement delegates the authority to appoint small business technical advisers to the head of the contracting activity. We continue to believe that the recommendation is valid because when a statutory provision such as section 15(k) and regulations such as the acquisition regulation conflict, the statute controls. An agency official said that the DOD OSBP recommended, as part of the legislative proposal process, changes to the National Defense Authorization Act to align with the DOD OSBP's interpretation of the statute, but it did not make it out of DOD. We will continue to monitor DOD's efforts to address this recommendation.

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Secretary of the Treasury should comply with sections 15(k)(8) and (k)(11) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Department of the Treasury
Status: Open

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

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Secretary of Veterans Affairs should comply with sections 15(k)(3), (k)(8), and (k)(11) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Department of Veterans Affairs
Status: Open

Comments: For section 15(k)(3), related to reporting requirement (head of agency or deputy head), a VA official stated that the agency has changed the reporting relationship of the OSDBU director. The official stated that the Deputy Secretary will now act as rating Official for the Executive Director, OSDBU, and will sign the initial draft rating. The official also provided a Senior Executive Leaders FY 2018 Rating Scheme (dated January 2018) which shows that the Deputy Secretary rates and reviews the OSDBU director. The information provided is sufficient to close as implemented this part of the recommendation. For section 15(k)(8), related to assigning small business technical advisors, an agency official stated that VA has circulated a draft Memorandum of Understanding for concurrence which would address among other things, the extent of supervisory authority to be exercised over the Small Business Technical Advisor personnel by the Executive Director, OSDBU, while the advisor personnel remain employees of the contracting activity. The official stated that VA's revised target completion date for this effort is September 30, 2019. We will continue to monitor VA's efforts to address this part of the recommendation. For section 15(k)(11), related to advise on in-sourcing, as of January 18, 2018, VA updated its Small Business Procurement Review Program Policy to include language about the role of the OSDBU as it relates to the requirements for section 15(k)(11). A VA official also stated that the policy was distributed by email to VA's acquisition workforce and was also posted to the agency's intranet on February 12, 2018. The official stated that this policy has been distributed to OSDBU staff and provided a copy to GAO. The information provided is sufficient to close as implemented this part of the recommendation.

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Director of the Office of Personnel Management should comply with sections 15(k)(2), (k)(8), and (k)(17) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Office of Personnel Management
Status: Open

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

Recommendation: To address demonstrated noncompliance with section 15(k) of the Small Business Act, as amended, the Commissioner of the Social Security Administration should comply with sections 15(k)(2), (k)(3), (k)(6), (k)(8), (k)(11), and (k)(15) or report to Congress on why the agency has not complied, including seeking any statutory flexibilities or exceptions believed appropriate.

Agency: Social Security Administration
Status: Open

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

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

Agency: Department of Homeland Security
Status: Open

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

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

Agency: Department of State
Status: Open

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

Recommendation: 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 help ensure that DOD is implementing the fraud, waste, and abuse prevention requirements to the OIGs, the Inspectors General of the Army, Navy, and Air Force should implement the requirements themselves or delegate the implementation of the requirements to the investigative services.

Agency: Department of Defense: Department of the Navy: Naval Inspector General
Status: Open

Comments: DOD concurred with the recommendation in its comments on the draft report. In June 2020, we requested information on the status of the recommendation. When we confirm the actions the Navy has taken, we will provide updated information.

Recommendation: To help ensure that DOD is implementing the fraud, waste, and abuse prevention requirements to the OIGs, the Inspectors General of the Army, Navy, and Air Force should implement the requirements themselves or delegate the implementation of the requirements to the investigative services.

Agency: Department of Defense: Department of the Army: Office of the Inspector General
Status: Open

Comments: DOD concurred with the recommendation in its comments on the draft report. As of July 2020, the Army had drafted a memorandum that would delegate the requirements to the investigative services or program office. We will update the status of this recommendation after the Army issues the final memorandum.

Recommendation: To mitigate the risk of poor acquisition outcomes and strengthen the department's investment decisions, the Secretary of Homeland Security should direct the Undersecretary for Management to update the acquisition policy to require that major acquisition programs' technical requirements are well defined and key technical reviews are conducted prior to approving programs to initiate product development and establishing Acquisition Program Baselines, in accordance with acquisition best practices.

Agency: Department of Homeland Security
Status: Open

Comments: In providing comments on this report, DHS concurred with our recommendation and stated that it planned to initiate a study to assess how to better align its processes for technical reviews and acquisition decisions. Upon completion of the study, DHS updated its acquisition policy instruction in May 2019, which adjusted the acquisition life cycle. Specifically, the updated instruction requires programs to conduct key technical reviews--including a preliminary design review--prior to establishing the program's Acquisition Program Baseline. As of July 2020, DHS was in the process of updating the related policies and guidance for its Systems Engineering Life Cycle, which govern the department's technical reviews. GAO will review these policies and guidance once complete to confirm alignment with the changes made to the acquisition management instruction and will monitor DHS's implementation of its new acquisition life cycle to ensure the department's actions meet the intent of this recommendation.

