Open Recommendations

Complete the enterprise-wide data inventory.

Document and implement a standard operating procedureto maintain the enterprise-wide data inventory as new datacollections are created and old data collections are retired.

Collaborate with NARA’s Chief Information Officer todocument and implement a standardized process tomonitor service level agreements with cloud-based serviceproviders. The process should include the monitoringresponsibilities of the Contracting Officer’sRepresentatives and actions NARA should take if acontractor does not meet the defined service levels.

Document and implement a process to incorporate theCloud Service Provider's Quality Assurance SurveillancePlan as part of future cloud service contracts. Whereincorporation of a Cloud Service Provider QualityAssurance Surveillance Plan is not anticipated, NARAshould incorporate its own Quality Assurance SurveillancePlan and service level agreements at the solicitationphase, these should align with commercial best practices.

Implement a documented process requiring the assignment of aQuality Assurance Evaluator for future relocation of records project(s).

Ensure a Quality Assurance Surveillance Plan is developed andimplemented requiring onsite supervision to provide proper oversight and compliancewith the PWS.

In collaboration with applicable parties, ensure PWS requirementsare developed to reflect the procedures necessary to protect and account for therelocation of archival records that should include:a. Implementing a documented process requiring the assignment of a QualityAssurance Evaluator for future relocation of records project(s).

In collaboration with applicable parties, ensure PWS requirementsare developed to reflect the procedures necessary to protect and account for therelocation of archival records that should include:Ensuring a Quality Assurance Surveillance Plan is developed, approved, andimplemented requiring onsite supervision to provide proper oversight andcompliance with the PWS.

Develop and implement standard operating procedures to ensurethat Research Services personnel comply with the PWS requirements.

Develop and implement standard operating procedures tocommunicate final PWS requirements to all responsible parties before the contract isawarded.

We recommend that the FAS Commissioner establish an oversight process for CSP-based contracts undergoing consolidation to ensure contracting personnel: (a) comply with General Services Acquisition Regulation 538.270-1, Evaluation of offers without access to transactional data, and FAS Policy and Procedure 2021- 05, Evaluation of FSS Program Pricing; and gather supporting documentation to determine a contractor’s most favored customer pricing for use in negotiation objectives; and (b) evaluate supporting documentation to verify a clear and relevant relationship between supporting documentation and each of the proposed prices it is meant to substantiate.

We recommend that the FAS Commissioner establish an oversight process for TDR pilot contracts undergoing consolidation to ensure contracting personnel do not rely solely on contract-level pricing tools; and, if prices paid data is not available, prioritize obtaining recent invoices or other than certified cost or pricing data from the contractor before relying on non-prices paid information.

We recommend that the FAS Commissioner re-evaluate previously consolidated MAS contracts to ensure that added products or services were evaluated to meet federal regulations and GSA policy requirements.

We recommend that GSA’s Chief Information Officer correct the geospatial data quality deficiencies identified in our report.

We recommend that GSA’s Chief Information Officer implement controls to ensure that the Inventory of Owned and Leased Properties (IOLP) and Federal Real Property Profile Management System (FRPP MS) datasets contain accurate latitude and longitude coordinates based on each property’s physical location except for those properties with a clear exemption for national security.

We recommend that GSA’s Chief Information Officer strengthen the data validation process for the IOLP and FRPP MS datasets to address the geospatial data quality deficiencies identified in our report.

We recommend that GSA’s Chief Information Officer establish a process to ensure GSA searches existing geospatial data before procuring new data, including: ensuring the Geographic Information Systems Center of Excellence is notified of future geospatial data needs prior to awarding a new contract for geospatial data; and improving Agency-wide awareness of the requirement to search existing geospatial data prior to awarding a new contract for geospatial data.

We recommend that the DNFSB implement the DNFSB’s Vulnerability Management Standard Operating Procedure for vulnerability and compliance management based on the risk and level of effort involved in mitigating confirmed vulnerabilities on a case-by-case basis, such as:a) Remediating vulnerabilities in accordance with the DNFSB Vulnerability Management Standard Operating Procedure.b) Opening plans of action and milestones to track critical and high-risk vulnerabilities that the DNFSB cannot address within 30 days.c) Preparing risk-based decisions in unusual circumstances in which a technical or cost limitation makes it infeasible to mitigate a critical or high-risk vulnerability, including identifying documented, effective compensating controls coupled with…

We recommend that the DNFSB (1) ensure that personnel complete privacy awareness and literacy training upon initial hire and annually thereafter, and (2) maintain training records in accordance with the DNFSB Security and Privacy Awareness and Training Program Standard Operating Procedure.

We recommend that the DNFSB update and finalize the Incident Response Plan and Incident Response Process Guide Cyber Playbook to incorporate lessons learned from incident response exercises.

We recommend that the DNFSB ensure all personnel with incident response responsibilities participate in incident response exercises.

Pay the five unpaid detainees who were released without pay or provide an explanation of the circumstances that prevent payment.

Implement internal controls that ensure timely and appropriate responses to the detainee request process.

Ensure ICE staff respond appropriately to detainee requests.

Identify process gaps and update NUREG-1021 to ensure that guidance in future revisions remains current and addresses emerging issues.