Open Recommendations

The Commissioner, TE/GE Division, should better align procedural guidance for TECU examination referrals with CP&C criteria for assigning cases to the Examination functions.

Direct Brown to provide documentation supporting that it has repaid or otherwise credited the $47,384 in questioned publication, materials and supplies, and long-term visa costs for which it has agreed to reimburse NSF.

Direct Brown to implement additional procedures which require it to verify that a publication acknowledges the NSF funding source(s) that supported the published research prior to the expense being charged to the NSF award(s).

Direct Brown to establish additional guidance regarding how to review invoices and receipts that include materials and supplies charged to NSF awards. This guidance should address how to ensure materials and supplies expenses are allowable and properly allocated to the funding sources that directly benefit from the purchase.

Direct Brown to create additional resources that provide guidance regarding the allowable charging of visa fees on NSF awards. This guidance should address how Brown will ensure it does not charge unallowable long-term visa fees to NSF awards.

Resolve the $17,059 in questioned inappropriately allocated publication costs and direct Brown to repay or otherwise remove the sustained questioned costs from its NSF awards.

Direct Brown to provide documentation supporting it has repaid or otherwise credited the $7,204 in questioned materials and supplies expenses for which it has agreed to reimburse NSF.

Direct Brown to produce formal written guidance and provide training on how to assess and document the methodology used to allocate publication costs consistent with the benefits received by acknowledged funding sources.

Direct Brown to update its processes and procedures to require Principal Investigators or other designated staff to both document and justify the allocation methodologies used when charging expenses to NSF awards near grant expiration dates.

Direct Brown to provide documentation supporting that it has repaid or otherwise credited the $6,671 in questioned indirect costs for which it has agreed to reimburse NSF.

Direct Brown to update its current award set-up practices to: (1) ensure that it sets up accounts for NSF awards, such that each account applies indirect costs using the appropriate rates established in the Negotiated Indirect Cost Rate Agreement in effect as of the date of grant award; and/or (2) document its decision to apply indirect costs using lower rates.

Direct Brown to strengthen its policies, procedures, or internal controls for how to verify—and how to document its verification of—its subawardees’ election to use proposed indirect cost rates. This should address how Brown will ensure that the decision to use proposed indirect cost rates will not result in NSF being overcharged for indirect costs in cases when negotiated rates decrease between the date a subaward is proposed and the date a subaward is awarded, within a single Negotiated Indirect Cost Rate Agreement.

Direct Brown to strengthen its policies, procedures, and internal control processes for applying its federally negotiated indirect cost rates to NSF awards. These updated policies, procedures, and internal control processes should ensure Brown is: • Appropriately applying its indirect cost rates to all direct costs that should be included in its Modified Total Direct Cost base per its negotiated indirect cost rate agreements. • Accurately classifying all costs for accounts that are included within its Modified Total Direct Cost base per its negotiated indirect cost rate agreements.

Direct Brown to strengthen its internal controls for retaining documentation to support lodging expenses. These updated internal controls could include providing annual training to ensure travelers and individuals responsible for approving travel reimbursements are aware of the documentation required for reimbursement per its institutional policies.

Direct Brown to strengthen its monitoring procedures to ensure it appropriately applies the fringe benefit rates included within its negotiated indirect cost rate agreements.

We recommend that EAC confirm that the Georgia Secretary of State’s Office implements corrective action to address recommendation 8 in Report Number 21-11 issued by the Georgia Department of Audits and Accounts.

We recommend that EAC calculate lost interest due to the untimely deposit of 2018 and 2020 Election Security funds and ensure any amounts due are deposited into to the election fund.

We recommend that EAC require the Georgia Secretary of State’s Office to reconcile interest earned reported by the Georgia Office of the State Treasurer and interest earned recorded on the general ledger and correct any impacted financial reports for the reissued Section 101, reissued Section 251, and Election Security awards.

We recommend that the FEMA Administrator direct FEMA Regions to:• begin administrative closeout of the 26 grant programs we identified with expired periods of performance to the extent permitted by the Stafford Act, for those with no pending requests for extension or lacking acceptable justifications for extension, and deobligate the associated $9.4 million in remaining funds;• assess and close, as appropriate, the 42 grant programs in our scope representing $7 billion in unliquidated funding; and• conduct a review of all authorized grant programs with expired periods of performance to determine whether to administratively closeout and deobligate remaining fund balances, to…

We recommend that the FEMA Administrator consistently apply FEMA Manual 205-0-1, Grants Management requirements, including that the recipient’s request and FEMA’s determination for extensions must be in writing and signed, and that FEMA’s determination include the rationale for the decision, including how the facts meet the applicable guidelines.

We recommend that the designated personnel complete training in detecting counterfeit system components (including hardware, software, and firmware) and best practices for counterfeit component prevention.

Review the data asset inventory to ensure that all data assets owned by the Commission are identified and enhance the Commission’s Privacy Policies and Procedures to address the gaps that were identified in the current Privacy Policy.

Revise regulations to require documents that can be verified to ensure firms complied with 13 CFR § 126.200(d)(3), that a legacy employee resided in a HUBZone for at least 180 days following the most recent certification (or recertification).

Update and implement standard operating procedures to request documents, as permitted under 13 CFR 126.304(b)(1), to verify during program examinations that firms meet size standards in the North American Industry Classification System code in which they perform on HUBZone contracts.

Improve the HCTS system notification module to ensure recertification notifications are sent timely and consistently to all HUBZone firms.