Recommendation: To improve the awareness of how risk-significant radioactive sources are transported within the United States and to better determine whether Nuclear Regulatory Commission (NRC) is meeting its goal of providing reasonable assurance for preventing the theft or diversion of these dangerous materials, the Chairman of NRC should take actions to collect information from licensees on the number of shipments and mode of transport for such sources--for example, by identifying the extent to which an existing NRC database (e.g., the National Source Tracking System) may be used to capture this information.

Agency: Nuclear Regulatory Commission
Status: Open

Comments: In its February 26, 2018 report to Congress on actions NRC has taken in response to GAO recommendations, NRC continued to disagree with the recommendation to expand its existing data collection requirements or to transition such information from its existing NRC databases to the NSTS. NRC stated that, as required by 10 CFR Part 37, "Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material," the NRC currently collects the number of shipments and mode of transport for domestic transfers, and the import and export of Category 1 quantities of radioactive material. Additionally, under the provisions of 10 CFR Part 110, "Export and Import of Nuclear Material," the NRC stated that it collects the number of shipments and mode of transport for the import and export of shipments containing Category 2 or higher quantities of radioactive material. The NRC stated that it is the agency's position that the current information collected provides the NRC with an understanding of the potential modes of transport for Category 1 and 2 quantities of radioactive material and existing regulatory requirements provide robust protection for all such modes. The NRC stated that it does not consider the proposed additional information collection activity to be of sufficient safety or security benefit to justify the associated regulatory actions it would require. In August 2019, and again in August 2020, the NRC reaffirmed its disagreement with this recommendation and that it did not intend to take action to implement it. Despite its disagreement with this recommendation, we will continue to monitor whether NRC takes any actions that would result in addressing the concern GAO raised.

Recommendation: In order for drug sponsors to benefit from FDA's revised guidance on antibiotic development and take full advantage of the QIDP designation, FDA should develop and make available written guidance on the QIDP designation that includes information about the process a drug sponsor must undertake to request the fast track designation and how the agency is applying the market exclusivity incentive.

Agency: Department of Health and Human Services: Food and Drug Administration
Status: Open

Comments: According to HHS, FDA issued draft guidance (a document of frequently asked questions) in January of 2018 that describes the QIDP designation. However, this document is in draft form and has not yet been finalized. As of August 2020, FDA reported it is working to finalize this guidance this year. GAO will revisit this recommendation when the final guidance is issued.

Recommendation: In order to better integrate virtual training devices into operational training, the Secretary of Defense should direct the Secretary of the Army to specify in Army guidance for developing virtual training device requirements that training developers consider and document the time available to train with the devices and intended usage rates to achieve training tasks and proficiency goals during operational training.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. As of December 2019, the Army had taken some steps to improve its guidance, as GAO recommended in August 2016, but did not plan to fully address the recommendation until 2021. Officials stated that the Army established target usage rates for existing virtual training devices and issued guidance and tracking tools for recording device usage. However, the Army had not modified the guidance, cited in GAO's August 2016 report, to require that training developers consider the amount of time available to train with or expected usage rates of new virtual training devices. According to Army officials, they will implement GAO's recommendation in a planned update to guidance on the justification and validation of new virtual training devices scheduled for 2021. By updating this guidance, the Army will have the information it requires to evaluate the amount of virtual training capabilities needed to achieve training tasks and proficiency goals during operational training.

Recommendation: To ensure that NNSA will provide clear information to stakeholders about the program needs that the revised CMRR project will satisfy, the Secretary should direct the Under Secretary for Nuclear Security, in his capacity as the NNSA Administrator, to update the program requirements document for the revised CMRR project to clarify whether the project will provide plutonium analysis equipment to meet the needs of DOE and NNSA programs other than those in the Office of Defense Programs.

Agency: Department of Energy
Status: Open

Comments: As of August 2020, LANL has drafted a revised PRD but NNSA's review is not yet complete. This recommendation will remain open until we can evaluate the PRD.

Recommendation: To enhance FAA's risk-based approach for oversight of repair stations, the Secretary of Transportation should direct the Administrator of the Federal Aviation Administration to develop and implement a process in Flight Standards for incorporating into SAS the volume of critical maintenance that each U.S. airline contracts to repair stations.

Agency: Department of Transportation
Status: Open

Comments: FAA did not concur with this recommendation. In July 2019, GAO confirmed that FAA does not plan to implement the recommendation because the agency continues to believe the subjective nature of volume of work makes it an ineffective risk indicator. However, the agency monitors many factors as primary risk indicators at repair stations. Many of these risk indicators are associated with important aspects of work volume such as high workforce turnover; changes in management; rapid growth or downsizing; changes in aircraft complexity/programs; financial conditions; age of fleet and increases in aircraft discrepancies. FAA considers these factors and the criticality of a specific maintenance action on an aircraft to be the most important risk indicators.

