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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Agency: Congress
Status: Open

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Agency: Department of the Treasury
Status: Open

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

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

Agency: Department of State
Status: Open

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

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

Agency: Social Security Administration
Status: Open

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

Recommendation: The Commandant of the Coast Guard should work with Congress to include in the Coast Guard's annual 5-year CIP a discussion of the acquisition programs it prioritized that describes how trade-off decisions made could affect other acquisition programs, such as by delaying recapitalization efforts or needing to conduct Service Life Extension Projects for legacy assets. (Recommendation 1)

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

Comments: The Coast Guard agreed with this recommendation and in August 2019 officials reported that the Coast Guard is working with DHS to include additional information that addresses how trade-off decisions made could affect other major acquisition programs in future CIP reports. It anticipates including this information in the FY 2021-2025 CIP, which it expects to release in late summer 2020.

Recommendation: The Commandant of the Coast Guard should require the Executive Oversight Council, in its role to facilitate a balanced and affordable acquisition portfolio, to annually review the acquisition portfolio collectively, specifically for long-term affordability. (Recommendation 2)

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

Comments: The Coast Guard disagreed with this recommendation stating that other bodies within the Coast Guard--such as the Investment Board, Deputies Council, and Investment Review Board--are responsible for making decisions regarding out-year funding, while the Executive Oversight Council works outside of the annual budget process. DHS also stated that, to meet the spirit of our recommendation, the Coast Guard will update the Executive Oversight Council's charter to require a review of the collective acquisition portfolio, specifically evaluating long-term planning. We believe that updating the Executive Oversight Council's charter to include long-term-planning is a positive step. However, we continue to believe that in addition to long-term planning, the Executive Oversight Council should include the major acquisition portfolio's budget realities faced by the Coast Guard in its reviews, or long-term affordability. If the planning accounts for long-term funding considerations to achieve the Coast Guard's acquisition goals and objectives, we believe the intent of our recommendation would be met. The Coast Guard expects to complete the update of the EOC charter by by late summer 2020.

Recommendation: The Commandant of the Coast Guard should establish and follow a sound air station optimization process similar to its process for analyzing boat stations to allow it to comprehensively analyze its need for air stations and air facilities and determine what changes may be needed. (Recommendation 1)

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

Comments: In 2017, GAO reported that a 2014 Coast Guard contracted analysis of selected air stations and air facilities identified overlap and unnecessary duplication but it did not comprehensively review all air stations and air facilities. The analysis determined that certain air facilities (Newport, Oregon, and Charleston, South Carolina) provided overlapping search and rescue coverage, some of which was unnecessarily duplicative. Coast Guard officials used the results of this analysis to support proposed closures of the air facilities in the President's Fiscal Year 2014 Budget. However, shortly before their planned closure date, the Coast Guard encountered strong opposition to the closures at the local, state, and Congressional levels, and did not close them. The Coast Guard agreed with GAO's recommendation that it establish and follow a sound air station optimization process and comprehensive analysis to determine what changes may be needed. In its December 2017 60-Day letter response, DHS said the Coast Guard will utilize the FY 2020 Planning, Programming, Budget, and Execution cycle to identify efficiencies in air station optimization and that the cycle is proceeding as planned. However, the response did not say whether the Coast Guard will act on findings and permanently close stations identified as overlapping, unnecessarily duplicative, and unnecessary, if any are identified. As of March 2020, the agency has identified the need for further analysis and estimates completion of these analyses in March 2021.

Recommendation: The Commandant of the Coast Guard should establish a plan with target dates and milestones for closing boat stations that it has determined, through its 9-step process and subsequent analysis, provide overlapping search and rescue coverage and are unnecessarily duplicative. (Recommendation 2)