Recommendation: To enhance FAA's risk-based approach for oversight of repair stations, the Secretary of Transportation should direct the Administrator of the Federal Aviation Administration to develop and implement an evaluative process with measurable performance goals and measures to determine the effectiveness of SAS as the SMS safety assurance component.

Agency: Department of Transportation
Status: Open

Comments: In July 2019, GAO confirmed that FAA plans to develop overall program goals and metrics as part of the next implementation phase of its new Safety Assurance System. These metrics are expected to be fully developed based on the final design of the new system and the program requirements identified. Final system testing and deployment into production for the Safety Assurance System is expected to be completed by February 2021, with final implementation scheduled to be completed by May 2022. Additionally, prior to deploying the system, FAA plans to provide training courses to the aviation safety workforce who will be using the new system, and plans to issue new policy documentation in June 2020 that will be used to provide additional guidance to that workforce on properly using the system.

Recommendation: To improve transparency in allocating its limited resources, and to help ensure that its resource allocation decisions are the most effective ones for fulfilling its missions given existing risks, the Commandant of the Coast Guard should document how the risk assessments conducted were used to inform and support its annual asset allocation decisions.

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

Comments: In February 2018, the Coast Guard liaison stated that Coast Guard management made a decision to not to address this recommendation within the annual Strategic Planning Direction (SPD) or Operational Planning Direction (OPD) products as previously planned, but rather within the Standard Operational Planning Process/Global Force Management Process Guide. The liaison further stated that both of these documents are currently under revision and expected to be completed by March 31, 2018. On October 11, 2018, the Coast Guard liaison stated that The Standard Operational Planning Process/Global Force Management Instruction is in routing for edits, comment, and final approval. The new estimated completion date is the 2nd quarter of FY 2019. GAO sent an inquiry to the Coast Guard on April 24, 2019 and is awaiting a reply. On March 30, 2020, the Coast Guard liaison informed GAO that the update to the Standard Operational Planning Process (SOPP)/Global Force Management (GFM) Instruction, which includes the addition and test of Strategic Priorities Planning Guidance and the new Coast Guard Force Allocation Matrix, was further delayed due to recent discussions of changing to a 2-year SOPP planning cycle to align with the Department of Defense Global Force Management process. This change would further require an update of the SOPP/GFM Instruction. The COVID-19 crisis as well as the need to finalize the Strategic Planning Direction by June 2020 are also factors in this delay. New Estimated Completion Date (ECD): June 30, 2021.

Recommendation: To ensure that high priority mission activities are fully supported with the appropriate number of staff possessing the requisite mix of skills and abilities, the Commandant of the Coast Guard should develop a systematic process that prioritizes manpower requirements analyses for units that are the most critical for achieving mission needs.

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

Comments: On December 14, 2016, the Coast Guard noted that it submitted two FY 2019 Resource Proposals to staff and equip the Manpower Requirements Determination Division to conduct the analysis as described in the recommendation. In April, 2016, the Coast Guard liaison stated that, resources permitting, the Coast Guard is to address the following steps: (1) Validate the "unit-type" list so that it encompasses the vast majority of active duty and civilian billets in a logical framework that can be readily analyzed, review/update the list as changes (e.g., asset mix, organizations) occur. (2) Develop the requirements for the envisioned Manpower Analysis & Simulation Tool (MAST). (3) Prioritize unit list according to strategic alignment and risk assessment (4) Conduct the manpower requirements analyses (MRA) in accordance with established priorities. As of August 2020, the Coast Guard reported it had not implemented the actions. Specifically, the Coast Guard reported that in response to GAO's February 2020 modernization report (GAO-20-223, rec#2), it was developing new guidance for executing the manpower requirement determination process. Officials told us that the new guidance would include a systematic process for prioritizing manpower analysis. In this way, the actions for implementing the GAO-20-223 recommendation may also serve to meet the intent of the recommendation for GAO-16-379. Officials told us the Coast Guard estimated implementing the actions by December 31, 2020.

Recommendation: To improve the strategic allocation of assets, the Commandant of the Coast Guard should incorporate field unit input, such as information on assets' actual performance from Operational Performance Assessment Reports and Planning Assessments, to inform more realistic asset allocation decisions--in addition to asset performance capacities currently used--in the annual Strategic Planning Directions to more effectively communicate strategic intent to field units.

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

Comments: In February 2018, the Coast Guard liaison stated that Coast Guard management made a decision to not to address this recommendation within the annual Strategic Planning Direction (SPD) or Operational Planning Direction (OPD) products as previously planned, but rather within the Standard Operational Planning Process/Global Force Management Process Guide. The liaison further stated these documents are under revision and expected to be completed by March 31, 2018. On October 11, 2018, the Coast Guard liaison stated that The Standard Operational Planning Process/Global Force Management Instruction is in routing for edits, comment, and final approval. The new estimated completion date is the 2nd quarter of FY 2019. GAO sent an inquiry to the Coast Guard on April 24, 2019 asking for an update. On March 30, 2020, the Coast Guard liaison informed GAO that the update to the SOPP/GFM Instruction, which includes the addition and test of Strategic Priorities Planning Guidance and the new Coast Guard Force Allocation Matrix, was further delayed due to recent discussions of changing to a 2-year SOPP planning cycle to align with the Department of Defense Global Force Management process. The liaison stated that the COVID-19 crisis as well as the need to finalize the Strategic Planning Direction by June 2020 are also factors in this delay. The new estimated completion date for this recommendation is June 30, 2021.

Recommendation: To help ensure continued progress in the implementation of effective cloud computing SLAs, the Secretaries of Health and Human Services, Homeland Security, Treasury, and Veterans Affairs should direct appropriate officials to develop SLA guidance and ensure key practices are fully incorporated as the contract and associated SLAs expire.

Agency: Department of Health and Human Services
Status: Open

Comments: The Department of Health and Human Services (HHS) concurred with our recommendation and reported that the department was in the process of addressing it. Specifically, a HHS official reported in August 2020 that the department had created a team to address cloud computing best practices and intended to finalize guidance on SLA key practices by June 2021. We will continue to evaluate the department's progress in implementing this recommendation.

Recommendation: To help ensure continued progress in the implementation of effective cloud computing SLAs, the Secretaries of Health and Human Services, Homeland Security, Treasury, and Veterans Affairs should direct appropriate officials to develop SLA guidance and ensure key practices are fully incorporated as the contract and associated SLAs expire.

Agency: Department of the Treasury
Status: Open

Comments: In August 2020, an official from the Department of the Treasury (Treasury) reported that the department was in the process of addressing the recommendation. Specifically, a Treasury official reported that the department's Office of the Chief Information Officer was working with the Treasury Senior Procurement Executive to incorporate the key practices identified in our report into Treasury acquisition policy, which was expected to be completed by January 2021. We will continue to monitor the status of this recommendation.

Recommendation: To help ensure continued progress in the implementation of effective cloud computing SLAs, the Secretaries of Health and Human Services, Homeland Security, Treasury, and Veterans Affairs should direct appropriate officials to develop SLA guidance and ensure key practices are fully incorporated as the contract and associated SLAs expire.

Agency: Department of Veterans Affairs
Status: Open

Comments: The Department of Veterans Affairs (VA) concurred with our recommendation and reported that the department was in the process of addressing it. In August 2020, a VA official reported that the department's Office of Information Technology was working to re-write existing SLA documentation following a review from the Office of Inspector General but did not provide a date when the guidance would be finalized. We will continue to monitor the status of this recommendation.

Recommendation: To ensure that all BIE schools are positioned to address safety and health problems with their facilities and provide student environments that are free from hazards, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a plan to build schools' capacity to promptly address safety and health problems with facilities. Such a plan could prioritize assistance to schools to improve the expertise of facility staff to maintain and repair school buildings.

Agency: Department of the Interior
Status: Open
Priority recommendation

Comments: Interior agreed with this recommendation. In June 2018, Indian Affairs provided us with documentation on its efforts to build schools' capacity to address safety and health problems with facilities. In particular, the agency updated its Service Level Agreement between BIA and BIE, which details their roles and responsibilities for inspecting and providing technical assistance to BIE schools, among other areas. However, Indian Affairs' documents provided little information on how it planned to support BIE school personnel in fixing safety hazards in their facilities. In our 2016 report, we found that school personnel often lack the necessary technical expertise, time, and resources to address safety hazards in school buildings. Further, the agency did not include information on whether it has staffed regional offices with specialists to assist schools with safety and facility issues. In February 2020, agency officials said that they had not taken further actions to implement the recommendation and indicated that no office or official was currently responsible for coordinating efforts to implement the recommendation.

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 provide greater assurance that the Interagency Rotation Program for national security personnel will be implemented as provided in section 1107 of the National Defense Authorization Act for Fiscal Year 2013, the Director of the Office of Personnel Management, in collaboration with the Committee on National Security Personnel, should establish a clear leadership and oversight structure to guide future implementation efforts.

Agency: Office of Personnel Management
Status: Open

Comments: OPM generally concurred with the recommendations, but raised issues primarily about the roles and responsibilities that GAO addresses in the report. As of November 2019, OPM has not taken any action on this recommendation.

Recommendation: To provide greater assurance that the Interagency Rotation Program for national security personnel will be implemented as provided in section 1107 of the National Defense Authorization Act for Fiscal Year 2013, the Director of the Office of Personnel Management, in collaboration with the Committee on National Security Personnel, should work with the departments and agencies to identify and take action on necessary next steps to proceed with the program's implementation, including developing and issuing required guidance for implementation within identified timeframes.

Agency: Office of Personnel Management
Status: Open

Comments: OPM generally concurred with the recommendations, but raised issues primarily about the roles and responsibilities that GAO addresses in the report. As of November 2019, OPM has not taken any action on this recommendation.