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

Comments: In 2017, GAO reported that the Coast Guard has a sound process for analyzing its boat stations that includes clear and specific steps for analyzing the need for stations using terms that can be readily defined and measured. A 2013 analysis of Coast Guard stations identified unnecessary duplication and recommended certain stations that could be permanently closed without negatively affecting the Coast Guard's ability to meet its 2-hour search and rescue response standard and other mission requirements; however, as of August 2017 the Coast Guard had not closed any stations, nor developed a plan with time frames for closing stations even though leaders said the results of the analysis remain valid. Closing unneeded stations has historically been difficult due to public concern about the effect of closures on local communities and other factors. In some cases over the years, Congress has intervened and enacted federal laws that have affected Coast Guard's proposed closures. Nevertheless, the Coast Guard agreed with GAO's recommendation that it establish a plan with target dates and milestones for closing stations. In its December 2017 60-Day letter response, DHS said the Coast Guard Office of Boat Forces continues to evaluate the optimal number, location, and configuration of stations to better meet mission requirements, and is finalizing analysis of operational needs in Coast Guard Districts One (D1) and Five (D5). As of December 2019, the agency had completed additional analyses and reported that it was considering changes in operations for several stations. The Coast Guard estimated that it will continue to consider changes until spring 2020. However, the Coast Guard did not establish target dates or milestones for closing stations. By developing a plan with target dates and milestones for closing stations that are unnecessarily duplicative, the Coast Guard would be better positioned to improve operations and achieve cost savings over time.

Recommendation: The Commandant of the Coast Guard should take action to close the stations identified according to its plan and target dates. (Recommendation 3)

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

Comments: In 2017, GAO reported that the Coast Guard has not taken action to implement the results of its analyses which recommended station closures even though it has completed requirements to pursue some station closures. For example, a 2013 analysis of Coast Guard stations identified unnecessary duplication and recommended certain stations that could be permanently closed without negatively affecting the Coast Guard's ability to meet its 2-hour search and rescue response standard and other mission requirements. However, as of August 2017 the Coast Guard had not closed any stations, nor developed a plan with time frames for closing stations even though Coast Guard leaders said the results of the analysis remain valid. GAO reported that the Coast Guard had not closed stations because past efforts to close stations (eight attempts since 1973) were met with resistance from affected communities and instances where the Congress intervened. Nevertheless, the Coast Guard agreed with GAO's recommendation that it establish a plan with target dates and milestones for closing stations. In its December 2017 60-Day letter response, DHS said that once analyses of the need for and locations of boat stations are completed for Coast Guard Districts One and Five, the Coast Guard will commence Congressional engagement and public outreach regarding any operational changes to D1 and D5 stations, if any, including processing feedback from stakeholders before making final decisions on recommended changes. As of December 2019, the Coast Guard reported that it was considering changes in operational status for several stations. The Coast Guard estimated that it will continue to consider changes until spring 2020, which, if implemented, will be more than 7 years after it proposed station closures. By closing unnecessarily duplicative stations, the Coast Guard could be better positioned to improve its operations and achieve cost savings over time.

Recommendation: To ensure that the elements of the agency's process for making asset maintenance decisions are achieving desired outcomes, the Secretary of the Interior should direct the Director of the Park Service to evaluate the Capital Investment Strategy and its results to determine if it is achieving its intended outcomes or if changes need to be made.

Agency: Department of the Interior
Status: Open

Comments: According to NPS officials, the agency is currently working to address this recommendation and expects to complete it in August 2020. GAO will update the status of the recommendation as soon as possible thereafter.

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

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

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

Recommendation: To improve 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: The Commissioner of IRS should direct the appropriate IRS officials to establish procedures to monitor whether non-IRS contractors with unescorted physical access to IRS facilities are receiving unauthorized access awareness training.

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

Comments: During fiscal year 2018, Facilities Management and Security Services (FMSS) established training requirements for non-IRS contractors with unescorted physical access to IRS facilities and communicated these requirements to its employees. However, FMSS did not establish procedures to monitor whether these non-IRS contractors receive the required unauthorized access awareness training. In addition, during our fiscal year 2019 audit, we found instances in which non-IRS contractors with unescorted physical access to an IRS facility did not complete the required training.

Recommendation: The Commissioner of IRS should direct the appropriate IRS officials to determine why staff did not consistently comply with IRS's existing requirements for the final candling of receipts at service center campuses and lockbox banks, including logging remittances found during final candling on the final candling log at the time of discovery, safeguarding the remittances at the time of discovery, transferring the remittances to the deposit unit promptly, and passing one envelope at a time over the light source, and based on this determination, establish a process to better enforce compliance with these requirements.

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

Comments: IRS's actions to address this recommendation are ongoing. During fiscal year 2017, IRS held a meeting with Submission Processing executives, staff, and the Receipt and Control Operation managers from all five service center campuses (SCC), and as a result of the meeting, IRS developed an action plan to resolve the residual risks associated with candling at the SCCs. IRS officials stated that during fiscal year 2020, it will complete the developed action plan.