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 strengthen oversight of the individual shared responsibility and premium tax credit provisions, the Commissioner of Internal Revenue should assess whether or not the data received from the health insurance marketplaces are sufficiently complete and accurate to enable effective correction of tax returns at-filing based on matching with the marketplace data and, if the assessment determines that such corrections would be effective, seek legislative authority to correct tax returns at-filing based on the marketplace data.

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

Comments: The Internal Revenue Service (IRS) agreed with GAO's recommendation. IRS reports that the quality of data submitted by health insurance marketplaces has improved since the 2015 return filing season, and it continues to use its correspondence process for resolving discrepancies between marketplace data and that reported by the taxpayer after the return has been filed. IRS has not considered requesting legislative authority to correct tax returns at the time of filing based specifically on discrepancies between the data submitted by the health insurance marketplace and reported by the taxpayer. Agency officials believe that would be premature at this time. They noted that a broader legislative initiative has already been proposed that would grant IRS with correctable error authority in cases where the information provided by the taxpayer does not match the information contained in government databases. Should this broad authority be granted in the future, IRS will then consider how to approach correction of tax returns at the time of filing based on discrepancies with health insurance marketplace data. Such authority was also included in the Administration's 2021 budget.

Recommendation: To strengthen oversight of the individual shared responsibility and premium tax credit provisions, the Commissioner of Internal Revenue should evaluate IRS efforts to collaborate and communicate with key external stakeholders to inform efforts related to implementation of the new 2015 PPACA requirements.

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

Comments: The Internal Revenue Service (IRS) agreed with GAO's recommendation but has not yet initiated an evaluation of collaboration and communication efforts with external stakeholders. IRS currently utilizes informal feedback processes to share information and identify opportunities for improvement with external stakeholders in implementing the shared responsibility payment and premium tax credit provisions. We continue to encourage IRS to evaluate its collaboration and communication efforts, but such an evaluation has not yet happened. We will continue to monitor IRS efforts.

Recommendation: To ensure consistent implementation of the Buy Indian Act procurement authority across the agencies and to enhance oversight of implementation of the Act at regional offices, the Secretaries of the Interior and Health and Human Services should direct the Bureau of Indian Affairs and Indian Health Service respectively, to clarify and codify their policies related to the priority for use of the Buy Indian Act, including whether the Buy Indian Act should be used before other set-aside programs.

Agency: Department of Health and Human Services
Status: Open

Comments: The Department of Health and Human Services concurred with this recommendation. The Indian Health Service (IHS) informed GAO that in order to clarify and codify the policies related to priority for use of the Buy Indian Act, formal rulemaking was required. IHS published the intent to promulgate the regulation in the Fall 2019 and Spring 2020 Unified Agendas. According to IHS officials, the timeline for completion of the new regulation is December 31, 2020.

Recommendation: To ensure consistent implementation of the Buy Indian Act procurement authority across the agencies and to enhance oversight of implementation of the Act at regional offices, the Secretaries of the Interior and Health and Human Services should direct the Bureau of Indian Affairs and Indian Health Service respectively, to collect data on regional offices' implementation of key requirements, such as challenges to self-certification.

Agency: Department of Health and Human Services
Status: Open

Comments: The Department of Health and Human Services concurred with this recommendation. The Indian Health Service (IHS) informed GAO that in order to clarify and codify policies related to priority for use of the Buy Indian Act, formal rulemaking was required. IHS published the intent to promulgate the regulation in the Fall 2019 and Spring 2020 Unified Agendas. Further, the officials stated that once the new Buy Indian regulation is promulgated, IHS plans to identify a plan to collect data on area office implementation of key policy requirements, including monitoring authentication of contractor credentials. According to IHS officials, due to limitations within the Federal Procurement Data System- Next Generation IHS is unable to collect the necessary data until the rule is promulgated.

Recommendation: To ensure that the Defense Civilian Personnel Advisory Service (DCPAS) and DOD components are determining LQA eligibility consistently with DOD's LQA Instruction, the DSSR, and OPM compensation claim decisions, the Secretary of Defense should direct the Under Secretary of Defense for Personnel and Readiness to require the Deputy Assistant Secretary of Defense for Civilian Personnel Policy or DCPAS, as delegated, to monitor reviews of LQA eligibility determinations conducted by DOD components.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this action, and as of December 2019, had taken steps to improve oversight of LQA determinations by DOD components; however, it had not issued guidance that requires the Deputy Assistant Secretary of Defense for Civilian Personnel Policy or DCPAS to monitor reviews of LQA eligibility determinations by DOD components. At the direction of DCPAS, DOD components completed reviews and submitted reports of overseas allowances paid to a sampling of overseas employees for calendar years 2015, 2016, and 2017. According to DCPAS officials, in DOD's 2017 review of overseas allowances, one employee was identified as having erroneously received LQA. This number is lower than the three employees identified during the 2016 review and lower than the 11 employees identified in the 2015 review. Additionally, in September 2019, the Deputy Assistant Secretary of Defense for Civilian Personnel Policy issued a memorandum requesting DOD components to complete a review of overseas allowances and differentials, including LQA, paid to overseas employees during calendar year 2018. In January 2018, the Under Secretary of Defense for Personnel and Readiness issued a memorandum that clarified LQA eligibility requirements as applied and interpreted in recent Office of Personnel Management compensation claim decisions and the Department of State Standardized Regulations. The memorandum also required components to screen relevant records and determine if there are any employees who are no longer eligible to receive LQA based on the compensation claim decisions and Department of State Standardized Regulations. Finally, according to DCPAS officials, in December 2019, DOD was revising DOD's LQA instruction to incorporate the new LQA guidance from the January 2018 memorandum. However, it is unclear whether the revised instruction once issued will require the Office of the Deputy Assistant Secretary or DCPAS to monitor the reviews conducted by DOD components to identify any potentially inconsistent eligibility determinations and ensure corrective action is taken, as was the intent of GAO's recommendation.

Recommendation: To enhance participation in and strengthen management of federal student aid programs for teachers, the Secretary of Education should direct Federal Student Aid's Chief Operating Officer to review the underlying cause of the known erroneous conversions to ensure steps Education has taken are sufficient to address the problem, and establish time frames for transferring the approximately 2,600 loan conversions currently with other loan servicers.

Agency: Department of Education
Status: Open

Comments: In its initial response, Education noted it has already taken steps to implement this recommendation, such as a comprehensive assessment to identify the causes of the conversions and the grants affected. After identifying the reasons, the agency worked with current grant servicer to ensure accuracy and make sure they understood program requirements. Regarding time frames for transferring the converted loans, in September 2017, Education provided documentation that the loan conversions were transferred to one servicer in December 2014. In 2018, Education provided additional information on the comprehensive assessment it conducted including the results, a work plan to address the erroneous conversions, and sample letters to recipients they deemed eligible for reconversion. Two changes, however, are currently underway which could affect past and future erroneous conversions. In December 2018, Education announced a process for grant recipients to request reconsideration if their grant was converted in error. Additionally, in 2018, Education's Negotiated Rulemaking Committee began discussing TEACH Grant requirements and ways to reduce and correct the inadvertent conversion of grants to loans, among other things. In April 2019, the subcommittee reached consensus on the proposed rule language, which allowed for erroneous loan conversions to be reversed under certain conditions. As of November 2019, Education has not yet published proposed rules for the TEACH Grant program, and it is unclear the extent to which all eligible recipients will be provided adequate opportunity to have the errors corrected. Given the substantial and ongoing changes to the program administration this recommendation remains open.

Recommendation: To help ensure that it receives accurate information on the full effect of funding decisions on acquisition programs, Congress should consider amending the law that governs the 5-year Capital Investment Plan to require the Coast Guard to submit cost and schedule information that reflects the impact of the annual President's budget request on each acquisition across the portfolio--in addition to the current practice of reporting the cost and schedule estimates in current program baselines.

Agency: Congress
Status: Open

Comments: As of July 2020, Congressional action has not been taken. GAO will continue to follow up with relevant congressional committees.

Recommendation: To help the Coast Guard improve the long-term outlook of its portfolio, the Commandant of the Coast Guard should develop a 20-year fleet modernization plan that identifies all acquisitions needed to maintain the current level of service and the fiscal resources necessary to build the identified assets. The plan should also consider trade-offs if the fiscal resources needed to execute the plan are not consistent with annual budgets.

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

Comments: The agency concurred with this recommendation. Since the issuance of GAO's report, in February 2016, Congress directed the Coast Guard to develop a long-term plan to cover fiscal year 2017 and 20 years thereafter and that it should be updated every two years. In November 2017, officials told GAO that the Coast Guard was developing a 20-year long-term plan that specifically focused on the highest priority recapitalization and sustainment efforts for its assets and will focus on meeting the intent of the 2016 congressional mandate. However, as of July 2020, the Coast Guard has not completed this plan. At that time, officials said that the Coast Guard continues to refine the process to define the long term acquisition and capital sustainment needs of the Service and align them with published and anticipated fiscal top line budgets. The Coast Guard is working with internal and external stakeholders to define useful parameters in order to complete work to close this recommendation. GAO will continue to monitor the Coast Guard's actions in completing its long-term plan given that GAO's recent work has found that the Coast Guard continues to pursue an unaffordable acquisition portfolio that is not likely to fully address all known and anticipated capability gaps.

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: 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: If cost savings are to be a goal of any future BRAC round, Congress may wish to consider amending the BRAC statute by elevating the priority DOD and the BRAC Commission give to potential costs and savings as a selection criterion for making base closure and realignment recommendations.

Agency: Congress
Status: Open

Comments: All the Matters for Congressional Consideration are contingent on the implementation of another round of BRAC. As of June 30, 2020, Congress has not authorized another round of BRAC.