Recommendation: To promote retirement savings without creating permanent tax-favored accounts for a small segment of the population, Congress should consider revisiting the use of IRAs to accumulate large balances and consider ways to improve the equity of the existing tax expenditure on IRAs. Options could include limits on (1) the types of assets permitted in IRAs, (2) the minimum valuation for an asset purchased by an IRA, or (3) the amount of assets that can be accumulated in IRAs and employersponsored plans that get preferential tax treatment.

Agency: Congress
Status: Open

Comments: No legislation limiting account owner accumulations enacted as of February 2020. In its October 2014 report, GAO found that individuals with limited, occupationally related opportunities could engage in sophisticated investment strategies and accumulate considerable tax-preferred wealth in IRAs and subsequently suggested to Congress legislative options. The Senate Finance Committee held a hearing on a range of IRA policy issues in September 2014 for which GAO provided a statement for the record that covered preliminary data on IRA balances. The Setting Every Community Up for Retirement Enhancement Act of 2019, enacted in December 2019 as division O of the Further Consolidated Appropriations Act, 2020, amended a number of requirements related to retirement accounts (Public Law 116-94). For example, section 401 limits inherited beneficiaries' ability to continue tax deferral to 10 years beyond the account owner's death. This provision somewhat reduces the long-term financial benefits of accumulating large balances in IRA accounts. However the Act did not adopt any of the other limits identified in GAO's October 2014 report. Without legislation, the intended broad-based tax benefits of IRAs are likely to continue to be skewed toward a select group of individuals.

Recommendation: To improve IRS's ability to detect and pursue noncompliance associated with undervalued assets sheltered in IRAs and prohibited transactions, the Commissioner of Internal Revenue should work in consultation with the Department of the Treasury on a legislative proposal to expand the statute of limitations on IRA noncompliance to help IRS pursue valuation-related misreporting and prohibited transactions that may have originated outside the current statute's 3-year window.

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

Comments: IRS agreed with GAO's October 2014 recommendation on IRAs with large balances and said it had discussed the recommendation with Treasury's Office of Tax Policy and Benefits Tax Counsel. Consequently, IRS said Treasury is aware of IRS's willingness to support legislative efforts in this area. Ultimately, Treasury reviews all tax legislative proposals and presents the administration's tax proposals for congressional consideration. However, Treasury has not released a legislative proposal as of January 2020. GAO reported in January 2020 that IRS examination said the 3-year statute of limitations for assessing taxes owed remains an obstacle in pursuing noncompliance that may span the many years of an IRA investment.

Recommendation: To help taxpayers better understand compliance risks associated with certain IRA choices and improve compliance, the Commissioner of Revenue should, building on research data on IRAs holding nonpublic assets, identify options to provide outreach targeting taxpayers with nonpublic IRA assets and their custodians, such as reminder notices that engaging in prohibited transactions can result in loss of the IRA's tax-favored status.

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

Comments: IRS has taken some action to provide general outreach and as of January 2020 has ongoing compliance research that could inform additional opportunities to target outreach to taxpayers with nonmarketable IRA assets at greater risk of noncompliance, as GAO recommended in October 2014. In June 2016, IRS published information on IRS.gov outlining the new information to be reported for nonmarketable IRA assets and included a general caution that IRAs with nonmarketable investments or assets under direct taxpayer control may be subject to a heightened risk of committing prohibited transactions. This caution is similar to those that IRS added to its publications about IRA contributions and distributions. It is a step toward helping taxpayers better understand which investments pose greater risks. In February 2018, IRS completed its first analysis of new information about the amounts and types of nonpublic IRA assets from Form 5498 for tax year 2016 that was filed in 2017. In October 2019, IRS also completed an interim compliance research project examining a sample of tax returns to determine whether the beneficiary of the IRA caused his or her IRA to engage in a prohibited transaction. As of January 2020, IRS was conducting a new compliance research project examining IRAs holding certain nonpublic asset types. The compliance research began in February 2019 and is to be completed in January 2021. Unless IRS augments outreach based on reliable data about nonpublicly traded IRA investments, taxpayers at greater risk may not be able to ensure compliance with rules on prohibited transactions.

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.