Recommendation: If Congress authorizes additional BRAC rounds, it may wish to consider amending BRAC legislation by requiring the Secretary of Defense to formally establish specific goals that the department expects to achieve from a future BRAC process.

Agency: Congress
Status: Open

Comments: All the Matters for Congressional Consideration are contingent on the implementation of another round of BRAC. As of June 30, 2020, Congress has not authorized another round of BRAC.

Recommendation: If Congress authorizes additional BRAC rounds, it may wish to consider amending BRAC legislation by requiring the Secretary of Defense to propose selection criteria as necessary to help achieve those goals, if necessary and appropriate.

Agency: Congress
Status: Open

Comments: All the Matters for Congressional Consideration are contingent on the implementation of another round of BRAC. As of June 30, 2020, Congress has not authorized another round of BRAC.

Recommendation: If Congress decides to authorize a future base closure round, it may want to consider whether to limit or prohibit the BRAC Commission from adding a contingent element to any recommendation and, if permitted, under what conditions.

Agency: Congress
Status: Open

Comments: All the Matters for Congressional Consideration are contingent on the implementation of another round of BRAC. As of June 30, 2020, Congress has not authorized another round of BRAC.

Recommendation: To reduce the incentive for facilities to restrict their service provision to avoid reaching the LVPA treatment threshold, the Administrator of CMS should consider revisions such as changing the LVPA to a tiered adjustment.

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

Comments: As of February 2020, CMS had not implemented this recommendation. CMS stated in February 2020 that the agency had extensive discussions with the Medicare Payment Advisory Commission regarding the Commission's suggestions for modifying the LVPA. CMS also stated that the agency was analyzing the design of the LVPA as part of its evaluation of the ESRD Prospective Payment System. This recommendation remains open because CMS has not provided documentation of steps such as those described above that the agency has taken to consider revisions to the LVPA. We will update the status of this recommendation upon receipt of additional information from CMS.

Recommendation: To more effectively implement SBA's expansion of OIT field staff as required by the SBJA, the Administrator of the SBA should update SBA's plan for additional OIT staff to include funding sources and time frames, as well as possible efficiencies from clearly defining roles and responsibilities and leveraging other entities' export assistance resources.

Agency: Small Business Administration
Status: Open
Priority recommendation

Comments: SBA concurred with our recommendations. In response to the Small Business Jobs Act of 2010 (SBJA) requirement that a total of 30 export finance specialists be hired nationwide by September 2012, SBA noted resource constraints and filled only 19 positions at that time. In 2016, SBA reported progress toward the SBJA requirement despite agency staffing limitations and staffed a total of 21 or 70% of the 30 required export finance specialist (EFS) positions. SBA officials also reported that they had hired staff to replace retirements or other staff departures, but determined that because of finite funding resources it would not be feasible to hire additional OIT staff. They instead took steps to mitigate the shortfall by engaging other field office staff to more proactively market its international trade programs to small businesses. In particular, in 2017, as part a result of the new Administrations' Agency Reform plan, SBA undertook a Field Alignment Project. Specific to OIT, this project was intended to better leverage certain District office field staff such that they would increase outreach efforts to promote exports as required by the SBJA and in response to GAO's recommendations. This was done by assigning district staff new specific output goals intended to increase export promotion activities. In January 2020, OIT reported hiring four additional export finance specialists, bringing the total hired to 25. OIT also reported establishing a strategy for future hires to be assigned to existing Export Assistance Centers, and requesting fiscal year 2021 funding to hire individuals to fill the remaining five positions. While these steps partially mitigate the shortfall and are in the spirit of the SBJA requirement and GAO's recommendations, as of January 2020 SBA has not yet achieved the 30 export finance specialists required by the SBJA.

Recommendation: To help ensure that Congress is fully apprised of efforts to resolve a case, Congress may wish to consider amending USERRA to require DOJ and OSC to report on additional time taken to resolve a matter after they decline representation.

Agency: Congress
Status: Open

Comments: As of February 4, 2020, this matter has not yet been considered by Congress.

Recommendation: To help ensure that that servicemembers who file complaints are adequately being informed of their USERRA complaint process rights in accordance with VBIA 2008, Congress may wish to consider amending USERRA to require DOL to report on the extent to which it is notifying complainants of their USERRA complaint process rights within 5 days of filing a complaint.

Agency: Congress
Status: Open

Comments: As of February 4, 2020, this matter has not yet been considered by Congress.

Recommendation: To help ensure that DOJ handles state cases as expediently as private employer cases, Congress may wish to consider amending USERRA to specifically require DOJ to adhere to the same 60-day deadline for state employer matters that they must adhere to for matters against private employers.

Agency: Congress
Status: Open

Comments: As of February 4, 2020, this matter has not yet been considered by Congress.

Recommendation: To help ensure that servicemembers in state employer cases are kept apprised of the status of DOJ's decision making without potentially compromising DOJ's ability to successfully bring suit against state employers, Congress may wish to consider amending USERRA to require DOJ to notify these servicemembers of the status of DOJ's efforts.

Agency: Congress
Status: Open

Comments: As of February 4, 2020, this matter has not yet been considered by Congress.

Recommendation: To help ensure that CFTC and SEC are strategically positioned to implement the joint report's recommendations and address remaining harmonization opportunities, as CFTC and SEC continue to develop the charter for the Joint Advisory Committee, the Chairmen of CFTC and SEC should take steps to establish, with associated time frames, clearer goals for future harmonization efforts and requirements for reporting and evaluating progress toward these goals. Specifically, the agencies could benefit from formalizing a plan to assess implementation of the joint report's recommendations and harmonization opportunities that may not have been fully addressed by the joint report, such as differences in market structure and investor definitions. Such a plan could include goals for future harmonization efforts, such as time frames for implementing the recommendations; assessment of whether remaining differences in statutes and regulations result in inconsistent regulation of similar products and entities that could lead to opportunities for regulatory arbitrage; and periodic reports to Congress on their progress, including the implementation and impact of the recommendations.

Agency: Commodity Futures Trading Commission
Status: Open

Comments: In July 2018, the CFTC and SEC Chairmen signed an updated version of a Memorandum of Understanding (MOU) originally signed in 2008. The new MOU created an updated framework for information sharing to make it easier for the two agencies to share information. A CFTC official noted that the MOU underscored two agencies' commitment to addressing harmonization efforts. In addition, CFTC officials identified examples of harmonization areas where CFTC and SEC have made some additional progress. This recommendation remains open until CFTC identifies steps taken to create a plan for assessing progress on working with SEC on remaining harmonization opportunities.

Recommendation: Given the increasing extent of business travel to the U.S. and the eroding effect of inflation, Congress may wish to consider raising the amount of U.S. income paid by a foreign employer that is exempt from tax for nonresidents who meet the other conditions of the exemption.

Agency: Congress
Status: Open

Comments: As of August 2019, Congress has not raised the amount of U.S. income paid by a foreign employer that is exempt from tax for nonresidents who meet the other conditions of the exemption.

Recommendation: Given the difficulty of enforcing the requirement for aliens to obtain certificates of compliance--sailing permits--before departing the country and the existence of withholding requirements and tax treaties, Congress may wish to consider eliminating the sailing permit requirement.

Agency: Congress
Status: Open

Comments: As of August 2019, Congress has not eliminated the sailing permit requirement.

Recommendation: In order to better assess whether changes are needed in the way IRS administers activities not engaged in for profit provisions, the Commissioner of Internal Revenue should take steps to estimate the extent of activities not engaged in for profit noncompliance from its ongoing research programs.

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

Comments: IRS agreed to research sole proprietor noncompliance, as GAO recommended in September 2009. It is focusing on those who improperly claim business losses (i.e., not profits). IRS's Office of Research, Analysis and Statistics is using the reporting compliance study of Form 1040 filers to gather the data on such noncompliant business losses. This research covered sampled tax returns filed for tax years 2009, 2010, and 2011 and used audits of the sampled tax returns that are filed for each tax year. In November 2016, IRS research officials provided the initial rough estimates of the percentage of disallowed losses and associated dollar amounts for all 3 tax years but as of December 2019, they had not yet indicated how these estimates helped IRS to understand the nature of the tax noncompliance. The officials cautioned that their ability to develop the estimates depends on the number of observations that can be applied from each tax year. This research, when completed, could help IRS to identify noncompliant sole proprietor issues and take action to reduce losses.

Recommendation: To support the triennial review program's goal of having grantees consistently meet more federal requirements, the Secretary of Transportation should direct the FTA to ensure that additional outcome and quality performance measures are balanced with the existing measures for assessing the timeliness of the triennial review program so that one priority is not emphasized at the expense of others.

Agency: Department of Transportation
Status: Open

Comments: Federal Transit Administration (FTA) anticipates adding a performance measurement, called reduction in repeat findings, that relates to assessing the quality of the review. This has been added to FTA's new Quality Review program focused on improving its Triennial Review program.

Recommendation: To address the current information gap in Regulation SHO for prime brokerage arrangements and mitigate the impact of any unintended consequences caused by SEC rules, as well as ensure consistent implementation of SEC rules by the industry, the Chairman of the Securities and Exchange Commission should finalize, in an expedited manner upon finalization of the temporary rule, the revised 1994 Prime Broker Letter.

Agency: United States Securities and Exchange Commission
Status: Open

Comments: As of June 4, 2019, the revised Prime Broker letter has not been finalized. Staff from the Reg SHO team in SEC's Trading and Markets division stated that they have regularly and continuously asked the industry for comments on the Prime Broker Letter without receiving any real progress. Their most recent request for comments was emailed to industry counsel on May 22, 2019. Industry counsel acknowledged the request but have yet to provide comments.